Conflict of Interest Mitigation Guidelines for Graduate Education

Actual or perceived conflicts of interest or commitment between the role of a graduate student and other Virginia Tech or external entities may arise for a variety of reasons, including but not limited to:

• VT employees pursuing graduate degrees or graduate coursework at Virginia Tech
• Students having a close connection with a faculty member or assistantship supervisor through marriage or other family relationship or through social settings such as clubs,  religious or civic organizations, etc.
• Students having a non-employment-based financial relationship with their advisor, supervisor, or committee member through a housing arrangement, personal loan, or other means 
• Students engaging in outside employment or business activity with their instructor, advisor, assistantship supervisor, or committee member
• Students having an advisory committee member who is employed by an outside entity that is financially supporting the student’s assistantship or the student’s or VT advisor(s)’ research
• Students engaging in consulting or other entrepreneurial activities that may interfere with or unduly influence their graduate studies
• Other conflicts due to personal or professional circumstances or choices

Perceived or actual conflicts can imperil the quality or integrity of the student’s experience, the graduate program, and/or the work environment. Thus potential conflicts of interest must be identified, documented, and managed to avoid any actual or perceived inappropriate personal, financial, or professional influence over the graduate student’s academic program, research, teaching, or other efforts related to their graduate education.

Procedures

Starting in 2025, graduate students receive a notice upon admission and a semi-annual reminder of COI guidelines. In addition, the Graduate School specifically monitors the potential conflicts of interest that may develop when VT employees pursue graduate degrees or graduate coursework at Virginia Tech. 

When a potential conflict of interest is identified, or if it is determined that there is no conflict between a student's status as an employee and their taking graduate courses at VT, use the Conflict of Interest Mitigation In Graduate School form to document the potential conflict and corresponding mitigation plan, or to show that there is no conflict between the student and employee status. 

When a COI Mitigation form is submitted and approved by the Graduate School, the decision is noted in the student's record with or without an expiration date based on the type of conflict and mitigation plan. If a significant parameter of enrollment or employment changes, or if a new and different type of potential conflict arises, the student must submit a new COI Mitigation form.

Examples of documentation:

• Employees whose enrollment is in no conflict with their employment may show any or all of the following (signature from employee/student, employment supervisor, and graduate program director are required for all students enrolled in a degree- or certificate program; for students in commonwealth status a signature from the employee/student and employment supervisor are sufficient): 
  • enrollment is in coursework only with no connection between employment and enrollment
  • there is no overlap between employment supervisor(s) and academic advisor/committee/instructors        
  • employment work does not in any way overlap with the coursework or research 
• Employees whose enrollment and employment may present potential conflict will need to show how employment and academic duties, responsibilities and evaluation are clearly separated, and how each is managed and evaluated independently. 
  • signature from employee/student, employment supervisor and graduate program director required; signature of advisor/committee chairperson required if Plan of Study has been filed       
• Documentation of clear separation of roles, access controls, funding arrangements, or alternative arrangements for oversight of the student's work that prevents undue influence over the student's academic pursuit
  • signature from employee/student, employment supervisor and graduate program director required; signature of advisor/committee chairperson required if Plan of Study has been filed       

Additional information, policies and procedures about conflict(s) of interest at Virginia Tech: 

• https://financialmanagement.vpfin.vt.edu/business-practices/dbmg/conflict-of-interest.html
• https://www.research.vt.edu/research-support/forms-guidance/conflict-interest.html
• https://www.research.vt.edu/sirc/disclosure/contacts.html
• https://www.research.vt.edu/sirc/disclosure/researcher.html