Disclosures to Federal Research Sponsors
Current as of April 15, 2024
Learn about disclosures that must be to federal research sponsors as part of research security.
Overview
Federal sponsors currently have varying requirements for the 糖心传媒淐urrent and Pending (Other) Support糖心传媒� and 糖心传媒淏iographical Sketch糖心传媒� disclosures. Beginning May 2024, NSF has adopted new 糖心传媒淐ommon Disclosure Forms糖心传媒� for 糖心传媒淐urrent and Pending (Other) Support糖心传媒� and 糖心传媒淏iographical Sketch.糖心传媒� Other federal agencies are expected to adopt the Common Disclosure Forms over time. For more information on the Common Disclosure Form requirements, please review the University糖心传媒檚 Common Disclosure Form guidance.
The following is intended to provide general guidance to researchers and departments regarding disclosures that support research security. For more specific agency requirements, researchers should consult the resources identified below, or contact their ORPA Research Administrator.
Current and Pending (Other) Support Information
Federal sponsors have expressed increasing concern over full and complete disclosure of all applicable 糖心传媒淐urrent and Pending (Other) Support.糖心传媒� Such disclosures assist federal agencies in identifying potential financial conflicts of interest, and may help prevent scientific, budgetary, or commitment overlap. Federal sponsors currently have varying requirements for the reporting of 糖心传媒淐urrent and Pending (Other) Support.糖心传媒� 糖心传媒淐urrent and Pending (Other) Support糖心传媒� can come in many forms, such as resources and financial support, both domestic and foreign. University researchers should ensure they disclose all applicable 糖心传媒淐urrent and Pending (Other) Support糖心传媒� as required by federal sponsors.
As discussed further in聽this University guidance, the CHIPS and Science Act of 2022 prohibits research and development awards from being made for any proposal in which a covered individual is participating in a 糖心传媒渕align foreign talent recruitment program.糖心传媒� Nevertheless, researchers should disclose whether they are party to any type of foreign talent program in 糖心传媒淐urrent and Pending (Other) Support.糖心传媒� Likewise, support provided in connection with an appointment or affiliation at a foreign institution should be disclosed in 糖心传媒淐urrent and Pending (Other) Support.糖心传媒�
The National Institutes of Health (NIH) (1) supporting documentation, which includes copies of contracts/agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support, and (2) immediate notification to NIH of undisclosed Other Support.
Effective October 10, 2025, the National Science Foundation (NSF) requires that proposers and recipients maintain supporting documentation, including copies of contracts, grants, or any other agreements specific to foreign appointments, employment with a foreign institution, participation in a foreign talent recruitment program and other information reported as current and pending (other) support for all senior/key personnel that must be available to NSF upon request.
For more information on 糖心传媒淐urrent and Pending (Other) Support糖心传媒� requirements,聽please review this compilation of requirements.
Biographical Sketches
Federal sponsors also currently have varying requirements regarding Biographical Sketch disclosures. Generally, individuals must disclose current positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments. This includes titled academic,professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
Though the CHIPS and Science Act of 2022 prohibits research and development awards from being made for any proposal in which a covered individual is participating in a 糖心传媒渕align foreign talent recruitment program,糖心传媒� researchers should disclose whether they are party to any type of foreign talent program in their Biographical Sketch. In addition, appointments or affiliations at foreign institutions should be disclosed in the Biographical Sketch.
Foreign Components of Research
Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports.
Under the NIH Grants Policy Statement, a Foreign Component is defined as 糖心传媒渁ny significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.糖心传媒� For example, if a researcher has a collaboration with investigators at a foreign institution that is anticipated to result in co-authorship, if the researcher uses the facilities or instrumentation of a foreign institution for grant related activities, or if the researcher receives financial support or resources from a foreign institution for grant related activities, this may require prior approval from NIH as a 糖心传媒渇oreign component糖心传媒� of the research.
NSF requires that applicants list planned 糖心传媒渋nternational activities糖心传媒� (defined as 糖心传媒渞esearch, training, and/or education carried out in cooperation with foreign counterparts either overseas or in the U.S. using virtual technologies糖心传媒�) for proposed projects. For more information, ORPA has issued guidance regarding foreign component disclosure matters.
Federal agencies differ with respect to the reporting and updating of current/pending support, biographical sketches and foreign components. It is expected that in time agencies will align to the . Information on when to report current/pending support for the University of Rochester糖心传媒檚 major sponsors (NIH and NSF) is included below. Please contact your ORPA Research Administrator for information on reporting or updating this information for other sponsors.
When to Report Current and Pending (Other) Support
- (upon request by NIH after proposal submission but prior to award);
- After Just-in-Time but prior to receipt of award (reporting required only if changes are substantive* in nature; consult ORPA if you are uncertain);
- Via Prior Approval Request for substantive* changes that occur during the award period but prior to the due date of the next Research Performance Progress Report (annual progress report);
- Research Performance Progress Report 糖心传媒� report changes only; and
- Upon request by NIH.
*While NIH does not define 糖心传媒渟ubstantive,糖心传媒� the concept is that the change is of a magnitude that NIH might prudently need to review the new arrangements to ascertain whether the existence, timing or the amount of NIH糖心传媒檚 award might need to change in light of the new information (e.g. substantive new support that alters the reporting investigators availability or where a prudent person might question whether there is scientific or financial overlap).
- At proposal submission;
- Just-In-Time (upon request by NSF after proposal submission but prior to award);
- After Just-in-Time but prior to receipt of award by accessing the proposal within Research.gov;
- Research Performance Progress Reports 糖心传媒� report changes only; and
- Upon request by NSF.
In addition, if the University discovers that a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process, ORPA must submit the information specified in the applicable general term and condition article entitled, 糖心传媒淧ost-award Disclosure of Current Support and In-kind Contribution Information糖心传媒� within 30 calendar days of the identification of the undisclosed current support or in-kind contribution through use of the Notification and Request Module in Research.gov.
Disclosures to the University
Learn about disclosures that must be made to the University of Rochester as part of research security.