Please note that the below information relating to disclosure requirements is sponsor specific. Per ASU, state and federal policies, disclosure to ASU may be required for activities that are not required to be reported to a sponsor. Please refer to the below links for information regarding ASU’s disclosure requirements.
Financial conflicts of interest
International research and global collaborations
Department of Defense
What to disclose
Domestic and foreign engagements and support, regardless if funded or unfunded (for all key personnel, in addition to PI or Co-PI, even if efforts are or are not to be funded by DOD).
Where to disclose
Current and pending support.
When to disclose
Proposal
Should you have any questions regarding the above, please contact your Research Administrator and Sponsored Officer.
Resources
March 20, 2019 memo: This memo applies to new research activities after April 19, 2019 and applies to grants, cooperative agreements, etc. If you have a DOD contract, please review terms and conditions as it may have additional requirements.
Department of Energy/National Nuclear Security Administration
What to disclose
Domestic and foreign engagements and support, regardless if funded or unfunded.
Where to disclose
Current and Pending Support. Include as an appendix to your project narrative. Do not attach a separate file. (DOE Grants Officers may determine where in the application current and pending support disclosures should be included.)
When to disclose
Proposal
Note: Per a Financial Assistance Letter released June 1, 2022, “FOA applicants must include current and pending support disclosures for all PIs and other senior/key personnel named in the application. After selection and during the life of the award, if there are changes to or additions of PIs or other senior/key personnel, such person(s) must also submit current and pending support disclosures within 30 days of joining the project team, or on a timeline consistent with the program office instructions. Also, for all PIs and other senior/key personnel, if there are changes to the previously submitted current and pending support disclosures, the individuals must update their disclosures within 30 days of the change, or on a timeline consistent with the program office instructions.” Each current and pending support disclosure must be signed, dated, and include the certification statement found in the FAL at the link below.
Should you have any questions regarding the above, please contact your Research Administrator and Sponsored Officer.
Resources
- DOE FY 2020 Continuation of Solicitation for the Office of Science Financial Assistance Program
- FAL Department of Energy Current and Pending Support Disclosure Requirements for Financial Assistance
National Aeronautics and Space Administration
What to disclose
Domestic and foreign engagements, regardless if funded or unfunded (e.g. If you are a co-I and spending more than 10% of your time on an active award or pending proposal).
Where to disclose
Current and pending support
When to disclose
Proposal
Note: NASA is currently updating its COI and Current and Pending disclosure policies. The resulting COI and C and P Support Disclosure Policy will require award recipients to disclose financial COI and non-financial Conflicts of Commitments (e.g. participating in a foreign talent recruitment program). Award recipients will also need to disclose all resources are support an individual’s research, regardless if foreign or domestic, made directly to the individual or through the recipient entity, or if the resource has monetary value.
As a reminder, the proposal you will be submitting does not need to be included on your Current and Pending Support, unless you have submitted the same proposal to another agency.
If you have a NASA contract, please review terms and conditions as it may have additional requirements.
Should you have any questions regarding the above, please contact your Research Administrator and Sponsored Officer.
Resources
- NASA Contract Restrictions
- NASA Grant Restrictions
- NASA Guidebook for Proposers Responding to a NASA Funding Announcement
National Institutes of Health
What to disclose
Foreign engagement and other support.
Where to disclose
Specific disclosure of “Foreign Components” is to be disclosed on its Research and Related Other Project Information Form submitted with proposals. This disclosure is in Item 6 of the Research and Related Other Project Information Form. Disclosures should also be included in the Other Support form, which may be requested as part of a Just-in-Time request at the pre-award post-submission stage.
When to disclose
Proposal, JIT, Interim and Final Research Performance Progress Reports.
What to disclose
A foreign component update (throughout a project, if the need arises to include a foreign component).
Where to disclose
Should always be included in the foreign components section of the RPPR Report, Section G.9; requires NIH prior approval.
When to disclose
Research Performance Progress Reports.
What to disclose
Changes in other support.
Where to disclose
Changes in Other Support for existing senior/key personnel, or Other Support for new senior/key personnel, should be requested in the RPPR.
When to disclose
Research Performance Progress Reports.
What to disclose
Undisclosed other support.
Where to disclose
If it is discovered that Other Support information was not disclosed on an active grant outside of JIT or the RPPR, the recipient must submit that updated Other Support information to the Grants Management Specialist named in the Notice of Award no later than 30 days after it becomes known.
When to disclose
No later than 30 days after it becomes known.
What to disclose
Foreign grants, contracts and other agreements.
What to disclose
For active NIH grants, foreign contracts, grants, and other agreements specific to senior/key personnel foreign appointments and/or employment with a foreign institution must be submitted as supporting documentation for Other Support information.
When to disclose
JIT and RPPR
Note: On and after January 25, 2022, NIH will require applicants and recipients to use the updated Biosketch and Other Support format for applications, Just-In-Time Reports, and Research Performance Progress Reports.
Please read the New NIH Other Support Requirements Research Operations News post for important information regarding new Other Support requirements.
Resources
- Biosketch Format Pages, Instructions and Samples
- Letter from NIH Director Francis Collins
- Research and Related Other Project Information Form
- Statement on Protecting the Integrity of U.S. Biomedical Research
- NIH FAQs on Other Support and Foreign Components
- NIH Grants Policy Statement, Section 1.2, definition of “other support”
- NOT-OD-18-160 Financial Conflict of Interest Disclosures of Foreign Financial Interests
- NOT-OD-19-114 Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components
- NOT-OD-21-073 Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021
- NOT-OD-21-110 Implementation of changes to the biographical sketch and other support format
- NOT-OD-21-122 Announcing New Inbox for Inquiries Related to Changes to Biographical Sketch and Other Support Format Page
- NOT-OD-22-210 Financial Conflict of Interest (FCOI) and Other Support: Reminders
- Other Support
NIH policy requires all individuals included in an application as senior/key personnel – including the program director/principal investigator and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way to disclose “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant,” and for determination to be made if the project activities include a foreign component, “significant scientific element or segment of a project to be performed outside the United States.”
Should you have any questions regarding the above, please contact your Research Administrator and Sponsored Officer.
National Science Foundation
What to disclose
Domestic and foreign engagements, regardless if funded or unfunded (e.g. ,scientific advisor, consultant, etc.).
Where to disclose
Current and pending support, annual reports, final reports, and biosketches (“Appointment Section”).
When to disclose
Proposal, reports.
What to disclose
A disclosure update.
Where to disclose
Through the “Other request” category in the Notification and Request Module in Research.gov; can occur by your SRO.
When to disclose
Post-proposal submission.
What to disclose
Undergraduate, graduate and postdoctoral training, including location, major/area and degree and year.
Where to disclose
Biosketch.
When to disclose
Proposal.
What to disclose
Academic, professional or institutional appointments, whether or not remuneration is received, and, whether full-time, part-time or voluntary.
Where to disclose
Biosketch.
When to disclose
Proposal.
What to disclose
All projects (including this project) currently under consideration from whatever source, and all ongoing projects, irrespective of whether support is provided through the proposing organization, another organization or directly to the individual.
Where to disclose
Current and pending support, project reports (for new support only), post-award information term and condition (if undisclosed at proposal time).
When to disclose
Proposal, reports.
What to disclose
Postdoctoral scholars, students or visiting scholars who are supported by an external entity, whose research activities are not intended for use on the project/proposal being proposed to NSF, and have an associated time commitment.
Where to disclose
Current and pending support, project reports (for new support only), post-award Information term and condition (if undisclosed at proposal time).
When to disclose
Proposal, reports.
What to disclose
Postdoctoral scholars, students or visiting scholars who are supported by an external entity, and whose research activities are intended for use on the project/proposal being proposed to NSF.
Where to disclose
Facilities, equipment and other resources.
When to disclose
Proposal.
What to disclose
Consulting that falls outside of an individual’s appointment.
Where to disclose
Current and pending support, project reports (for new support only), post-award information term and condition (if undisclosed at proposal time).
When to disclose
Proposal, reports.
What to disclose
Travel supported/paid by an external entity to perform research activities with an associated time commitment.
Where to disclose
Current and pending support, project reports (for new support only), post-award information term and condition (if undisclosed at proposal time).
When to disclose
Proposal, reports.
What to disclose
Startup company based on non-organization-licensed IP.
Where to disclose
Current and pending support, project reports (for new support only), post-award information term and condition (if undisclosed at proposal time).
When to disclose
Proposals, reports.
What to disclose
Startup packages from other than the proposing organization.
Where to disclose
Current and pending support, project reports (for new support only), post-award information term and condition (if undisclosed at proposal time).
When to disclose
Proposals, reports.
Activities that are NOT required to be disclosed to NSF:
- Consulting that is permitted by an individual’s appointment and consistent with the proposing organization’s “Outside Activities” policies and procedures.
- Travel supported/paid by an external entity to attend a conference or workshop.
- Honoraria.
- Teaching commitments.
- Startup company based on organization-licensed Intellectual Property.
- Organizational startup packages provided to the individual from the proposing organization.
- Unrestricted gifts.
- Mentoring as part of appointment.
- Academic year salary.
Note: Starting prior to October 5, 2020, if/when ASU 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, the PI or co-PI must work with the AOR on submission of the information outlined in the article within 30 calendar days of the identification of the undisclosed current support or in-kind contribution.
Resource: October 5, 2020 Significant Change
Should you have any questions regarding the above, please contact your Research Administrator and Sponsored Officer.
Resources:
- NSF Biographical Sketch.
- NSF Collaborations and Other Affiliations Information.
- NSF Current and Pending Support.
- NSF Current and Pending FAQs.
- NSF director’s letter on research protection.
- NSF FAQs Regarding Current and Pending Support PAPPG (NSF 22-1) (April 20, 2022).
- NSF Fillable PDF FAQs.
- NSF PAPPG 2022.
- NSF Pre-Award and Post-Award Disclosures Relating to the Biographical Sketch and Current and Pending Support (April 20, 2022).
- NSF Training Webinar.
- October 5, 2020 Significant Change.
Additional federal funding agencies information
- JCORE Report: “Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise” .
- John S. McCain National Defense Authorization Act for Fiscal Year 2019.
- National Security Presidential Memorandum (NSPM) – 33 on United States Government-Supported Research and Development National Security Policy (January 14, 2021).
- Public Health Service (PHS): Promoting Objectivity in Research.
- PHS: Financial Conflict of Interest (FCOI), Title 42 CFR 50, Subpart F.
- Summary of NSTC Guidance for Implementing National Security Presidential Memorandum 33 Disclosure Requirements (January 11, 2022).
- Summary of NSTC Guidance for Implementing National Security Presidential Memorandum 33: Provisions Regarding DPIs, Consequences, Information Sharing and Research Security Programs (January 10, 2022).