Disclosing Other Support
Introduction
As part of the U.S. Government's efforts to protect U.S. intellectual property and the integrity of federally funded research endeavors, major federal sponsors have issued clarification and new guidance regarding requirements for disclosing other support.
欧美口爆视频 Boulder is committed to international engagement, collaboration, and compliance with all U.S. regulations governing international research collaborations. Disclosing and vetting other support through the proper channels protects everyone鈥檚 interests and the 欧美口爆视频 research enterprise. Failure to disclose other support and outside activities can result in termination of funding, ineligibility for future funding, and threaten overall funding for the University.
The following provides guidance to researchers on best practices and requirements for disclosing other support and outside activities at the proposal stage. Additional information about Federal sponsor guidance on External Activity Disclosures can be found here.
欧美口爆视频 Boulder Researcher Responsibilities
- Maintain and update a record of all current and pending support. Use of the听 is used and required by many federal agencies.
- Be familiar with sponsor requirements for disclosing current and pending support (guidance for major federal sponsors provided below).
- Annually disclose and update as needed all outside professional activities and financial relationships through the 欧美口爆视频听Disclosure of External Professional Activities (DEPA)听蹿辞谤尘.
- Provide accurate information and certification on an听OCG Proposal Submission Request (PSR)听form for each proposal.
- Follow federal and 欧美口爆视频 Boulder听disclosure and reporting requirements听related to foreign support of research.
- Err on the side of transparency when disclosing other support and outside activities to 欧美口爆视频 Boulder and federal agencies.
- If you are involved in a foreign talent recruitment program, disclose this involvement in your DEPA and in your proposal current and pending document. Note that the U.S. Department of Energy (DOE)听听from participating in foreign talent recruitment programs.
- Review Federal Sponsor Disclosure Requirements below to determine the level of detail that is required for each disclosure and requirements for disclosure certification.
- In submitting proposals, PIs certify that all information is complete and accurate to the best of their knowledge.听Exclusion of information in any documents may be considered by the university and the funder as providing fraudulent information.
Federal Sponsor Disclosure Requirements
William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021
, Sec. 223. Disclosure of funding sources in applications for Federal research and development awards.
As required by Public Law 116-283, Sec. 223, the University of 欧美口爆视频 Boulder, in applying for a Federal research or development award, must make each covered individual employed by 欧美口爆视频 Boulder aware of the following:
Disclosure Requirement:听
Each federal research agency shall require, as part of any application for a research and development award from such agency that each covered individual listed on the application:
- disclose the amount, type, and source of all current and pending research support received by, or expected to be received by, the individual as of the time of the disclosure;
- certify that the disclosure is current, accurate, and complete; and
- agree to update such disclosure at the request of the agency prior to the award of support and at any subsequent time the agency determines appropriate during the term of the award;
National Science Foundation (NSF)
All PIs, Co-PIs and non-Co-PI senior personnel from 欧美口爆视频 Boulder and subrecipient or collaborative institutions must provide a听Current and Pending Support document, that:
- 贵辞濒濒辞飞蝉听听for content and format. Effective January 30, 2023, Biographical Sketch and Current and Pending disclosures should be prepared using and include disclosure certifications.
- Includes all current and pending support for ongoing projects and proposals from all sources, foreign and domestic
- Include support from federal, state, local, foreign, public or private foundations, industrial or other commercial organizations, or internal funds allocated toward specific projects
- All projects or activities that require a time commitment听from the individual must be included, even if there is no salary support from the project
- Certify that, at the time of submission, they are not participating in any malign foreign talent recruitment program.
All PIs, Co-PIs and non-Co-PI senior personnel from 欧美口爆视频 and subaward or collaborative institutions must also provide a Biographical Sketch, disclosing all appointments. More information on these requirements can be found at听.
References:
- 听posted July 11, 2019.
National Institutes of Health (NIH)
All PIs, Co-PIs and senior/key personnel from 欧美口爆视频 Boulder and subrecipient institutions must provide an听Other Support听document, typically at the 鈥淛ust in Time鈥 phase before an award is made and in progress reports (RPPRs) if there are changes in support or addition of key personnel. Other Support must:
- 贵辞濒濒辞飞听听for content and format. Effective January 25, 2022, Current and Pending disclosures should be prepared on a NIH approved template that includes disclosure certification.听
- NIH will move to the Common Form for Current and Pending (Other) Support prepared using for application due dates and other submissions on or after May 25, 2025.
- Be provided for anyone contributing to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation (all Senior/Key Personnel. Not required for Other Significant Contributors).
- 滨苍肠濒耻诲别听all financial resources, whether Federal, non-Federal, commercial or institutional, available in direct support of an individual's research endeavors. Include gifts in direct support of an individual鈥檚 research endeavors as well as financial support for laboratory personnel.
- 滨苍肠濒耻诲别听all non-financial resources听(i.e. lab space, high value materials, animals, equipment, supplies, support for employees or 听students contributing to the research) uniquely available (i.e., not a shared resource or facility broadly available) in direct support of an individual's research endeavors.
- Non-financial resources intended for use on the proposed project can be reported in Facilities and Other Resources or the Other Support document.
- If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates.
- If there is no associated effort level, zero effort can be listed but an estimated dollar value must be listed;听effort and dollar value cannot both be zero.
- An item or service given with the expectation of an associated time commitment is not a gift and is an in-kind contribution and must be reported as Other Support.
- Non-financial resources intended for use on the proposed project can be reported in Facilities and Other Resources or the Other Support document.
- Include all positions and appointments,听domestic and foreign, with or without remuneration full-time, part-time, or voluntary within the Biosketch. This includes Consulting agreements (that are not a part of one鈥檚 欧美口爆视频 appointment), where the person will be conducting research as part of the consulting activities.
- For foreign appointments, provide听Supporting Documentation; copies of contracts specific to the individual鈥檚 foreign appointments and/or foreign employment and/or all foreign activities and resources that are reported in Other Support. If not in English, translated copies must be included.
- Not听include gifts and 欧美口爆视频 startup packages,听unless in direct support听of an individual鈥檚 research endeavors, nor training awards, prizes or gifts.
- Not听include either the application under consideration nor the current NIH award for this project.
Also to be noted:
- 鈥淔inancial resources鈥 is interpreted broadly and includes any project an individual is听committing measurable effort听to and听research efforts听under an appointment or affiliation with a foreign institution or entity where support is non-monetary.
- Include in-kind support and selection to foreign talents or similar-type program.
- Gifts and 欧美口爆视频 start up packages do not need to be reported. However, if a gift received from an outside entity is in direct support of an individual鈥檚 research endeavors, the recommendation is to report it.
- 础濒濒听current听scientific positions, appointments and honors should also be disclosed in the听听诲辞肠耻尘别苍迟.
- NIH will move to the Common Form for Biosketches prepared using听 for application due dates and other submissions on or after May 25, 2025.
- Institutional resources (ex: broadly available core facilities/shared equipment) should be listed under Facilities and Other Resources within the proposal application. When in doubt, disclose.
NIH has specific requirements for听foreign components听related to disclosure. NIH defines foreign component as 鈥減erformance of any 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.鈥 Note that a visiting fellow working on an NIH funded project may be considered a foreign component and should be discussed with the NIH Grants Management Officer (see听).
Disclosure of a foreign component must be made in the NIH application:
- On the R&R Other Project Information Form
- In a 鈥淔oreign Justification鈥 attachment
- In cases where foreign support is provided (ex: foreign fellow working on NIH project, etc., disclose this support on the Other Support document as an In-Kind Contribution.
- Supporting Documentation (i.e. copies of contracts) should be provided for all foreign activities and support.
厂别别听听released July 10, 2019 and听听补苍诲听.
National Aeronautics and Space Administration (NASA)
NASA has released the October 2024 version of the Grant and Cooperative Agreement Manual (GCAM), replacing the Proposer鈥檚 Guide.
Starting October 1, 2024, new requirements for Current and Pending Support, will apply to federal assistance awards. A template for the new Current and Pending Support format is available听.
Current and pending support must be provided in NASA proposals as follows:
- For all PIs and Co-PIs
- For all Co-Is proposing to spend 10% or more of their time on the proposed project
- PIs and Co-PIs must disclose all ongoing pending projects and proposals, regardless of salary
- Co-Is must disclose ongoing and pending projects that require a significant share (more than 10%) of their time
- 贵辞濒濒辞飞听
- For NASA ROSES submissions, proposers should refer to the new GCAM, even if earlier ROSES program elements still cite the retired Proposer鈥檚 Guide.
NASA is restricted from using funds to enter into or under any grant or cooperative agreement of any kind 鈥渢o participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement.鈥 For all NASA proposals:
- 欧美口爆视频 PIs must provide an Assurance of Compliance to the China funding restriction via the PSR form
- Subrecipients must provide an Assurance of Compliance to the China funding restriction by completing the Subrecipient China Assurance Form听
Department of Defense (DOD)
As of April 20, 2019, DoD notice of funding opportunities (NFO) for research and research-related educational activities will include a requirement for current and pending support documentation from听all key personnel听at the proposal stage.
The Current and Pending Support document must include:
- A list of current projects the individual is working on, as well as any future support applied for, regardless of source. This includes听all听projects funded or pending funding decision from any source: all domestic and international sources, funds internal and external to 欧美口爆视频, and funds paid directly to the individual
- Titles and objectives of the other research projects
- Percentage per year devoted to the other projects
- Total amount of support the individual is receiving or will receive
- Name and address of agencies and/or other parties supporting other research projects
- Period of performance for the other research projects
For reference, see the U.S. Department of Defense (DoD)听听issued on March 20, 2019. OCG recommends use of for creation of the Current and Pending Support document since it meets these requirements and is used by multiple federal agencies.
Department of Energy (DOE)
DOE does not provide agency guidance on current and pending documents. Refer to specific DOE funding opportunity announcements for details.
On July 7, 2019, DOE issued a听听regarding foreign government talent programs. Per this directive:
- DOE does not allow participation in foreign talent programs by its employees or contractor personnel.
- A 欧美口爆视频 researcher who is contracted to work in a DOE national lab and who is part of a foreign talent program must remove his/her association with the talent program before receiving funding.
- Foreign government talent recruitment programs are defined as, 鈥渁ny foreign-state-sponsored attempt to acquire U.S. scientific-funded research or technology through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States.鈥
Resources
If you have any questions regarding sponsor requirements for disclosure at the proposal stage, contact your Proposal Analyst. If you have questions regarding disclosure or updates to disclosures once an award has been made, contact your Grant or Contract Officer. All OCG staff contacts can be found in the听OCG Directory.