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.