Approvals and Disclosures to Federal Agencies

Federal Sponsor Disclosure and Prior Approval Requirements Relevant to International Collaboration

Given governmental concerns regarding undue foreign influence on federally-funded researchers, federal agencies are revising and clarifying their disclosure requirements to ensure federally-funded researchers disclose their relationships and activities with non-US institutions, organizations and funding agencies. Failure to properly and timely disclose foreign relationships and activities may jeopardize current funding and PI-eligibility for future fundingWe therefore strongly encourage all faculty members to review their University and federal sponsor disclosure obligations in the context of their international collaborations and affiliations with foreign institutions.

NIH-Specific Guidance

In addition to the specific guidance below, you can also consult this chart developed by NIH, which provides examples of what to disclose to NIH about Senior/Key Personnel on Applications and Awards.

NSF-Specific Guidance

NSF’s 2020 Proposal and Award Policies and Procedures Guide (PAPPG), reflects several significant changes regarding Current and Pending Support as well as Biographical Sketches, as detailed below. 

DOD-Specific Guidance

On March 20, 2019, the Undersecretary of Defense announced new requirements for all new DOD Notices of Funding Opportunities (NFOs) pertaining to new research and research-related educational activities after April 19, 2019. Proposers must submit the following information for all key personnel whether or not the individuals' efforts under the project are to be funded by the DOD:

  • A list of all current projects the individual is working on.
  • Any future (pending) support the individual has applied to receive, regardless of the source.
  • Title and objectives of each of these research projects.
  • The percentage per year each of the key personnel will devote to the other projects.
  • The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
  • Name and address of the agencies and/or other parties supporting the other research projects.
  • Period of performance for the other research projects.

The above information is to be included in a Senior Key Person Profile form included in all Notices of Funding Opportunities (NFOs), using OMB Form 4040-0001 Research and Related Senior/Key Person Profile (Expanded).

Please see the full March 20, 2019 memo attached for additional details.

Department of Energy (DOE)-Specific Guidance

Department of Energy Directive 486.1A prohibits DOE employees and DOE contractor personnel (which is defined to include joint appointees, subcontractors and individuals performing R&D work within the scope of a prime DOE contract at a DOE site or facility) participation in foreign government talent recruitment programs of countries designated by DOE as a foreign country of risk.