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Federal Agency Disclosure Information

Disclosing “other support” in proposals for US federal sponsored research

In addition to UMD’s internal Outside Professional Activity reporting requirement, many research funding agencies also require these types of activities to be disclosed during the proposal process and, in some cases, after the project is awarded. The funding agencies use these disclosures to identify possible Conflicts of Interest, Conflicts of Commitment, and also ties with foreign entities. Disclosing accurate and complete information is required by US law. Also, when you certify your proposal in the Kuali Research system, you are certifying that you have provided all of the required information. If you have any questions, please contact your contract administrator in ORA.

The policies on exactly what needs to be disclosed and how the disclosures are made vary by funding agency. We have provided an overview of the current* policies in this document but it is important to review the requirements from the information sources to ensure you have the most-up-to-date information.

*The federal policies and requirements in this document are frequently changing. Please refer to source information to ensure you have the most current and accurate information.

Federal Systems

What to Disclose to NIH about Senior/Key Personnel on Applications and Awards - 
https://grants.nih.gov/policy/protecting-innovation.htm(link is external)

NIH - Please see these links for the most updated version of the table entitled NIH Pre-award and Post-award Disclosures Relation to the Biographical Sketch and Other Support and the most updated Frequently Asked Questions Regarding Other support and Foreign Components

As stated in NIH NOT-OD-21-073(link is external) and NOT-OD-21-110(link is external) and new mandatory format effective 1/25/22:

Other Support Format Page changed – separates funded projects from in-kind contributions. ADDED: Signature block for PD/PI or Other Senior/Key Personnel to certify the accuracy of the information submitted. Each PD/PI or senior/key personnel must electronically sign their respective Other Support form as a PDF prior to submission.

Reporting of Other Support is required for all individuals designated in an application as senior/key personnel—those devoting measurable effort to a project. FYI for Training Grants: Information on Other Support is not specifically requested for Program Directors, training faculty, and other individuals involved in the oversight of training grants since applicable information is collected in other sections of a training grant application. Other Support is not required to be submitted for individuals categorized as Other Significant Contributors(link is external).

Recipients are reminded to establish and maintain effective internal controls (e.g., policies and procedures) to ensure that individuals designated in applications as senior/key personnel fully disclose all Other Support information to their institution as soon as soon as it becomes known.

Updated Requirements for Recipients (New Mandatory Format Effective January 25, 2022) NIH requires the following:

  • Supporting documentation, which includes copies of contracts, grants, or any other agreement 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. If the contracts, grants or other agreements are not in English, recipients must provide translated copies.
  • Immediate notification of undisclosed Other Support. When a recipient organization discovers that a PI or other Senior/Key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the recipient must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.

For more information, see FAQs: Biosketch format pages, instructions, and samples(link is external); Biosketch FAQ(link is external); Other Support information; Other Support and Foreign Components FAQ(link is external)

NOT-OD-21-110(link is external): NIH expects applicants and recipients to use the updated biosketch and other support format for applications, Just-in-Time (JIT) Reports, and Research Performance Progress Reports (RPPRs) as of May 25, 2021. NIH will require the use of the updated format pages for the previously mentioned submissions for anything on and after January 25, 2022. Failure to follow the appropriate formats on or after January 25, 2022 may cause NIH to withdraw applications from or delay consideration of funding.

Send your inquiries to our new central email inbox nihosbiosketch@nih.gov(link sends e-mail).

NIH FAQs - full list can be found here(link is external). Highlighted updates below; italics means copied directly from NIH FAQ.

GENERAL

  • Do the 2021 changes to the Other Support Format page affect the instructions for Other Support in the Research Performance Progress Report (RPPR)? In NOT-OD-21-073 there is one format page, and a single set of instructions. Should recipients use the same format and instructions for all Other Support submissions? While the format has changed, NIH will still require recipients to report significant changes in Other Support for all existing senior/key personnel, and Other Support information for any new senior/key personnel being requested in the RPPR. The updated format page and instructions must be used for all Other Support submissions, including both competing applications and the RPPR. There are no longer separate instructions for competing applications and the RPPR.

SIGNATURES

  • Is the researcher’s signature now required on Other Support submissions? NIH requires an electronic signature on all Other Support submissions as of January 25, 2022. All principal investigators and other senior/key personnel must electronically sign the Other Support form, prior to its submission to NIH, certifying that the information is accurate and complete.
  • Will electronic signatures be accepted on Other Support submissions? Other Support submissions must be submitted as a flattened PDF, after all signatures are obtained. Recipients and applicants may use the electronic signature software of their choice, and in alignment with their institutional practices. A typed name is not an electronic signature and is not acceptable. Applicants and recipients must maintain supporting documentation to reasonably authenticate that the appropriate individual signed the form. Recipients must and make the documentation available upon request in accordance with 45 CFR Part 75.364. UMD strongly recommends our researchers use Adobe Sign(link is external)).

CORE FACILITIES

  • NOT-OD-21-073 states that institutional resources, such as core facilities or shared equipment that are made broadly available, should not be included in Other Support, but rather listed under Facilities and Other Resources. How does NIH define broadly available? Core facilities, shared equipment, and other shared services are considered broadly available; recipients do not need to disclose in Other Support. For other resources, recipients must use professional judgement to determine whether a resource is made broadly available and apply these principles consistently across the institution.

FOREIGN CONTRACTS

  • Contracts, grants or other agreements submitted as supporting documentation may contain confidential and/or sensitive information. Can recipients redact confidential/sensitive information prior to submitting? NIH needs access to all information necessary to make an informed judgement about possible scientific, budgetary, or commitment overlap and to make an informed judgment about management of possible significant financial conflicts of interest. NIH handles confidential and sensitive information in accordance with our cybersecurity requirements and requires submission of complete documentation.
  • Is supporting documentation (e.g. contracts, grants or other agreements) required for completed support? Supporting documentation is required for active and pending support specific to senior/key-personnel foreign appointments, affiliations, and/or employment with a foreign institution.
  • If a researcher indicates that they do not have a “formal” agreement in place, is supporting documentation still required for that foreign appointment, affiliation, and/or employment with a foreign institution? Yes. If the individual is performing activities under any active contract, grant or other agreement, it must be provided as supporting documentation.

Disclosure requirements vary by agency. Review the BAA or Funding announcement carefully.

DARPA has published "Senior/Key Personnel Foreign Influence Risk Rubric"(link is external) and "Countering Foreign Influence Program (CFIP) FAQs"(link is external)

Example from DARPA BAA and additional information can be found here(link is external).

 

Type of Activity Report in current/ pending support
A list of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of the source ✔
Title and objectives of the other research projects ✔
The percentage per year to be devoted 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 ✔

 

Example from ARL BAA

 

Type of Activity Report in current/ pending support
All project support from whatever source must be listed. ✔
The list must include all projects requiring a portion of the PI's and other key personnel's time, even if they receive no salary support from the project(s). ✔
The information should include, as a minimum: the project/proposal title and brief description, the name and location of the organization or agency presently funding the work or requested to fund such work, the award amount or annual dollar volume of the effort, the period of performance, and a breakdown of the time required of the PI and/or other key personnel. ✔

 

Example from DARPA contracts:

FUNDAMENTAL RESEARCH CONSIDERATIONS 
Subcontractor University performance under this contract will include effort categorized as fundamental research. In addition to DARPA support for free scientific exchanges and dissemination of research results in a broad and unrestricted manner, the university participant acknowledges that such research may have implications that are important to U.S. National Interests. As such, the university participant hereby agrees to comply with the following: 
(a) The University participant shall have in place a mechanism to identify foreign participant involvement or foreign entity interest in the research in question, and agrees to share such information with DARPA as the funding sponsor. Foreign participant involvement may be restricted or prohibited as agreed to between the parties. The University participant may have in place special procedures including, but not necessarily limited to, Talent Management Plans, Security Plans, Procedures to identify and mitigate personal and/or organizational conflicts of interest, and/or Training Programs, to ensure that University, Government Funding Sponsor, and U.S. National Interests are sufficiently protected. The University participant agrees to share such information with DARPA as the funding sponsor. Foreign participant involvement may be restricted or prohibited as agreed to between the parties.

Requirements may vary between National Labs.

Examples from EERE T 540.133 02: Pre- Award Information Sheet(link is external)

 

Type of Activity Potential Conflicts of Interest within Project Team Report in current/ pending / past support

The Recipient is required to disclose potential conflicts of interest within the Project Team. **

 ✔
Explain the conflict and the parties involved in a separate attachment.

If no conflicts of interest exist, check the box marked “None” below.

Does the PI, Co-PI(s) or any other the Recipient’s or Subrecipient’s principals, have any applications or funding requests for this project or related work (i.e., work that relates directly or indirectly to the project to be funded under the award number listed above) pending with or approved by any Federal or non-Federal entity (including but not limited to industry, private investors, and foreign, state or local governments)?

 ✔
If yes, attach an explanation for each submission including the source of funding/name of the Federal or non-Federal entity, date of submission, title of submission, application status and project abstract.

The Recipient must disclose all funding from any Federal or non-Federal entity that the Recipient or any other Recipient’s or Subrecipient’s principals (including, but not limited to, the PI or any Co-PI(s)), is currently receiving or have received within the last 5 years using the same or similar technology proposed for the project to be funded under the award number listed above.

 ✔
The following table may be used to provide the information(link is external) (page 4). Complete a separate table for each source of funding.
Attach a separate explanation for each source of funding that includes name of the Federal or non-Federal entity providing the funding; title of the project; funding amount; non-federal share, if applicable; start and end dates; and project abstract. ✔
The following table may be used to provide the information(link is external) (page 4). Complete a separate table for each source of funding.

 

** POTENTIAL CONFLICTS OF INTEREST WITHIN PROJECT TEAM:

  • An apparent or actual conflict of interest may exist where an individual or entity has different, and potentially conflicting, duties or relationships with respect to other individuals or entities within the Project Team.
  • Examples of potential conflicts of interest include but are not limited to: the PI for the Recipient has an equity stake in a Subrecipient; the PI for the Subrecipient has a consulting arrangement with the Recipient; or a Subrecipient is a subsidiary of or otherwise affiliated with the Recipient, etc.

 

NASA requirements may vary by NASA site. Review the proposal guide carefully!

The most recent Guidebook for Proposers can be found here: Guidebook for Proposers(link is external). The current and pending support information is in Section 2.16 Current and Pending Support.

Other resources

Council on Governmental Relations: Chart Comparing Disclosure and Other Requirements/Recommendations Among JCORE, NSPM-33, NDAA 2021, NSF & NIH (including NIH NOT-OD-21-073)(link is external) last updated 9/2/2021

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