Disclosure

Other Support Disclosure

Many federal funding agencies, including common funders for UCCS like NIH and NSF, have issued disclosure and training requirements. These include the disclosure of support (both financial and non-financial) from foreign entities and institutions. This page is intended to provide guidance in navigating these disclosure requirements. 

If you have additional or specific questions, please contact your program officer or dedicated sponsor contract.

File Your Annual COI Disclosure

From the Provost

Provost Memo Disclosure and Reporting

News

New Annual Malign Foreign Talent Recruitment Program Certification for PIs/Co-PIs

- June 3, 2025

Starting on June 7, 2025, in accordance with the NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter II.D.1.e(ii), all PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov that they are not party to a MFTRP. Individuals who are currently a party to a MFTRP are not eligible to serve as senior/key personnel on an NSF proposal or on any NSF award made on or after May 20, 2024. NSF is providing notification of this new requirement to impacted PIs and co-PIs.

What you need to know about completing the required MFTRP certification in Research.gov:

  • There is no organizational certification requirement, the certification requirement is for PIs and co-PIs.
  • Impacted PIs and co-PIs will be prompted to complete the MFTRP certification after signing into Research.gov using the Sign In link at the top of www.Research.gov.
  • PIs and co-PIs with more than one active award made on or after May 20, 2024, are only required to certify once, annually.
  • Once completed, PIs and co-PIs can view their MFTRP certification response under the Academic/Professional Information section of their profile.
  • NSF is working to expand the MFTRP annual certification requirement for all senior/key personnel roles at a future date. Additionally, NSF is working to provide organizations with access to the annual certifications.
  • Please see PAPPG Chapter II.D.1.d(ix) for information about Authorized Organizational Representative (AOR) responsibilities regarding senior/key personnel MFTRP certifications.
  • Frequently Asked Questions and MFTRP contract examples will be available on the MFTRP section of the Office of the Chief of Research Security Strategy and Policy website shortly.

If you have any questions about this requirement, please contact researchsecurity@nsf.gov for additional guidance. System-related questions should be directed to the NSF IT Service Desk at 1-800-381-1532 (7:00 AM - 9:00 PM ET; Monday - Friday except federal holidays) or to the Research.gov team rgov@nsf.gov.

Researchers Failed to Disclose Foreign Support, DOJ Alleges

-July 17, 2024

"Three researchers from the University of Maryland at College Park who received federal funding failed to disclose that their projects were also getting support from foreign companies, in violation of the False Claims Act, the U.S. Department of Justice alleged in the news release Tuesday."

Cleveland Clinic to Pay Over $7 Million to Settle Allegations of Undisclosed Foreign Sources of Funding on NIH Grant Applications and Reports

 -May 17, 2024

"The Cleveland Clinic Foundation (CCF) has agreed to pay $7,600,000 to resolve allegations that it violated the False Claims Act (FCA) by submitting to the National Institutes of Health (NIH) federal grant applications and progress reports in which CCF failed to disclose that a key employee involved in administering the grants had pending and/or active financial research support from other sources."

Stanford University Agrees to Pay $1.9 Million to Resolve Allegations That it Failed to Disclose Foreign Research Support in Federal Grant Proposals

-October 2, 2023

"Stanford University, located in Palo Alto, California, has agreed to pay $1.9 million to resolve allegations that it violated the False Claims Act by submitting proposals for federal research grants that failed to disclose current and pending support that 12 Stanford faculty members were receiving from foreign sources."

What Investigators Need to Know

Collaboration, whether with domestic or international partners, has always been and remains an important component of scientific advancement and innovation. However, in recent years, the U.S. government has expressed concern that foreign entities, governments, and/or individuals are having inappropriate and undue influence on U.S. government-funded researchers and institutions. It has, particularly, voiced concerns about the non-reciprocal exchange of ideas and perceived efforts of some foreign governments to exploit the U.S. research environment "to circumvent the costs and risks of conducting research."

Federal agencies have been establishing and updating instructions regarding "Other/Current and Pending Support." They may request similar information, but at this time, the process is not uniform. Additionally, some of the instruction and guidance provided may be ambiguous. Ensure you contact the sponsor or program officer if you need clarification or have questions. The resources on this page provide some guidance for some agencies.

Regardless of the sponsor, information provided in Other/Current and Pending Support documents must be current, accurate, and complete. It is recommend to err on the side of disclosure. If in doubt, disclose.

Failure to comply with disclosure requirements could result in a number of negative consequences for both the researcher and their home institution, including, but not limited to, termination of grants or awards, ineligibility for participation in U.S. government activities, and suspension of eligibility to receive federal funding.

What Investigators Need to Do

There are many things you can do to help ensure you are compliant with disclosure requirements. You should:

  • Complete or update your UCCS Annual Conflict of Interest.
  • Carefully read any disclosure requirements for grant and funding notices. Some of these policies are developing and changing, so it's important to make sure your knowledge is up-to-date. Some sponsors (such as NSF) may require you to certify that are you are not party to certain activities.
  • Keep your NIH or NSF Biosketch updated. Update regularly, like you would a CV. Use current sponsor guidelines.
  • Stay aware of Export Control policies and procedures. Export control isn't just about physical materials, but also the exchange of certain kinds of information. Ensure your team is familiar with Export Control policies, too.
  • If your project has an Export Controlled component, reach out to the UCCS Export Control Officer as soon as possible.
  • Know the federal regulations for working with collaborators and sponsors from outside of the United States.
  • Complete any required training.
  • Ensure that you update any changes in support when completing progress or final reports.
  • Report informal collaborations (where no written agreement or exchange of funds exist) as well as formal ones while disclosing. It is recommend to err on the side of disclosure. If in doubt, disclose.
UCCS Annual COI Disclosure

NSF Specific Disclosure Requirements

NOTE:For proposals submitted or due on or after January 30, 2023, PIs and senior personnel must certify that the information in their NSF Current and Pending Support and Biological Sketch documents are accurate, current and complete, in compliance with Certification Requirement for Senior Personnel Specified in the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 [Section 223(a)(1)]. The certification will be included in both SciENcv and the NSF fillable format.

Starting October 23, 2023, SciENcv is required for preparation of Current and Pending Support. 

NSF has outlined their disclosure requirements for proposals in the Proposal & Award Policies & Procedures Guide (PAPPG). If you are seeking NSF funding, you should familiarize yourself with these policies and procedures. It is critical that researchers are transparent and thorough with their disclosures. Failure to properly disclose could result in non-acceptance of your proposal, loss of privilege to work under an NSF award, or suspension/termination of an NSF award, among other penalties.

The NSF has also issued a helpful disclosure table (scroll down to Current disclosure requirements), which details the types of activities that should be reported and where such activities should be reported in the proposal.

Finally, in the PAPPG 24-1, NSF has issued a policy prohibiting senior personnel from participating in Malign Foreign Talent Recruitment Programs. For awards made on or after May 20, 2024, PIs and co-PIs will need to certify annually in Research.gov that they are not party to an MFTRP.

Questions about NSF?

  • Contact the DIAS/Policy Office regarding proposal and award procedural questions, including disclosure, at policy@nsf.gov
  • For award specific questions, contact the cognizant Grants and Agreements Officer in the Division of Grants and Agreements or Division of Acquisition and Cooperative Support
  • PAPPG FAQ
  • NSF Disclosure Requirements and Standardization (Updated 11/1/2023)

NIH Other Support Disclosure Requirements

The National Institutes of Health (NIH) requires full transparency regarding all resources that support a researcher’s research endeavors. This includes Other Support disclosures for all Senior/Key Personnel on NIH-funded applications and awards. Accurate and timely disclosure is essential to maintain compliance and protect the integrity of federally funded research.

What is "Other Support"?

As detailed in NOT-OD-21-073, applicants should 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 or are based at the institution the researcher identifies for the current grant. All senior/key personnel are required to disclose. Required disclosure includes (but is not limited to):

  • Resources and/or financial support from all foreign and domestic entities, such as laboratory, personnel, and provision of high-value materials that are not freely available.
    • Institutional resources that are broadly available (e.g., core facilities or shared equipment) should be listed under Facilities and Other Resources, not Other Support.
  • Consulting agreements involving research.
  • In-kind contributions (such as office/laboratory space, equipment, supplies, human resources) supported by an outside source. These should include actual or reasonable estimates of time commitment and/or dollar value.

Foreign Activities

NIH grant applicants must submit:

  • Copies of contracts, grants, or agreements for foreign appointments/employment.
  • English translations for any non-English documents.
  • Obtain NIH prior approval for inclusion of any foreign components to an NIH award

What is not "Other Support"?

If new or otherwise undisclosed Other Support is discovered, an updated document must be submitted to NIH as soon as the support becomes known.

When and How to Submit to NIH (JIT & RPPR):

  • Just‑in‑Time (JIT): NIH requests Other Support after peer review and before award when an application is under funding consideration. Submit only when NIH asks via eRA Commons; a JIT request is not a Notice of Award.
    Where: eRA Commons → Status → Just‑in‑Time. (See also, NIH GPS §2.5.1 (JIT timing & elements) and eRA Commons JIT Help)
  • Progress reports (RPPR): If Other Support has changed since the last submission (e.g., new award, in‑kind contribution), update at RPPR. (See also, NIH “Other Support” page (who/when))
  • Who must disclose: All Senior/Key Personnel listed on the application, with limited role‑based exceptions as stated by NIH

What Training is Required?  Effective October 1, 2025 (NOT-OD-25-133)

  • Who Is Required to Complete the Training? All Senior/Key Personnel must complete the required training.
  • When does the Training Need to be Completed By?
    • Prior to proposal submission, or
    • Within 30 days of being newly added to an existing NIH award (best practice)
    • Individuals must have completed training within 12 months prior to the proposal submission date.
  • How is This Reported? NIH may require a signed certification of compliance with disclosure requirements.
  • How Long Does the Training Take to Complete? Approximately 60 minutes.

  • What Training Should be Completed? UCCS is offering the CITI training [Research Security Training (Combined Course)] which provides an overview of Research Security, the importance of disclosure, and mitigation and management strategies.

    The CITI training is anticipated to take 60 minutes to complete. This training is shorter than the 4-hour long training modules offered through NSF.

    To sign up, follow these steps:

  1. Sign in to an existing CITI account or start a new account. If you start a new account, be sure to use your UCCS email address and associate your account with UCCS. Guides on how to do this are available on CITI’s website.
  2. Navigate to your “My Courses” page and scroll down to the bottom where you will see “Add a Course”
  3. Select “Research Security”
  4. Select “Research Security Training (Combined Course) A condensed and combined single-module course based on the NSF’s Research Security Training”. 

 

Questions about NIH?

Foreign Talent Recruitment Programs and Malign Foreign Talent Recruitment Programs

Recently, the United States government has expressed concerns about particular programs called Foreign Talent Recruitment Programs (FTRP) and Malign Foreign Talent Recruitment Programs (MFTRP). Federal funding agencies have developed policies prohibiting participation in these programs. To learn more about these programs, visit our page about Foreign Talent Recruitment Programs and Malign Foreign Talent Recruitment Programs.

Links and References

Disclosure Guidance by Common Funding Agencies

*The below are general guidance issued by these agencies. However, researchers should carefully read disclosure requirements in individual funding announcements and work with OSPRI throughout the process.

Additional Information

Image of UCCS sign