Federal Sponsor Disclosure Requirements

In response to the concerns about undue foreign influence, many federal agencies have adjusted or clarified their disclosure requirements.  Please always refer to the terms and conditions in the award.  The information below highlights some of the main clarification and requirements of the federal sponsors.

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    Resources

    Public Health Service (National Institutes of Health)

    Timing: Submit with application

    Applies to: All Senior/Key Personnel and Other Significant Contributors

    What to disclose: Include positions and honors, list any relevant foreign and domestic, paid and unpaid academic and professional appointments, achievements, and honors including voluntary, guest, adjunct, honorary

    May 25, 2021 Changes

    • NIH renamed Section B “Positions and Honors” to be “Positions, Scientific Appointments, and Honors” and updated the instructions to read (specific changes are in bold italics):
      • List in reverse chronological order all positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary). High school students and undergraduates may include any previous positions. For individuals who are not currently located at the applicant organization, include the expected position at the applicant organization and the expected start date.
    • Section A (Personal Statement)- all applicants may include details about ongoing and completed research projects from the past three years to which they want to draw attention within the personal statement, Section A (previously known as research support)
    • Section D-
      • Non-Fellowship- "Research Support" removed
      • Fellowship- "Research Support" removed and replaced with "Scholastic Performance"

    Resources:

    Timing: Submit with application and requires prior approval when adding a foreign component to the NIH award in Research Performance Progress Report

    Applies to: PHS Project- It is the Program Director/Principal Investigator's responsibility to include foreign component information in the application and request prior approval if necessary

    What to disclose:

    Foreign Component: performance of a significant scientific element of the NIH-supported project outside of the US, whether or not funds are expended

    • Examples of “significant”:
      • Collaborations with investigators at a foreign site anticipated to result in co-authorship
      • Use of facilities or instrumentation at a foreign site
      • Receipt of financial support or resources from a foreign entity
    • "Outside of the US" or Foreign: organization located in a country other than the US and its territories that are subject to the laws of that country, regardless of the citizenship of the proposed Program Director/Principal Investigator

    Resources:

    Timing:

    • KR COI Annual Disclosure required prior to proposal submission and at least annually for the duration of the award
    • Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award and at least annually for the duration of the award

    Applies to: All Investigators on PHS compliant proposals or flow-through excluding SBIR/STTR Phase I proposals are required to disclose their significant financial interests.

    Investigator(s) include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by PHS, or proposed for such funding, which may include, for example, collaborators or consultants.

    • For non-UCI Investigators on the UCI's award/proposal and any subrecipients following UCI's PHS COI Policy, all individuals that meet the definition of an Investigator must submit the Form 800SR.

    What to disclose:

    "Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the Investigator's Institutional Responsibilities includes the following:

    • Total income or payment of services received over the past 12 months and/or equity interest (includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value) in a publicly traded entity exceeding $5,000 when aggregated
    • Total income or payment of services received over the past 12 months from a non-publicly traded entity exceeding $5,000
    • Any equity interest (includes any stock, stock option, or other ownership interest) in a non-publicly traded entity
    • Total payments received over the past 12 months for any intellectual property rights and interests (e.g., patent, copyright, assigned or licensed to a party other than the Regents) exceeding $5,000
    • Any reimbursed or sponsored travel

    The term "Significant Financial Interest" does not include: salary, royalties, or other remuneration paid by the UCI to the Investigator if the Investigator is currently employed or otherwise appointed by the UCI, including intellectual property rights assigned to the UCI and agreements to share in royalties related to such rights; income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; income from seminars, lectures, or teaching engagements sponsored by a US federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a) within the US, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education; or income from service on advisory committees or review panels for a US federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a) within the US, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.  All significant financial interests from a foreign entity (governmental, non-profit, for-profit, etc.) must be disclosed.

    Resources:

    Timing: Submit at Just-in-Time and update in annual progress reports

    Applies to: All individuals designated in an application as senior/key personnel except:

    • Program Directors, training faculty, and other individuals involved in the oversight of training grants
    • Individuals categorized as Other Significant Contributors

    What to disclose: 

    • All foreign and domestic resources made available to a researcher in support of and/or related to ALL of their research endeavors (regardless of whether they have monetary value and whether they are at the institution the researcher identifies for current grant)
    • Resources includes but not limited to foreign and domestic:
      • Current and pending support including support through the applicant organization, through another domestic or foreign organization, or provided directly to an individual that supports the senior/key personnel’s research efforts
      • Positions and scientific appointments including paid and unpaid, full-time, part-time, and voluntary (including adjunct, visiting, or honorary) titled academic, professional, or institutional appointments and affiliations with foreign entities or governments
      • Financial support for laboratory personnel
      • Provision of high-value materials not freely available (e.g., biologics, chemical, model systems, technology, etc.), in-kind support and contributions (e.g. office/laboratory space, equipment, supplies, employees)
      • Foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program
      • Income, salary, consulting fees, and honoraria in support of an individual’s research endeavors
      • Research collaborations that directly benefit the researcher’s research endeavors

    May 25, 2021 Changes

    • Signature block added. The Program Director (PD)/Principal Investigator (PI) and Other Senior/Key Personnel must electronically sign the other support form to certify its accuracy.
    • Supporting documentation. If Other Support includes foreign activities or resources, the PI/PD or Other Senior/Key personnel much attach copies of contracts, grants, or any other agreement specific to their foreign appointments and/or employment with a foreign institution, as well as for all foreign activities and resources reported in Other Support. If these documents are not in English, they must provide translated copies.
    • Immediate notification of undisclosed Other Support. As soon as it becomes known to UCI that a PI/PD or Other Senior/Key personnel on an active NIH grant failed to disclose Other Support information when submitting the Just-in-Time information or RPPR, as applicable, UCI must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.  Even accidental oversight may have individual and/or institutional reputational consequences.  Therefore, PIs/PDs and Other Senior/Key Personnel should take great care to ensure that Other Support is properly and completely disclosed.
    • NIH reorganized the Other Support page to separate funded projects from in-kind contributions.

    Resources: 

    NIH Recommendation: "In the interest of full transparency, recipients should err on the side of disclosure. Researchers should consult with their institutional officials for guidance to ensure compliance with institutional and NIH policies. NIH requires complete and accurate reporting of all sources of research support, financial interests and affiliations, both foreign and domestic.”

    Purpose: NIH evaluation of Other Support to ensure:

    • All resources, domestic or foreign, directly supporting the individual’s research endeavors have been reported
    • Sufficient levels of effort are committed to the project
    • There is no scientific, budgetary, or commitment overlap
    • Only funds necessary to the approved project are included in the award
    • Any foreign resources that meet the definition of a foreign component have received appropriate prior approval.

    National Science Foundation

    January 22, 2024: NSF released the 2024 Proposal & Award Policies and Procedures Guide effective May 20, 2024. See Summary of Changes.

    Timing: Submit through SciENcv with application

    Applies to: All Senior Personnel

    What to disclose: Using SciENcv include education and training, ALL titled foreign or domestic academic, professional, or institutional positions whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary)

    Resources:

    Timing: Submit with application by listing primary countries involved on the coversheet

    Applies to: NSF Project

    What to disclose: International Activities include:

    • International Research/Education/Training Activities: research, training, and/or education carried out in cooperation with foreign counterparts either overseas or in the US using virtual technologies.
    • International Conferences: enter on the Cover Sheet country/countries with which project participants will engage and/or travel to attend international conferences
    • Work in foreign countries: PI responsible for obtaining required authorizations if necessary to conduct work in foreign countries.

    Resources:

    Timing: 

    • KR COI Annual Disclosure required prior to proposal submission
    • Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award- COI Team will send a follow-up NSF question if the Investigator has a positive KR COI Annual Disclosure at award stage to determine if a COIOC review is required
    • Investigators are required to disclose if they acquire or discover a new significant financial interests during the period of the NSF award

    Applies to: All Investigators are required to disclose their significant financial interests. 

    "Investigator(s)" include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by NSF, or proposed for such funding, which may include, for example, collaborators or consultants.  For more clarification, please visit Identifying NSF Investigators.

      • For any non-UCI Investigators on the UCI proposal/award and any subrecipients following UCI's NSF COI policy, all individuals who meet the definition of an Investigator must complete the Form 900SR

    What to disclose: 

    "Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the NSF project includes the following:

    • Total income or payment of services received over the past 12 months exceeding $10,000
      • Includes salary, consultant payments, honoraria, royalty payments, dividends, loan or any other payments or consideration with value, including payments made to the University Health Sciences Compensation Plan). Please exclude income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities and income from service on advisory committees or review panels for public or nonprofit entities
    • Equity interest (e.g., stock, stock options, real estate, or any other investment or ownership interest in an entity exceeding $10,000 (current market value) or a 5% or greater ownership interest
    • Any intellectual property rights and interests (e.g., a patent, patent application, copyright of software assigned or licensed to a party other than the UC Regents)

    Related Financial Interest: Work to be performed under the sponsored project and results therefore that would reasonably appear to affect the Significant Financial Interest of the Investigator or the financial interests of the entity in which the Investigator has a financial interest. 

    Resources:

    Timing: Submit through SciENcv with application and update in annual and final progress reports 

    • If an organization discovers that a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process (see PAPPG Chapter II.D.2.h(ii)), the AOR must submit the information specified in the applicable general term and condition article entitled, “Post-award Disclosure of Current Support and In-kind Contribution Information” within 30 calendar days of the identification of the undisclosed current support or in-kind contribution through use of the Notification and Request Module in Research.gov.
    • RPPR: PIs and co-PIs on active NSF awards must indicate if there has been a change in active other support since submission of the proposal, or the last reporting period in their annual and final project report. If there has been a change, the individual must submit a revised current and pending support document prepared in SciENcv as part of their project report.

    Applies to: All Senior Personnel

    What to disclose: 

    • Includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value including but not limited to the following:
      • All existing projects, as well as all projects currently under consideration for funding

      • Consulting activities must be disclosed under the proposals and active projects section of the common form when any of the following scenarios apply:

        • The consulting activity will require the senior/key person to perform research as part of the consulting activity;
        • The consulting activity does not involve performing research, but is related to the senior/key person’s research portfolio and may have the ability to impact funding, alter time or effort commitments, or otherwise impact scientific integrity; or
        • The consulting entity has provided a contract that requires the senior/key person to conceal or withhold confidential financial or other ties between the senior/key person and the entity, irrespective of the duration of the engagement.
      • Contracts associated with participation in programs sponsored by foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs. Further, if an individual receives direct or indirect support that is funded by a foreign government-sponsored talent recruitment program, even where the support is provided through an intermediary and does not require membership in the foreign government-sponsored talent recruitment program, that support must be disclosed. Senior/key personnel must also report other foreign government-sponsored or affiliated activities.
      • All in-kind contributions with the expectation of an associated time commitment (such as office/laboratory space, equipment, supplies, employees, students) not intended for use on project/proposal being proposed
        • Notes: In-kind contributions intended for use on the project being proposed to NSF should be included as part of the Facilities, Equipment and Other Resources section of the proposal and need not be replicated in the current and pending support submission. Gifts (such as services, lodging, equipment time, etc.) are by definition given without the expectation of anything in return and do not need to be reported.

    Resources: 

    Article 38: Post-award Disclosure of Current Support and In-Kind Contribution Information- Effective 10/5/2020, if an organization discovers that a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process, the Authorized Organizational Representative must submit the information outlined in the article within 30 calendar days of the identification of the undisclosed current support or in-kind contribution.

    Applies to: All Senior/Key Personnel

    Ineligibility: Individuals who are a current party to a Malign Foreign Talent Recruitment Program are not eligible to serve as a senior/key person on an NSF proposal or on any NSF award made after March 25, 2024.

    What to certify: Each individual identified as senior/key person must certify prior to proposal submission that they are not a party to a malign foreign talent recruitment program and annually thereafter for the duration of the award.

    Resource: PAPPG 2024

    Department of Energy

    Timing: With application attached to the Research and Related Senior/Key Person Profile (Expanded) form.

    Applies to: Principal Investigator and all senior/key personnel who will be identified by name in Section A of the application's budget and all other personnel who contribute in a substantive, meaningful way to the scientific development or execution of the project, whether or not salaries are requested (including Consultants if they meet this definition).

    What to disclose: A biosketch is to provide information that can be used by reviewers to evaluate the PI’s potential for leadership within the scientific community. Examples of information of interest are invited and/or public lectures, awards received, scientific program committees, conference or workshop organization, professional society activities, special international or industrial partnerships, reviewing or editorship activities, or other scientific leadership experiences. 

    SC requires the use of the format approved by the National Science Foundation (NSF), which may be generated by the Science Experts Network Curriculum Vita (SciENcv), a cooperative venture maintained at https://www.ncbi.nlm.nih.gov/sciencv/.

    The biographical information (curriculum vitae) must include the following items within its page limit: 

    • Education and Training: Undergraduate, graduate and postdoctoral training, provide institution, major/area, degree and year. 
    • Research and Professional Experience: Beginning with the current position list in chronological order, professional/academic positions with a brief description. 
    • Publications: Provide a list of up to 10 publications most closely related to the proposed project. For each publication, identify the names of all authors (in the same sequence in which they appear in the publication), the article title, book or journal title, volume number, page numbers, year of publication, and website address if available electronically. Patents, copyrights and software systems developed may be provided in addition to or substituted for publications. An abbreviated style such as the Physical Review Letters (PRL) convention for citations (list only the first author) may be used for publications with more than 10 authors. 
    • Synergistic Activities: List no more than 5 professional and scholarly activities related to the effort proposed.

    Resources: 

    The following disclosure requirements were implemented on June 18, 2022 unless otherwise required by a DOE award.

    Timing: 

    • KR COI Annual Disclosure required prior to proposal submission and at least annually for the duration of the award
    • Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award and at least annually for the duration of the award
    • With the acquisition or discovery of a new significant financial interest during an active DOE award

    Applies to: All Investigators on DOE proposals or flow-through excluding SBIR/STTR Phase 1 and Office of Indian Energy proposals are required to disclose their significant financial interests .

    "Investigator(s)" include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the purpose, design, conduct, or reporting of research funded by DOE, or proposed for such funding, which may include, for example, collaborators or consultants.  Note: DOE Program Officers retain discretion to expand the definition of an Investigator for a specific award.

    • For non-UCI Investigators on the UCI's award/proposal and any subrecipients following UCI's DOE COI Policy, all individuals that meet the definition of an Investigator must submit the Form 800SR.

    What to disclose: 

    "Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the Investigator's Institutional Responsibilities includes the following:

    • Total income or payment of services received over the past 12 months and/or equity interest (includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value) in a publicly traded entity exceeding $5,000 when aggregated
    • Total income or payment of services received over the past 12 months from a non-publicly traded entity exceeding $5,000
    • Any equity interest (includes any stock, stock option, or other ownership interest) in a non-publicly traded entity
    • Total payments received over the past 12 months for any intellectual property rights and interests (e.g., patent, copyright, assigned or licensed to a party other than the Regents) exceeding $5,000
    • Any reimbursed or sponsored travel

    The term "Significant Financial Interest" does not include: salary, royalties, or other remuneration paid by the UCI to the Investigator if the Investigator is currently employed or otherwise appointed by the UCI, including intellectual property rights assigned to the UCI and agreements to share in royalties related to such rights; income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; income from seminars, lectures, or teaching engagements sponsored by a US federal, state, or local government agency, a domestic institution of higher education, or a  domestic research institute that is affiliated with an institution of higher education; or income from service on advisory committees or review panels for a US federal, state, or local government agency, a domestic institution of higher education, or a domestic research institute that is affiliated with an institution of higher education.  All significant financial interests from a foreign entity (governmental, non-profit, for-profit, etc.) must be disclosed.

    Resources

    Resources:

    Updated to reflect new DOE Financial Assistance Letter 2022-04 issued on June 1, 2022

    Timing:

    • Submit with application as required by funding opportunity announcements.
    • 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.
    • 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.

    Applies to: Principal Investigator and senior/key personnel, including subawardees

    What to disclose: 

    A list of all sponsored activities, awards, and appointments, whether paid or unpaid; provided as a gift with terms or conditions or provided as a gift without terms or conditions; full-time, part-time, or voluntary; faculty, visiting, adjunct, or honorary; cash or in-kind; foreign or domestic; governmental or private-sector; directly supporting the individual’s research or indirectly supporting the individual by supporting students, research staff, space, equipment, or other research expenses. All involvement in foreign government-sponsored talent recruitment programs must be identified in current and pending support.

    Program offices may also require disclosure of past support, limited to a reasonable time period to be determined by the program office.

    For every activity, list the following items:

    • The sponsor of the activity or the source of funding.
    • The award or other identifying number.
    • The title of the award or activity. If the title of the award or activity is not descriptive, add a brief description of the research being performed that would identify any overlaps or synergies with the proposed research.
    • The total cost or value of the award or activity, including direct and indirect costs and cost share. For pending proposals, provide the total amount of requested funding.
    • The award period (start date – end date).
    • The person-months of effort per year being dedicated to the award or activity.
    • If required to identify overlap, duplication of effort, or synergistic efforts, append a description of the other award or activity to the current and pending support.

    Each current and pending support disclosure must be signed, dated, and include a certification statement. The information may be provided in the formats approved by the National Science Foundation (NSF):

    • SciENcv: a signature, date, and a certification statement must be attached until the website automatically attaches a certification statement (anticipated Spring 2022).
    • NSF Fillable PDF: a signature, date, and a certification statement must be attached.

    Certification Statement:

    “I, [Full Name and Title], certify to the best of my knowledge and belief that the information contained in this Current and Pending Support Disclosure Statement is true, complete, and accurate. I understand that any false, fictitious, or fraudulent information, misrepresentations, half-truths, or omissions of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (18 U.S.C. §§ 1001 and 287, and 31 U.S.C. 3729-3733 and 3801-3812). I further understand and agree that (1) the statements and representations made herein are material to DOE’s funding decision, and (2) I have a responsibility to update the disclosures during the period of performance of the award should circumstances change which impact the responses provided above.”

    Resources:

    Purpose: Current and Pending support is intended to allow the identification of potential duplication, over-commitment, potential conflicts of interest or commitment, and all other sources of support.

    Department of Defense

    August 9, 2024- DoD starts prohibiting any funding or award to a fundamental research project in which a covered individual is participating in a malign foreign talent recruitment program

    Timing: With proposal application and possibly during an award's performance period as specified by the DOD agency

    In general, researchers should disclose all paid or unpaid positions with non-profit or commercial entities or academic or research institutions, including honorary positions, affiliated positions, joint positions, participation in Talents Programs, and relevant honors. Biographical sketch requirements vary depending on the DOD agency and funding opportunity. Consequently, to help prevent accidental non-compliance, please carefully review the disclosure requirements associated with each funding opportunity announcement. Questions about biographical sketch requirement should be directed to the Contract and Grant Officer assigned to your unit.

    In addition, please note that a DOD agency may require updated biographical sketch information during an award’s performance period. Please be sure to carefully read the award terms and conditions to learn when such updates, if required, must be submitted.

    Note: In some cases, NIH biographical sketches could be used.

    Timing: Submit with application

    Applies to: Proposals for all non-procurement research and research-related educational activities (i.e., grants, cooperative agreements, Technology Investment Agreements) should include the below information for all key personnel, whether or not the individuals’ efforts under the project are to be funded by DoD in the Senior Key Person Profile form included in the Notice of Funding Opportunities

    Please note that DOD proposals for other types of awards may have other requirements so please check the program solicitation.

    What to disclose: 

    • List of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of source
    • Title and objectives of other research projects
    • Percentage per year to be devoted to other projects
    • Total amount of support the individual is receiving in connection to each of the other projects or will receive if other proposals are awarded
    • Name and address of agencies and/or other parties supporting the other research projects
    • Period of performance of other research projects

    Resources: 

    Starting August 9, 2024, the Department of Defense is prohibited from providing funding to or making an award of a fundamental research project proposal in which a covered individual is participating in a malign foreign talent recruitment program or to a proposing institution that does not have a policy addressing malign foreign talent programs pursuant to Section 10632 of the CHIPS and Science Act of 2022. 

    Definitions:

    • Covered Individual: An individual at an extramural research institution who contributes significantly to the design and/or execution of a fundamental research project that is, or if selected for award would be, funded, in whole or in part, by the Department of Defense, and who is considered essential to the successful performance of the fundamental research project. Covered individuals include those listed as key personnel in fundamental research project proposals, such as the principal investigator or co-principal investigators.
    • Malign Foreign Talent Recruitment Program: Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue in exchange for the individual:
      • Engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials or data products;
      • Being required to recruit trainees or researchers to enroll in such program, position, or activity;
      • Establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;
      • Being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances; 
      • Through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in a substantial overlap or duplication with a Federal research and development award;
      • Being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient;
      • Being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to institutional policies or standard terms and conditions of the Federal research and development award;
      • Being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or
      • Having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award; and
    • A program that is sponsored by:
      • A foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern;
      • An academic institution on the list developed under Section 1286(c)(8) of the John S. McCain NDAA for FY 2019 (10 U.S.C. 2358 note; Public Law 115-232); or 
      • A foreign talent recruitment program on the list developed under Section 1286(c)(9) of the John S. McCain NDAA for FY 2019 (10 U.S.C. 2358 note; Public Law 115-232)

    Resource: DoD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions (starting page 9)

    DARPA released a memo to DARPA staff and contractors announcing their Countering Foreign Influence Program (CFIP) will create risk assessments of all proposed Senior/Key Personnel selected for negotiations of a fundamental research grant or cooperative agreement award. The CFIP risk assessment process will be conducted separately from the DARPA scientific review process and adjudicated prior to final award. More details are available in the risk rubric.

    Resources:

    The Army Research Risk Assessment Protection Program (ARRP) issued a Risk Matrix/Rubric and FAQs related to the identification and mitigation of conflicts of commitment/conflicts of interest in Army research grants and cooperatives agreements.  These two resources are available on the ARRP website.

    National Aeronautics and Space Administration

    NASA COI Policy implemented December 1, 2023

    Timing: Submit with application

    Applies to: PIs, Co-Principal Investigators (CoPIs), and any Co-I serving in one of the three special Co-I categories and (if the person is known) graduate student participant/trainees as defined in NASA's Guidebook Appendix B.

    No biographical sketches are required for Co-Is or other team members who are spending less than 10 percent of their time in any given year on the proposed work unless specified in the NOFO.

    What to disclose: Includes their professional experiences, positions, and a bibliography of publications, especially those relevant to the proposed effort, as well as a description of scientific, technical, and management experience on relevant prior efforts.

    • PIs, Co-PIs, and any Co-Is serving in one of the 3 special Co-I categories and (if known) graduate student participant/trainees defined in Appendix B
    • No biographical sketches are required for Co-Is or other team members who are spending less than 10 percent of their time in any given year on the proposed work unless specified in the NOFO.

    Resources:

    Timing: Submit with application

    Applies to: Principal Investigator and Co-Principal Investigators and Co-Investigators proposing to spend 10% or more of their time in any given year to the proposed effort.  The proposing PI shall also notify the NASA Program Officer identified in the NOFO immediately of any successful proposals that are awarded for substantially overlapping work as proposed to NASA, any time after the proposal due date and until the announcement of NASA’s selections.

    What to disclose: 

    Principal Investigators and Co-Principal Investigators:

    • All ongoing and pending projects and proposals (regardless of salary support) in which they are performing or will perform any part of the work
    • Current and pending support with Chinese universities and other similar institutions or a Chinese-owned company at the prime recipient level and at all subrecipient levels, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement.
      • Note: "China or Chinese-owned Company" means the People's Republic of China (PRC), any company owned by the PRC, or any company incorporated under the laws of the PRC. Chinese universities and other similar institutions are
        considered to be incorporated under the laws of the PRC and, therefore, the funding restrictions apply to grants and cooperative agreements that include bilateral participation, collaboration, or coordination with Chinese universities.

    Co-Investigators: a list of ongoing and pending projects and proposals (regardless of salary support) that require more than 10% of their time in any given year

    For each current and pending project, provide the following items:

    • Title of funded project or proposal title;
    • Name of PI on award or proposal;
    • Program name (if appropriate) and sponsoring agency or organization, including a point of contact with their telephone number and email address;
    • Performance period;
    • Total amount proposed (if pending) or received by that PI (including indirect costs) for that award or the amount per year if uniform (e.g., $50k/year); and
    • Time commitment by the PI for each year of the period of performance.

    Resources:

    Timing: With proposal submission and award certifications

    Applies to: Grants, cooperative agreements and contracts

    What to do:

    • Assistance Awards (Grants and Cooperative Agreements): Assure will not participate, collaborate, or coordinate bilaterally 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. This assurance requirement imposes an award restriction which is broader than the "contracting with China" restriction under NASA contracts and extends to individuals performing part of the NASA-funded scope of work who have an affiliation with China or a Chinese-owned company.
    • Contracts: Assure will not enter into bilateral written contracts or subcontracts with China for the performance of any part of the NASA scope of work.

    Resources:

    Timing: 

    • KR COI Annual Disclosure required prior to proposal submission
    • Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award- COI Team will send a follow-up NSF/NASA question if the Investigator has a positive KR COI Annual Disclosure at award stage to determine if a COIOC review is required
    • Investigators are required to disclose if they acquire or discover a new significant financial interests during the period of the NSF/NASA award

    Applies to: All Investigators on NASA proposals and flow-through are required to disclose their significant financial interests. 

    "Investigator(s)" include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by NASA, or proposed for such funding, which may include, for example, collaborators or consultants.  

      • For any non-UCI Investigators on the UCI proposal/award and any subrecipients following UCI's NSF/NASA COI policy, all individuals who meet the definition of an Investigator must complete the Form 900SR

    What to disclose: 

    "Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the NASA project includes the following:

    • Total income or payment of services received over the past 12 months exceeding $10,000
      • Includes salary, consultant payments, honoraria, royalty payments, dividends, loan or any other payments or consideration with value, including payments made to the University Health Sciences Compensation Plan). Please exclude income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities and income from service on advisory committees or review panels for public or nonprofit entities
    • Equity interest (e.g., stock, stock options, real estate, or any other investment or ownership interest in an entity exceeding $10,000 (current market value) or a 5% or greater ownership interest
    • Any intellectual property rights and interests (e.g., a patent, patent application, copyright of software assigned or licensed to a party other than the UC Regents)

    Related Financial Interest: Work to be performed under the sponsored project and results therefore that would reasonably appear to affect the Significant Financial Interest of the Investigator or the financial interests of the entity in which the Investigator has a financial interest. 

    Resources: