Federal Sponsored Projects 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.

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 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

Timing: Submit with application

Applies to: All Senior Personnel

What to disclose: Includes 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: 

  • 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 PHS, 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 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 with application and update in annual progress reports

  • Must be PDFs generated through use of an NSF-approved format
  • RPPR: On October 5, 2020, NSF added the following new question to the Edit Participants screen: Has there been a change in the active other support of the PI/PD(s) since the last reporting period? If Principal Investigators (PIs)/Project Directors (PDs) and co-PIs/co-PDs select “Yes,” they will be required to upload their most up-to-date Current and Pending Support document in an NSF-approved format to notify NSF that active other support has changed since the award was made or since the most recent annual 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:
    • 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.

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:

Department of Defense

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: 

DARPA recently 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:

Department of Energy

Timing: Submit with application as Appendix 2: Current and Pending Support

Applies to: Principal Investigator and senior/key personnel, including subawardees, regardless of funding source

Please note that DOE Offices other than the Office of Science may have different requirements; please check the program solicitation

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 foreign government-sponsored talent recruitment programs must be identified in current and pending support.

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
  • The total cost or value of the award or activity, including direct and indirect costs. 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
  • Briefly describe the research being performed and explicitly identify any overlaps or synergies with the proposed research.

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.

National Aeronautics and Space Administration

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:

NASA is prohibited from funding a “grant or cooperative agreement of any kind to participate, collaborate or coordinate bilaterally in any way with China or any Chinese-owned company at the prime recipient level or at any subrecipient level...”

Resources: