Disclosures

Federal funding agencies have recently started to review the information researchers provide in their disclosure documents for research security purposes. They have also developed powerful new tools to help identify any omissions in these documents. It is absolutely essential that all other funding and support (including in-kind support), collaborations, and affiliations are disclosed to both federal sponsors and to Vanderbilt. When in doubt, disclose; federal funding agencies have repeatedly noted that over-disclosure is not penalized.

Best Practices

  • Sign up for an ORCID ID and keep it updated with your most recent publications. You can link your ORCID ID to SciENcv to generate complete and accurate biosketches and other support documents. You can find some more information on setting up and maintaining an ORCID ID at the Vanderbilt Library.
  • Actively review your disclosure documents before submitting any proposal to external funders. Do not wait until the last minute to update these documents!
  • Be especially mindful to disclose all sources of support or collaborations involving countries of concern (China, Iran, North Korea, and Russia).
  • Submit proposals to the Sponsored Programs Administration at least 3 days before the sponsor deadline so they can be fully reviewed.

Current Guidelines for Disclosing to Federal Agencies

  • National Institutes of Health (NIH)

    NIH created a table outlining what needs to be disclosed and how and is continuing to update FAQs to address specific details.

    • In the biosketch, key personnel must disclose scientific affiliations or appointments
    • In Other Support, disclose all sources of support for all research activities.
      • Remember to including in-kind resources that are uniquely available to key personnel (office/laboratory space, equipment, supplies, and employees) including those available outside the applicant institution.
      • Include funds outside of appointment period, such as summer research funding.
      • Report all current and pending support at the time of applicant submission, in progress reports, and other times, if there are substantive changes.
    • Disclose Foreign Components on proposals, progress reports and final technical reports.
      • Check yes to a question such as “Does this project involve activities outside of USA” on the cover page.
      • Identify and list non-US performance sites for the project.
      • Identify international collaborators and their roles.
      • Review all pending & active awards and contact Sponsored Programs Administration to correct errors if any.
  • National Science Foundation (NSF)

    NSF has worked in close collaboration with the NIH on Research Security, including efforts to harmonize their practices and in the creation of a similar table outlining Pre-award and Post-award Disclosures and a FAQ on Current and Pending Support.

  • Department of Defense (DoD)

    DoD requirements will be listed in each Notice of Funding Opportunity and will include information to be included in biosketches and other support disclosures.

    • In the biosketch, all key personnel, should include all positions, including unpaid positions, honorary titles, affiliated and joint positions, and participation in Talents Programs.
    • All key personnel need to disclose other support, including
      • 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 project
  • Department of Energy (DOE)

    Funding opportunity announcements (FOA) will require that:

    • Applicants include current and pending support disclosures for all PIs and other senior/key personnel named in the application.
    • 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.
  • National Aeronautics and Space Administration (NASA)

Disclosing to Vanderbilt