Disclosing Support to Federal Agencies

Global Research at Penn

Current agency guidance for other support follows.

NIH

What to Disclose Where to Disclose When to Disclose
Outside Appointments, both paid and unpaid Biosketch Proposal, RPPR
International Collaborations with activities outside of the U.S. Foreign Component Proposal or requires Prior approval
Related sources of support including post-docs and visiting scholars funded by foreign sources, in kind resources provided by other institutions, and foreign grants the investigators Other Support Proposal, RPPR
International Collaborators in your lab (not key personnel) Personnel report in RPPR RPPR only if effort exceeds month

Click the image to download the table:
NIH Disclosures
This announcement on the NIH website has more information.

NIH Website’s Guidelines »
Council on Governmental Relations Commentary on Disclosing to NIH »

NSF

What to Disclose Where to Disclose When to Disclose
Outside Appointments, both paid and unpaid Biosketch Proposal, RPPR
Research, training and or education carried out with international counterparts either overseas or using virtual technologies Cover sheet (list countries), Project narrative Proposal
Funding of a foreign organization including subaward or consultant arrangements as part of award Cover Sheet Proposal or Requires Prior approval
Unfunded substantial international collaborations Facilities, Equipment and Other Resources and letter of collaboration
Organizations that have been involved as partners and full details of organizations involved as partners
Proposal, RPPR
Other sources of support for research including support to Penn and support directly to the individual (office/laboratory space, equipment, supplies, employees, students) Current and Pending Support Proposal, RPPR
International Collaborators in your lab (not key personnel) Personnel report in RPPR RPPR only if effort exceeds month

NSF Website’s Guidelines »

Department of Defense

What to Disclose Where to Disclose When to Disclose
Outside Appointments, both paid and unpaid Biosketch Proposal
Related sources of support Other Support Proposal

 

Generally, the following information should be disclosed to federal research Sponsors:

mapAt the time of proposal/Just in Time

  • All Outside Appointments, including paid and unpaid, as well as honorary
  • External sources of support
  • Externally provided in kind resources

At the time of progress reporting:

  • New outside appointments
  • New sources of support
  • New externally provided in kind resources
  • New collaborators who are significant contributors
  • Effort expended by visiting researchers and student volunteers if 1 calendar month or more of effort is expended

If there are any questions as to if a new outside appointment or external source of support is permissible under the terms of the award, it is appropriate to discuss the proposed activity with the Sponsor’s Program Office.

It is currently not necessary to report:

  • Support not related to research activities.
    • support to attend or host a conference
    • paid travel expenses to give a talk.
Foreign Components:

Foreign components need prior approval on NIH grants. They should be called out in proposals if known, and should be reported prior to engaging in the research activity if added after the start of the award. Foreign Components include:

  • performance of work related to the grant at a foreign location
  • collaboration related to the funded research with a foreign researcher who will perform work at his/her home institution.

*Note: the foreign component needs to be reported and approved by NIH even if NIH funds are not being used to support the activity

In collaboration with Penn Global