Disclosure Requirements Frequently Asked Questions
Overview
Faculty, staff, and students may have disclosure requirements arising from University policies, federal sponsor requirements, state or federal requirements, or the terms and conditions of a research award.
Disclosure requirements vary depending on the individual's University role, research activities, external interests and commitments, and sources of research support. More than one disclosure requirement may apply to the same activity or relationship.
The Office of Research Security (ORS) provides guidance regarding University disclosure requirements and research security-related disclosure obligations and coordinates with the Office of Sponsored Programs and other University offices, as appropriate.
Why are research-related disclosures required?
Disclosure requirements promote transparency regarding external interests, commitments, affiliations, appointments, research support, and other activities that may affect University responsibilities or federally sponsored research.
University and federal sponsor requirements help institutions and sponsors identify and address potential conflicts of interest or commitment, duplication of research support, undisclosed affiliations or appointments, prohibited activities, and other research security concerns.
Are University disclosure requirements and federal sponsor disclosure requirements the same?
No.
University disclosure requirements address external interests, activities, relationships, and commitments that must be reported to Stony Brook University in accordance with applicable University policies and procedures.
Federal sponsor disclosure requirements establish information that must be reported to a sponsoring agency, often through proposal and award documents such as Biographical Sketches, Current & Pending (Other) Support, Other Support, or other sponsor-required disclosures.
An activity may need to be disclosed to the University, a federal sponsor, or both.
Researchers are responsible for complying with all applicable disclosure requirements.
What types of activities or relationships may need to be disclosed?
Depending on the applicable University or sponsor requirements, disclosures may include:
- Outside appointments or positions.
- Consulting or other professional activities.
- Paid or unpaid affiliations.
- Research support.
- In-kind contributions or resources.
- Sponsored travel.
- Gifts or other resources supporting research.
- Equity or ownership interests.
- Participation in outside companies or organizations.
- External laboratory, office, personnel, equipment, or other resources.
- Foreign or domestic research collaborations or affiliations.
- Participation in foreign talent recruitment programs.
- Other external interests, activities, relationships, or commitments required by University policy or a research sponsor.
The information that must be disclosed depends on the applicable requirement.
Do disclosure requirements apply only to international activities?
No.
University disclosure requirements and federal sponsor disclosure requirements may apply to both domestic and international interests, activities, relationships, appointments, affiliations, commitments, and sources of support.
Some federal research security requirements establish additional requirements or restrictions involving certain foreign activities, entities, countries, or foreign talent recruitment programs, but researchers should not assume that a domestic activity does not need to be disclosed.
Do unpaid appointments or activities need to be disclosed?
They may.
Disclosure requirements are not limited to activities for which an individual receives salary or other compensation. Unpaid appointments, affiliations, positions, research resources, laboratory access, personnel support, or other relationships may be reportable depending on the applicable University or sponsor requirements.
Researchers should consider the nature of the relationship or resource rather than whether compensation is received.
Do I need to disclose outside academic appointments?
Outside academic appointments may be subject to University and federal sponsor disclosure requirements, including paid, unpaid, honorary, adjunct, visiting, or other appointments or affiliations.
The specific reporting requirements depend on the nature of the appointment and the applicable University and sponsor requirements.
Do consulting activities need to be disclosed?
Consulting and other outside professional activities may be subject to University disclosure requirements when they relate, or could reasonably appear to relate, to an individual's institutional responsibilities or otherwise present a potential conflict of interest or commitment.
Consulting relationships may also need to be reported to a federal sponsor when they fall within the sponsor's disclosure requirements.
Do I need to disclose a faculty startup company or other company I own?
Ownership, equity, management roles, consulting relationships, or other interests in an outside company may be subject to University disclosure requirements.
Additional requirements may apply when the company:
- Sponsors or participates in University research.
- Licenses or may license University intellectual property.
- Employs or engages the researcher as a consultant.
- Participates in an SBIR or STTR project involving the University.
- Provides resources or support related to University research.
- Otherwise has a relationship with the researcher's University responsibilities.
Researchers involved with faculty startup companies should review the applicable University and sponsor requirements and seek guidance when necessary.
Do research resources provided by another organization need to be disclosed?
They may.
Federal sponsors may require disclosure of research resources provided by an external organization even when the support is not provided directly to Stony Brook University or does not involve a monetary payment to the researcher.
Examples may include:
- Laboratory or office space.
- Equipment or materials.
- Research personnel.
- Visiting researchers or students supported by another organization.
- Data or other research resources.
- Research funding provided directly to an investigator or another institution.
- Other in-kind contributions supporting an individual's research activities.
Sponsor requirements vary, so investigators should review the requirements applicable to each sponsor.
What is Current & Pending (Other) Support?
Current & Pending (Other) Support is used by federal research sponsors to identify research activities and resources available to or supporting an investigator.
Depending on the sponsor, required disclosures may include current and pending research projects, external research support, in-kind contributions, research resources, and other activities or support.
Federal agencies may use different forms, terminology, instructions, and certification requirements. Investigators should follow the requirements of the specific sponsoring agency.
What information belongs in a Biographical Sketch?
Federal sponsors use Biographical Sketches to obtain information about an individual's professional preparation, appointments, positions, affiliations, and other information relevant to the proposed research.
The information required varies by sponsor and may change over time.
Investigators should use the current sponsor-required format and instructions when preparing a proposal.
What is a Foreign Component?
Some federal sponsors use the term Foreign Component for certain activities involving a significant scientific element or segment of a project conducted outside the United States.
Whether an activity constitutes a Foreign Component depends on the sponsoring agency's requirements and the circumstances of the research.
International collaboration does not automatically mean that a project has a Foreign Component. Researchers should review the requirements of the applicable sponsor and seek guidance when uncertain.
What is a Foreign Talent Recruitment Program?
A Foreign Talent Recruitment Program generally involves an arrangement, program, or activity through which a foreign country or foreign entity seeks to recruit science and technology professionals or researchers.
Federal law, sponsor requirements, and University policy establish disclosure requirements and, in certain circumstances, restrictions related to participation in Foreign Talent Recruitment Programs.
Researchers should contact ORS before participating in a Foreign Talent Recruitment Program or if they are uncertain whether a proposed activity meets the applicable definition.
What is a Malign Foreign Talent Recruitment Program?
Federal law defines certain Foreign Talent Recruitment Programs as Malign Foreign Talent Recruitment Programs (MFTRPs) based on the characteristics of the program, the obligations imposed on participants, and/or the foreign entities or countries involved.
Federal research agencies prohibit covered individuals from participating in Malign Foreign Talent Recruitment Programs and require certifications related to such participation.
Researchers who are considering or currently participating in a Foreign Talent Recruitment Program should contact ORS for review.
When should I update a disclosure?
The timing depends on the applicable disclosure requirement.
University disclosure requirements may require updates when new or anticipated external interests, activities, relationships, or commitments arise, in addition to required annual certification.
Federal sponsors may require disclosures at proposal submission, Just-in-Time, prior to award, during annual or progress reporting, or when circumstances change during an award.
Researchers should not wait for the next proposal or annual disclosure cycle if an applicable requirement requires an earlier update.
What should I do if I realize something was omitted from a sponsor disclosure?
Contact the appropriate University office promptly.
Sponsor requirements may require corrections or updates when information was omitted or when previously submitted information changes. The appropriate response depends on the sponsor, award, information involved, and applicable reporting requirements.
Researchers should coordinate any correction or sponsor notification through the appropriate University process rather than contacting the sponsoring agency independently on behalf of the University.
Does disclosure mean an activity is prohibited?
No.
Disclosure and prohibition are different concepts. Many outside activities, collaborations, appointments, affiliations, and sources of support are permissible when properly disclosed and conducted in accordance with applicable University and sponsor requirements.
However, some activities may require additional review, management, sponsor notification or approval, or other action. Certain activities may also be prohibited by University policy, federal law, or sponsor requirements.
ORS can assist researchers in identifying requirements that apply to a proposed activity.
Does disclosing an activity to Stony Brook satisfy my federal sponsor disclosure requirements?
Not necessarily.
Reporting an activity through a University disclosure process does not automatically satisfy a federal sponsor's disclosure requirements.
Similarly, including information in a federal sponsor disclosure does not necessarily satisfy University disclosure requirements.
Researchers should ensure that information is reported through each process required by the University and applicable sponsors.
Where do I report my University external interests and commitments?
Individuals subject to the University's disclosure requirements report applicable external interests, activities, relationships, and commitments through the University's designated disclosure process.
University disclosure guidance provides information about who must disclose, what must be disclosed, when disclosures must be made, and how to complete and maintain a Disclosure Profile.
VIEW UNIVERSITY DISCLOSURE REQUIREMENTS
Where can I find federal sponsor disclosure requirements?
Federal research sponsors establish their own disclosure instructions and requirements for proposal and award documents.
Researchers should consult the applicable sponsor guidance and University resources when preparing Biographical Sketches, Current & Pending (Other) Support, Other Support, or other sponsor-required disclosures.
VIEW FEDERAL SPONSOR DISCLOSURE REQUIREMENTS
Need Assistance?
Disclosure requirements can overlap and may vary based on an individual's role, external activities, research support, and sponsoring agency.
Contact ORS if you are uncertain whether an external interest, activity, appointment, affiliation, commitment, or research relationship must be disclosed under University research security requirements.
Questions regarding preparation or submission of sponsor proposal and award documents should be coordinated with the appropriate University research administration office.