Federal Sponsor Disclosure Requirements
Overview
Federal sponsors require investigators to disclose information regarding research support, professional appointments and affiliations, collaborations, foreign activities, financial interests, and other information necessary to promote transparency, protect research integrity and research security, and ensure compliance with sponsor requirements.
Sponsor disclosures are separate from—and in addition to—the University's Disclosure of External Interests & Commitments requirements. Investigators are responsible for ensuring that sponsor disclosures are complete, accurate, current, and consistent with both sponsor instructions and their University Disclosure Profile.
Although disclosure requirements vary by agency, most federal sponsors require investigators to report information throughout the lifecycle of a sponsored project, including proposal development, award negotiation, project performance, and post-award management.
The Office of Research Security (ORS) has developed sponsor-specific disclosure guidance to help investigators understand agency disclosure requirements, Common Forms, sponsor-specific expectations, and post-award disclosure obligations.
Browse the sponsor-specific disclosure guidance below to learn more about the requirements that apply to your funding agency.
General Sponsor Disclosure Requirements
Depending on the sponsor, investigators may be required to disclose:
| Disclosure Topic | Description |
|---|---|
| Biographical Sketches | Investigator qualifications, appointments, affiliations, education, and professional experience. |
| Current and Pending (Other) Support | Active and pending research support, research resources, and in-kind contributions, as required. |
| Available Resources | Facilities, equipment, personnel, and other resources available for the proposed project. |
| Foreign Components | Research activities outside the United States or involving foreign organizations, when defined by the sponsor. |
| International Collaborations & Affiliations | International research relationships, appointments, affiliations, and collaborations requiring disclosure. |
| Conflict of Interest / Conflict of Commitment | Financial interests and outside activities when required by sponsor policy. |
| Foreign Talent Recruitment Programs | Certifications or disclosures regarding Foreign Talent Recruitment Programs, when applicable. |
| Other Sponsor-Specific Requirements | Additional disclosures required by agency policy or funding opportunity instructions. |
General Best Practices
Before Proposal Submission
- Review the funding opportunity announcement and agency-specific guidance.
- Ensure institutional and sponsor disclosures are complete, accurate, and consistent.
- Discuss foreign collaborations, foreign components, or international activities with OSP and ORS early.
- Review sponsor definitions, as disclosure terminology varies by agency.
During the Award
- Update sponsor disclosures when required.
- Obtain sponsor prior approval before adding foreign components or other activities requiring approval.
- Notify ORS of new outside appointments, research support, or other reportable activities.
- Maintain an accurate University Disclosure Profile.
Publications and Reporting
- Acknowledge only the funding that directly supported the published work.
- Follow sponsor-specific publication acknowledgment requirements.
- Report publications in accordance with sponsor progress reporting requirements.
Sponsor-Specific Disclosure Guidance
The Office of Research Security has developed sponsor-specific disclosure reference guides to help investigators understand agency disclosure requirements throughout the proposal and award lifecycle.
| Reference Guide | Description |
|---|---|
| Department of Defense (DoD) | Sponsor-specific guidance for DoD disclosure requirements, Common Forms, research security requirements, and post-award disclosure obligations. |
| Department of Energy (DOE) | Sponsor-specific guidance for DOE disclosure requirements, Common Forms, research security expectations, and ongoing disclosure obligations. |
| National Aeronautics and Space Administration (NASA) | Sponsor-specific guidance for NASA disclosure requirements, Common Forms, research security requirements, and investigator responsibilities. |
| National Institutes of Health (NIH) | Sponsor-specific guidance for NIH disclosure requirements, Common Forms, Foreign Components, Other Support, and post-award disclosure requirements. |
| National Science Foundation (NSF) | Sponsor-specific guidance for NSF disclosure requirements, Common Forms, Current and Pending (Other) Support, Malign Foreign Talent Recruitment Program requirements, and annual certifications. |
Learn More
Other Federal Sponsors
Many federal agencies implement government-wide disclosure requirements established through NSPM-33, the CHIPS and Science Act, and related federal guidance. Because agency-specific implementation varies, investigators should review the applicable Notice of Funding Opportunity (NOFO) and sponsor instructions.
Related University Guidance
| Reference Guide | Description |
|---|---|
| Disclosure of External Interests & Commitments | University disclosure requirements for outside professional activities and external interests. |
| Conflict of Interest | Financial conflicts of interest in research. |
| Conflict of Commitment | Outside professional activities and competing commitments. |
| Foreign Talent Recruitment Programs | Federal restrictions and disclosure requirements. |
| Organizational Conflict of Interest | Institutional conflicts affecting sponsored activities. |
Research Security Considerations
Disclosure requirements are one component of each federal sponsor's broader research security program. Investigators may also need to comply with sponsor requirements related to international collaborations, research security training, foreign talent recruitment programs, export controls, prior approvals, and other award-specific obligations.
ORS has developed Federal Sponsor Research Security Guidance to help investigators understand these broader sponsor requirements throughout the proposal and award lifecycle.
Learn More
Federal Sponsor Research Security Guidance
ORS Assistance
If you have questions regarding sponsor disclosure requirements, foreign collaborations, appointments, research support, or other reportable activities, contact the Office of Research Security before submitting your proposal or making changes to an active award.