Disclosure Requirements
Overview
Transparency is fundamental to maintaining research integrity, research security, and public trust. The Office of Research Security (ORS) administers the University's Disclosure Program, helping faculty, staff, students, and other researchers understand and comply with University and sponsor disclosure requirements.
Depending on an individual's University role, funding sources, and research activities, disclosure obligations may include external interests, professional activities, appointments, affiliations, research support, conflicts of interest, conflicts of commitment, and participation in Foreign Talent Recruitment Programs.
This page provides an overview of the University's research disclosure programs and directs researchers to guidance on institutional disclosures, federal sponsor disclosure requirements, research Conflicts of Interest, research Conflicts of Commitment, Foreign Talent Recruitment Programs, Organizational Conflicts of Interest, and related topics.
University Disclosure Requirements
The University's Disclosure of External Interests & Commitments Policy requires certain faculty, staff, students, and researchers to disclose external interests, professional activities, appointments, affiliations, research support, and other reportable relationships. These disclosures promote transparency and help the University meet its obligations under institutional policy, federal regulations, and sponsor requirements.
The University's Disclosure Profile provides a centralized institutional record that supports sponsor compliance, institutional review, and other University processes. Information reported through the Disclosure Profile is also used by ORS in administering the University's research Conflict of Interest (COI) and Conflict of Commitment (COC) programs and evaluating other research security and sponsor disclosure requirements, as appropriate.
Maintaining a complete and current Disclosure Profile helps ensure that institutional and sponsor disclosures remain accurate, consistent, and up to date throughout the lifecycle of a research project.
Learn More
Federal Sponsor Disclosure Requirements
Many federal sponsors require investigators to submit disclosures in addition to the University's institutional disclosure requirements. These sponsor disclosures are separate from—and do not replace—the University's Disclosure Profile and must be prepared in accordance with the specific requirements of the sponsoring agency.
Depending on the sponsor, investigators may be required to disclose information related to research support, appointments and affiliations, international collaborations, Foreign Components, Current and Pending (Other) Support, Available Resources, Foreign Talent Recruitment Programs, Common Forms, and other agency-specific disclosure requirements.
Although disclosure requirements vary among federal agencies, they share a common purpose: to promote transparency, protect research integrity and research security, and ensure compliance with sponsor policies and federal regulations.
Investigators are responsible for ensuring that sponsor disclosures are complete, accurate, current, and consistent with both sponsor instructions and their University Disclosure Profile.
Learn More
Federal Sponsor Disclosure Requirements
Research Conflict of Interest & Conflict of Commitment Program
The Research Conflict of Interest and Conflict of Commitment (COI/COC) Program provides the framework for reviewing external interests and commitments that may affect—or appear to affect—an individual's research or University responsibilities.
ORS administers the Research COI/COC Program in accordance with the University's Disclosure of External Interests & Commitments Policy, applicable University procedures, and federal sponsor requirements.
Disclosure of an external interest or commitment does not necessarily mean that a conflict exists. ORS reviews disclosed information to determine whether a Conflict of Interest, Conflict of Commitment, or other concern exists and whether additional review or management is necessary.
- Conflict of Interest. A Conflict of Interest (COI) may arise when an individual's financial or personal interests could affect—or appear to affect—their professional judgment, research decisions, or University responsibilities. Learn More About Conflict of Interest
- Conflict of Commitment. A Conflict of Commitment (COC) may arise when outside professional activities, appointments, affiliations, or other external commitments interfere—or reasonably appear to interfere—with an individual's ability to fulfill their University responsibilities. Learn More About Conflict of Commitment
The Research COI/COC Program also provides information about COI training, University review, conflict determinations, and conflict management.
Conflict of Interest Disclosure and Compliance Procedures for Researchers — Procedures governing research COI disclosure, review, determination, management, and compliance.
Learn More
Research Conflict of Interest & Conflict of Commitment Program
Foreign Talent Recruitment Programs
Federal research sponsors require disclosure of certain foreign appointments, affiliations, research support, and other professional activities. Many sponsors also prohibit participation in Malign Foreign Talent Recruitment Programs (MFTRPs) for individuals participating in federally funded research.
ORS provides guidance regarding Foreign Talent Recruitment Programs (FTRPs), sponsor disclosure requirements, federal restrictions, and University disclosure obligations.
Learn More
FOREIGN TALENT RECRUITMENT PROGRAMS
Organizational Conflict of Interest
An Organizational Conflict of Interest (OCI) differs from an individual Conflict of Interest (COI). Rather than involving a researcher's personal financial interests or relationships, an OCI arises when the University's institutional relationships, financial interests, or other activities could impair—or appear to impair—its objectivity in conducting sponsored activities.
Certain federal sponsors require institutions to identify, evaluate, disclose, and, when necessary, manage Organizational Conflicts of Interest to help ensure that sponsored activities are conducted objectively and without institutional bias.
Organizational Conflict of Interest considerations may arise during proposal development, contract negotiations, subaward relationships, technology commercialization activities, procurements, or other sponsored research activities. ORS works with investigators and University offices to identify and address potential OCI concerns before sponsored activities begin.
Learn More
Organizational Conflicts of Interest (OCI) Website
Need Assistance?
Researchers with questions regarding University or sponsor disclosure requirements are encouraged to contact ORS before engaging in a new outside activity, accepting an appointment or affiliation, submitting a proposal, or participating in an activity that may require disclosure.
Early consultation helps ensure compliance while supporting productive research and collaboration.