University and Sponsor 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.
The Disclosure Program supports responsible research by promoting transparency regarding external interests, professional activities, appointments, affiliations, research support, and other reportable relationships. These disclosures help the University identify and appropriately manage potential conflicts of interest and commitment, satisfy sponsor requirements, and support the integrity and security of the research enterprise.
Depending on an individual's University role, funding sources, and research activities, multiple disclosure requirements may apply. This page provides an overview of the University's disclosure programs and directs researchers to detailed guidance on University disclosures, sponsor disclosure requirements, conflicts of interest, 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 serves as the foundation for the institutional review of external interests and commitments. Information reported through the Disclosure Profile supports the University's evaluation of:
- Conflicts of Interest (COI)
- Conflicts of Commitment (COC)
- Foreign Talent Recruitment Programs (FTRPs) and Malign Foreign Talent Recruitment Program (MFTRP) restrictions, when applicable
- Sponsor-specific disclosure requirements
- Other research security and institutional compliance reviews, 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.
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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.
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Federal Sponsor Disclosure Requirements
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.
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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.