/Office for Research and Innovation
Research Security

 

Federal Sponsor Disclosure Requirements

Federal sponsors require investigators to disclose information regarding research support, professional appointments and affiliations, collaborations, foreign activities, financial interests, and other information necessary to evaluate eligibility, transparency, research integrity, and research security.

Sponsor disclosure requirements 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 submission, award negotiation, project performance, and closeout.

Understanding Sponsor Research Security Requirements

For sponsor-specific research security guidance, including proposal development, award management, post-award responsibilities, and activities that may require institutional review, visit the Federal Sponsor Research Security Guidance page.

General Sponsor Disclosure Requirements

Depending on the sponsor, investigators may be required to disclose:

  • Biographical Sketches (Biosketches)
  • Current and Pending (Other) Support
  • Available Resources
  • Foreign Components
  • International Collaborations and Affiliations
  • In-Kind Contributions and Other Resources
  • Senior/Key Personnel appointments and affiliations
  • Conflict of Interest and Conflict of Commitment information, when required
  • Participation in Foreign Talent Recruitment Programs or certifications regarding Malign Foreign Talent Recruitment Programs
  • Other sponsor-specific disclosures

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.

Research Security Considerations

Federal agencies continue to strengthen research security requirements related to transparency, foreign activities, appointments, affiliations, research support, and participation in Foreign Talent Recruitment Programs.

Investigators should ensure that:

  • University disclosures remain current.
  • Sponsor disclosures are complete and consistent.
  • International collaborations are disclosed when required.
  • Changes in outside activities are reported promptly.

 

Sponsor-Specific Guidance

Other Federal Sponsors

Many federal agencies now implement government-wide research security requirements established through NSPM-33, the CHIPS and Science Act, and the Common Forms Initiative. Although agency-specific disclosure requirements vary, investigators should review the applicable Notice of Funding Opportunity (NOFO), program announcement, or award terms and conditions for sponsor-specific instructions.

Investigators applying to agencies such as the Department of Agriculture (USDA), Department of Commerce (including NIST and NOAA), Department of Homeland Security (DHS), Department of Transportation (DOT), Environmental Protection Agency (EPA), Department of Justice (DOJ), Department of the Interior (DOI), and other federal sponsors should contact OSP or ORS whenever questions arise regarding disclosure requirements.

 Related University 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.