University and Sponsor Disclosure Requirements
Stony Brook University is committed to the principles of academic freedom, open scientific inquiry, and responsible stewardship of research. Faculty, staff, and students are encouraged to engage in external professional activities that advance research, scholarship, innovation, education, and public service.
Transparency is fundamental to maintaining research integrity, research security, and public trust. University policies, federal regulations, and sponsor requirements require researchers to disclose certain external interests, professional activities, appointments, affiliations, research support, and participation in certain foreign talent recruitment programs. These disclosures enable the University to identify and appropriately manage potential conflicts of interest and commitment, comply with sponsor requirements, and protect the integrity and security of the research enterprise.
Depending on their University role, funding sources, and research activities, individuals may be subject to multiple disclosure requirements. This page provides an overview of those requirements and directs researchers to additional guidance.
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Research Disclosure Requirements
Researchers may be required to disclose information in several different contexts.
| Disclosure Requirement | Purpose |
|---|---|
| Disclosure of External Interests & Commitments | University disclosure of external financial interests, outside professional activities, appointments, affiliations, and other reportable relationships. |
| Conflict of Interest (COI) | Financial interests or relationships that may affect—or appear to affect—the objectivity of research or other institutional responsibilities. |
| Conflict of Commitment (COC) | Outside professional activities, appointments, affiliations, or obligations that may interfere with a researcher's ability to fulfill University responsibilities or sponsor commitments. |
| Foreign Talent Recruitment Programs (FTRPs/MFTRPs) | Disclosure of participation in Foreign Talent Recruitment Programs and compliance with federal restrictions on participation in Malign Foreign Talent Recruitment Programs. |
| Sponsor Disclosure Requirements | Sponsor-specific disclosures such as Biosketches, Current & Pending (Other) Support, Available Resources, Foreign Components, and other agency-required information. |
| Organizational Conflicts of Interest (OCI) | Institutional conflicts that may affect the University's objectivity in conducting sponsored activities. |
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. ORS uses these disclosures to:
- Identify and evaluate potential Conflicts of Interest (COI);
- Identify potential Conflicts of Commitment (COC);
- Assess participation in Foreign Talent Recruitment Programs (FTRPs) and compliance with restrictions on Malign Foreign Talent Recruitment Programs (MFTRPs), when applicable;
- Assist investigators in meeting sponsor-specific disclosure requirements;
- Coordinate additional review with other University offices, when appropriate; and
- Develop management measures when necessary to support compliance, research integrity, and research security.
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 disclose information beyond the University's institutional disclosure requirements. Sponsor disclosures are separate from—and in addition to—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:
- 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, when applicable
- Other sponsor-specific disclosure requirements
Federal sponsors, including the National Institutes of Health (NIH), National Science Foundation (NSF), Department of Energy (DOE), Department of Defense (DoD), and National Aeronautics and Space Administration (NASA), have established agency-specific disclosure requirements. Although these requirements vary, they are intended to promote transparency, identify potential conflicts, 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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Biosketch, Current & Pending and Other Support Website
- Department of Defense
- Department of Energy
- National Aeronautics & Space Administration
- National Institutes of Health
Organizational Conflict of Interest
Unlike a Conflict of Interest (COI), which involves an individual's financial interests or relationships, an Organizational Conflict of Interest (OCI) involves circumstances in which the University's institutional relationships, financial interests, or other activities could impair—or appear to impair—its objectivity in performing sponsored work.
Certain federal sponsors require institutions—not individual investigators—to identify, evaluate, disclose, and, when necessary, manage Organizational Conflicts of Interest. These requirements are intended to ensure that research, procurement, and other sponsored activities are conducted objectively and without institutional bias.
Examples of federal requirements include:
- Federal Acquisition Regulation (FAR) Subpart 9.5
- Uniform Guidance (2 CFR §200.318(c)(2))
- Agency-specific OCI requirements established by sponsors such as the Department of Defense (DoD), ARPA-H, and other federal agencies
Organizational Conflict of Interest considerations may arise during proposal preparation, contract negotiations, subaward arrangements, technology commercialization activities, or other sponsored research relationships. Researchers, department chairs, deans, and administrative offices are encouraged to consult ORS whenever a proposed activity may create an actual or potential Organizational Conflict of Interest.
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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.