Disclosures to Funding Agencies

The National Institutes of Health (NIH), the National Science Foundation (NSF), and the Department of Defense (DOD) have all recently issued new policies or further guidance clarifying investigators’ obligations to disclose all other support they receive for their research activities. While the requirements vary slightly among the different agencies, all agencies require disclosure not just of research funding received through the University, but also of other funding and affiliations investigators may have in their individual capacities.

NSF recently updated its disclosure guidance.

Previous guidance from NIH in NIH Notice NOT-OD-19-114, “Reminders of NIH Policies on Other Support and on Policies Related to Financial Conflicts of Interest and Foreign Components,” July 10, 2019, stated that investigators must disclose:

• All paid or unpaid scientific or titled academic, professional or institutional, full time, part-time, or voluntary appointments (including adjunct, visiting or honorary) at all foreign and domestic entities.
• Paid or unpaid collaborations with foreign or domestic researchers that directly benefit the project (for example, collaborations that produce data that will be used in the research or resulting publications).
• All current projects and activities undertaken by the PI or senior/key personnel that involve paid or in-kind support from domestic or foreign entities in the form of laboratory personnel, lab space, scientific materials or instrumentation (e.g., biologics, chemical, model systems, data sets, technology, etc.)
• All resources and other support from any source for other paid or unpaid individuals who contribute to the scientific development or execution of the project. This would include any support provided by other institutions/governments to visiting scientists or volunteers who are participating in the research while at Georgetown (even if such visiting scientists or volunteers are not paid by Georgetown).
• Any participation in foreign “talent” or similar programs.

More recently, NIH Notice NOT-OD-21-110, effective for grant applications, Just in Time (JIT) information, or Research Performance Progress Reports (RPPRs) submitted on or after January 25, 2022, NIH has revised the Biosketch format (and included separate formats for non-fellowship and fellowship applications) and added new requirements related to Other Support.

The following information must be disclosed by the principal investigator and all key personnel in their biosketches:

• All paid or unpaid scientific or titled academic, professional or institutional, full time, part-time, or voluntary appointments (including adjunct, visiting or honorary) at all foreign and domestic entities. If the appointment is with a foreign entity, an English-language version of the investigator’s agreement with the foreign entity must be provided at the Just In Time (JIT) stage as part of the Other Support submission.

The principal investigator and all key personnel must submit a signed Other Support page that includes the following information related to all of the investigator’s research activities:

• Consulting engagements that involve a research component.
• Paid or unpaid collaborations with foreign or domestic researchers that directly benefit the project (for example, collaborations that produce data that will be used in the project or resulting publications).
• All current projects and activities undertaken by the PI or senior/key personnel that involve paid or in-kind support from domestic or foreign entities in the form of laboratory personnel, lab space, scientific materials or instrumentation (e.g., biologics, chemical, model systems, technology, etc.)
• All resources and other support from any source for other paid or unpaid individuals who contribute to the scientific development or execution of the project. This would include any support provided by other institutions/governments to visiting scientists who are participating in the project while at Georgetown (even if such scientists are not paid by Georgetown).

• Any participation in foreign “talent” or similar programs.

In-Kind Contributions

• In-kind is defined as contributions such as office or laboratory space, equipment, chemicals, supplies, technology or employees, students, visitors, or volunteers in the lab that are paid by an outside organization.
• In-kind contributions that are intended to be used on the project being proposed should be disclosed in the Facilities and Other Resources or Equipment section.

In addition, any “foreign components” of federally funded research should be fully disclosed in proposals, progress reports, and final technical reports. NIH defines a foreign component as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended” (emphasis added). This includes collaborations with investigators at a foreign institution anticipated to result in co-authorship (even if no funding is provided to the other institution); use of facilities or instrumentation at a foreign site; or receipt of financial support or resources from a foreign entity.

Staff in the sponsored research offices (Research Development Services, melissa.layman@georgetown.edu / Office of Sponsored Research, osrapps@georgetown.edu for the Medical Center and the Office of Research Services, for the Office of Research Services, Hector Tiongson for NSF proposals at rht3@georgetown.edu  and Blair Ribiero for all other federal agencies at br561@georgetown.edu . Main Campus and the Law Center) will remind faculty of the relevant disclosure requirements during the proposal submission and the annual progress report processes and are available to answer any questions, but investigators are ultimately responsible for ensuring that their disclosures are complete. Failure to fully disclose all other support or foreign components could subject both faculty and the University to numerous consequences from funding agencies, including suspension or termination of awards, withholding of future awards, and federal prosecution.