Important new policy guidance from federal research funding agencies, including the NSF and NIH, now mandates broader disclosure of “Other Research” support provided to Principal Investigators and other researchers. The funding agencies now require that researchers with active or pending federal research disclose all resources made available, or expected, in support of all the researchers’ research efforts – even if the support does not relate to the specific research being funded by the agency, and regardless of whether the support involves a cash funding or is “in-kind” support. As just one example, researchers will need to report any students or postdocs providing support for their research efforts if the individual is funded through external funding.
Please carefully read the details below to understand how these requirements will apply to you, your federal research proposals, and any active or pending government-funded research you may have. You will also find details on how you can obtain additional information about these requirements.
Rensselaer understands that these disclosure requirements will increase the burdens on our faculty and other researchers. However, going forward, the U.S. federal agencies will be requiring researchers to personally certify the accuracy and completeness of the disclosures. The agencies have become aggressive in enforcing disclosure requirements, and have even taken steps to ban researchers from federal grants for non-compliance. In some cases, federal criminal charges have been brought against faculty for knowing non-disclosure. It is therefore critical that all faculty involved with federal research understand and comply with these rules. We want to help you do just that to ensure that your research is not disrupted.
U.S. law now mandates that researchers funded by federal grants more broadly disclose “Other Support” for research efforts, including disclosure of all resources made available, or expected, in support of all of the researcher’s research efforts. The disclosures are required:
- regardless of whether the source of the research support is foreign or domestic;
- regardless of whether the resource is made available through Rensselaer or directly to an individual researcher;
- regardless of whether the resource has identifiable monetary value, e.g., including “in-kind contributions” such as office or lab space, equipment, supplies, high-value materials, visiting scholars, seconded or other temporary external researcher, or students who are fully or partially funded through external sources, and;
- regardless whether the Other Research supported is related to the researcher’s applied-for (pending) or active federal grant.
In addition, researchers:
- must disclose “all positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments.” This includes “titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).”
- must explicitly indicate the intended use of a “foreign component” in any application for a federally funded research award, and must request prior approval from the government funding agency before adding a “foreign component” to an existing federally funded research award (see, for example, NIH's Grants Policy Statement Section 8.1.2.10). The Foreign Award and Component Tracking System (FACTS) Overview defines a “foreign component” as “performance of 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". The NIH states that such significant grant-related activity may include “collaborations with investigators at a foreign site anticipated to result in co-authorship; use of facilities or instrumentation at a foreign site; or receipt of financial support or resources from a foreign entity.”
The agencies are requiring that researchers update these disclosures on any active awards, and will require researchers to certify that the disclosures are current, accurate, and complete.
The following listing is intended to assist Rensselaer researchers identify the types of resources a federal funding agency requires to be disclosed as Other Support and/or in-kind contribution:
Appointments/Positions. Researchers must disclose “all positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments.” This includes “titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).”
Financial support for research, including, but not limited to, foreign or domestic support, whether employment, contractual, or otherwise, including private and public sources of funding or income. This support could be provided as an award, cash funding, scholarship, sponsored research funding, travel funding, honorarium, or university-directed funding, or honorarium. This would also include any start-up funds provided by an entity other than RPI.
Foreign Programs, including, but not limited to selection to or involvement in a foreign government-sponsored “talents” recruitment program or any other similar-type program organized, managed, or funded by a foreign government for recruitment.
Financial support for laboratory personnel. Disclosure is to include employees, post-docs, students, and visiting scholars who are involved in the research endeavors and who are paid a salary or otherwise supported, even if only partially, by a government, non-Rensselaer institution, private company, or some other entity. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the researcher may be required to provide reasonable estimates.
In-kind contributions, e.g., office/laboratory space, equipment, supplies, and other “high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).” This includes third party commitments to time for research collaborations that benefit the investigator's research endeavors, regardless of whether the collaboration is related to the research grant being applied for or funded by a given federal agency. Note that an item or service given with the expectation of an associated time commitment is an in‐kind contribution requiring disclosure.
Outside Activities such as consulting where the researcher will be conducting research as part of the consulting activities. Private equity financing (e.g., in support of the SBIR/STTR program) and honoraria in support of an individual’s research endeavors must be included.
Instructions for making and updating disclosures to NSF and NIH can be found here: NIH Notice, effective May 25, 2021 (NOT-OD-21-073); NSF Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 2 2 ‐1) effective October 4, 2021. Other federal agencies, such as Department of Energy and NASA, are imposing the same requirements; please contact the Rensselaer Office of Research Administration and Finance (RAF) for help in making disclosures to these other agencies.
The agencies are mandating that copies of contracts, grants, or other agreements specific to foreign funding, appointments, and/or employment with a foreign institution must be submitted to the agency. If they are not in English, translated versions must be provided. Faculty and researchers should work with RAF and/or Rensselaer General Counsel regarding disclosure of any such documents.
To assist the research community in compliance with the requirements, the Rensselaer Office of General Counsel (518-276-3777) and Office of Research Administration and Finance (RAF), rafsupport@rpi.edu are available to answer questions and assist with individual situations.
