Ensuring Transparency and Compliance in Federally Funded Research
The federal government requires covered individuals to fully disclose information that could reveal potential conflicts of interest or commitment with federally funded research. Disclosure is critical for assessing an individual’s ability to carry out proposed research and for identifying potential overlap or duplication in projects.
Federal agencies have created consistent disclosure requirements and common forms, including the Biographical Sketch and Current and Pending (Other) Support information. These forms are used to evaluate:
- The capacity of the researcher to execute proposed work
- Any scientific or budgetary overlap/duplication
- Potential conflicts of commitment or competing obligations
NSPM-33 Requirements for Disclosure
Current and Pending (Other) Support information:
NSPM-33 requires disclosure of:
(a) All resources made available, or expected to be made available, to an individual in support of their R&D efforts, regardless of:
- Whether the source is foreign or domestic
- Whether the resource is provided through the organization applying for the award or directly to the individual
- Whether the resource has monetary value
(b) Includes in-kind contributions requiring a commitment of time and directly supporting research, such as:
- Office or laboratory space
- Equipment or supplies
- Employees or students
Other Support for Researchers Includes:
- All resources made available in support of all professional R&D efforts
- Support provided directly to the individual, not just through the institution
- Funding or in-kind support from domestic and foreign entities
- Contributions with or without monetary value (e.g., space, equipment, personnel)
The table NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support provides helpful guidance on:
- Types of activities to report
- Where and when to report them in applications
- Updates required throughout the award lifecycle
- Activities that do not need to be reported
Federal Agency-Specific Disclosure Requirements
Beyond NSPM-33, individual federal agencies may have additional disclosure requirements. Researchers are strongly encouraged to review grant proposal instructions for each agency before submission.
Key Agencies: