Disclosure of Other Support

Purpose:

This policy is created to:

• Comply with the provisions of federal law, the Office of Management and Budget’s regulations, including 2 CFR 200, the Uniform Guidance, and other relevant sponsor requirements.
• Establish expectations with faculty and staff about other support information.
• Promote the best possible alignment between faculty and staff activity and funding sources and, in so doing, enhance work at the university.

The University of Maryland Baltimore (UMB) recognizes the importance of providing good stewardship of institutional and extramural funds. The university’s stewardship responsibilities include complying with federal requirements for disclosing other support (also known as current and pending support). Other support may include active, pending, or previous sources of support for a faculty member’s research and other sponsored activities.

Sponsoring agencies request information on other support as part of the proposal process, often before the issuance of an award, or as part of the annual progress report process. Sponsors use the information to ensure that scientific, budgetary, or commitment overlap does not occur. The requirement for disclosure is in place to demonstrate that:

• The funding agency is not providing funds for work that is already supported by another source;
• The faculty member has sufficient time available to conduct the work for which funds are being requested; and
• Only funds necessary to conduct the approved project are included in the award.

Additionally, there is interest in the federal government on undue foreign influence on the U.S. research enterprise, and federal sponsors have emphasized that appropriate disclosures must be made as part of other support documents.

Policy:

1. It is the policy of UMB that all researchers who engage in sponsored projects will comply with federal law, university policies, and sponsoring agency requirements regarding the provision of information on other support documents.
2. UMB requires that every disclosure to an external funding agency of a researcher’s active, pending, or previous sources of support for research and other sponsored activities be current, accurate, and complete to the best of the researcher’s knowledge.
   1. This requirement applies regardless of the source of support, whether or not UMB is the recipient of the support. For example, if a researcher with a joint or affiliate appointment is listed as an investigator on an award to another institution, that must be disclosed in other support.
   2. The requirement for disclosure applies at the time of proposal submission, before the award of support, as part of the annual progress report, and at any subsequent time the agency determines appropriate during the term of the award.
3. It is the investigator’s responsibility to ensure the accuracy of other support documents for the project team, in accordance with the application guidelines or the sponsor’s instructions. The investigator is required to take training on disclosures provided by Sponsored Programs Administration.
4. False, fictitious, or fraudulent statements or claims (including intentional omissions) in violation of this policy may result in university and sponsor administrative, civil, or criminal penalties. 

Scope:

All faculty and staff who engage in or propose to engage in sponsored projects; all federal and nonfederal sponsored projects

Roles and Responsibilities:

The Principal Investigator/Project Director, in collaboration with their department administration, is responsible for compiling complete and accurate other support documentation for each key person (as defined by the sponsor), including subrecipient investigators.

Department administrative staff should assist with reports of current and pending awards at UMB and support the Principal Investigator/Project Director in obtaining other support from the project team key persons.

Sponsored Programs Administration will respond to general questions about sponsor requirements and instructions.  Sponsored Programs Administration will submit other support documents to the sponsor in accordance with sponsor instructions.  Sponsored Programs Administration will maintain the required investigator training presentation.