Making Disclosures to Federal Funders

Agencies use other support information to assess:

• Potential scientific and budgetary overlap with the proposed research
• Investigator and staff over commitment (effort greater than 100%)
• Security and integrity concerns of publicly funded U.S. research

• Undue influence of U.S. academic institutions by foreign entities
• Talents Programs
  • Theft of intellectual property
  • “Double dipping” by applying for and accepting federal funding for work already funded elsewhere
  • Providing support to restricted parties (many Chinese universities are affiliated with the PLA)
  • U.S. universities may not be monitoring when faculty accept appointments abroad

The recent federal concern for research security has resulted in increased scrutiny and disclosure requirements.

• Outside Appointments
  • Even if honorary and unpaid
• Subsidized Travel
  • From a foreign entity
• Other sources of support
  • Support through grants to Penn
  • Support to individuals related to the research that is not through Penn (i.e., extramural activities) even when it is during summer months for those with 9-month appointments
  • International collaborations, even when no money is exchanged (in-kind support)
  • Visiting scholars/students working on the project where funding is from a foreign institution/government (e.g., supported by home institution, funded by China scholarship Council, etc.)

The following table may be useful to help determine what should be disclosed to federal sponsors:

Disclosure Requirements for Common Penn Funders

• New/clarified federal agency requirements for disclosure
  • What needs to be disclosed is not standard across agencies
  • When information needs to be disclosed is not standard across agencies

• Publications or presentations
  • Cite only the support that has contributed to the specific research being reported
  • Be specific about what each funding source supported
• Exchange of materials
  • Utilize Material Transfer Agreements in Penn’s Research Inventory System (RIS) for incoming and outgoing material
• Activities and engagements outside of Penn employment
  • Review any documents/contracts carefully for terms or descriptions that accurately reflect your engagement
  • Be sure that contracts in a foreign language are appropriately translated
  • Penn is happy to review any such agreements to ensure they align with Penn policies as well as identify potential concerns

In-Person Training:

If you would like to schedule an in-person meeting to discuss these federal requirements and related issues, please contact expctrl@lists.upenn.edu.

Online Training Modules in Knowledge Link: