Making Disclosures to Federal Funders

Federal agencies use the information provided in biosketches and other support documentation to assess the capacity of the individual to carry out the proposed research as well as to help assess potential overlap/duplication with the project being proposed.

Reporting Other Support and Outside Activities to Federal Sponsors of Research

Other Support

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

Recent Federal Concern for Research Security

  • 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.

Agencies generally want to know about:

  • 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.)

Different agencies have different requirements for how to disclose

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
Click here for current agency guidance on what/where/when to disclose

General Good Practices

  • 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
  • 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

Helpful Links

NIH guidance (link to FAQ at bottom of page) NSF guidance Penn Vice Provost for Research: Information on internatioanl engagements Penn Guidance on international travel and hosting foreign visitors

Training Opportunities

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:

Reporting Other Support and Outside Activities to Federal Sponsors of Research Restricted Party Screening at Penn Export Compliance for Researchers
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