Pre- and Post-Award Disclosures Relating to the Biographical Sketch and Other Support
The National Institutes of Health (NIH) and the National Science Foundation (NSF) have disclosure requirements for activities and commitments that may affect performance on sponsored projects. Investigators must address potential scientific, budgetary, or commitment overlap with proposed activities at the proposal stage in the NSF Current & Pending Support, while these commitments are included in the NIH Other Support document prior to award. Additionally, applicants to both agencies must disclose all resources made available in support of their research, regardless of monetary value or if the support is supplied directly or through the institution.
Fortunately, both agencies have published guidance on their disclosure requirements, including timing (at time of proposal, prior to award, or post-award); the nature of the information that must be disclosed (consulting, travel, awards, etc.); and where the information should be reported (biographical sketches, other support documents; project reports, etc.). Their tables also include types of information that do not require disclosure, such as teaching commitments, institutional salary, and organizational start-up packages.
Investigators must divulge all sources of support and potential project overlap consistent with the sponsor’s requirements. Failure to disclose can lead to a loss of funding, and in some instances, prosecution by the sponsoring agency. Best practices in sponsor disclosures include:
- Report all sources of support consistent with the funding agency’s requirements.
- Be thorough and complete in accounting for all forms of research support, whether financial, in-kind, or other sources of support.
- Update disclosures annually or when new reportable support is obtained.
- Use sponsor specific forms, templates, or formatting to complete your disclosures.
For specific NIH and NSF disclosure requirements, refer to:
Blog post by Tricia Callahan, Senior Research Education and Information Officer, Office of Sponsored Programs