Disclosures Requirements

Ensuring that researchers provide thorough and transparent disclosures of international collaborations (scholarly presentations, publishing written materials regarding scientific information not otherwise controlled, participation in international conferences/exchanges, writing a recommendation letter for a foreign student, etc) rely heavily on submitting accurate, complete, and consistent disclosure and helps prevent potential conflicts of interest, ensures compliance with regulations, and fosters trust within the research community.

Federal agencies are actively investigating discrepancies and failures to disclose among grantees. In some cases, these investigations have led to criminal and civil charges, as well as employment terminations. These discrepancies typically come to light when federal agencies compare information from publications, conflict of interest statements, conflict of commitment disclosures, grant applications, and annual progress reports.

Best Practices

• Understand your disclosure requirements as a researcher and UM employee
• Disclose any new or changes to existing activities/relationships within 30 days
• Maintain a set of up-to-date records of your activities, payments, and relationships to refer to when completing these disclosure requests
  • Maintain an updated CV
  • The types of information you need to maintain and track include appointment affiliations, research collaborations, laboratory visitors (scholars and researchers), in-kind resources & other support, outside financial interests and relationships.
• Understand the disclosure requirements of the agency to which you are submitting a funding proposal:
  • NIH’s Requirements for Disclosure of Other Support, Foreign Components and Conflicts of Interest
  • NIH’s Foreign Interference page
  • NSF’s Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support
  • NSF's Certification for Malign Foreign Talent Recruitment Programs (MFTRPs) - VIDEO
  • DoE’s Current and Pending Support Disclosure Guidance
• UM’s Research Administration Preparing Proposal to facilitate and expedite the processing of your externally sponsored applications