Researcher Disclosure Requirements

Researchers may need to make disclosures that relate to their U.S. and international activities in the following places:

This annual disclosure form is filed in Rascal. Disclosure requirements include, among other things, any payments and sponsored travel from:

  • U.S. and non-U.S. companies, foundations, and professional societies
  • non-U.S. institutions of higher education
  • non-U.S. government entities

For questions about Annual Financial Interest Reports please contact:

Michael Klein, JD

Director of Research Compliance
Office of Research Compliance and Training
212-851-2986
mak67@columbia.edu

“Other Support” or “Current and Pending Support” section of funding application. This section of the application must include any current or pending financial resources, whether Federal, non-Federal, commercial or institutional, available in direct support of an individual's research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards. Training awards, prizes, or gifts do not need to be included. Other support may include support that may be provided to you at or by a non-U.S. institution. This information must be updated in your progress reports. 

Please note that this is an active area of rulemaking by sponsoring agencies. This website will be updated and the Columbia community notified when sponsoring agencies issue new rules, guidance or clarifications regarding disclosure requirements for “other support". For agency specific guidance, see Disclosure Policy and Guidance below. 

Biosketch. The Biosketch should include any appointments at any institutions that are relevant to the application, including adjunct or honorary appointments. For agency specific guidance, see Disclosure Policy and Guidance below. 

Foreign Component (NIH only). If any portion of an NIH-funded or proposed project is being conducted outside the U.S., you must check “Yes” to the application question of “Does this project involve activities outside of the United States or partnerships with international collaborators?”   

  • Use Field 6 of the Research and Related (R&R) Other Project Information form to indicate whether your project involves activities outside the U.S. or partnerships with international collaborators. If “YES” then a “Foreign Justification” attachment must be provided in Field 12, Other Attachments. See instructions.

Facilities and Special Resources (NIH only). This section of an NIH application is where you should disclose if you are going to utilize special resources, space, instruments, reagents, or other resources, including those from U.S. and non-U.S. collaborators and institutions.

Certain grant-related activities must be reported in section G.9 of the RPPR if they involve a foreign component, defined as significant scientific activity that was performed outside of the United States, either by the grantee or by a researcher employed by a foreign organization, whether or not grant funds were expended. The following grant-related activities are significant and must be reported:

  • involvement of human subjects or research with live vertebrate animals;
  • extensive foreign travel by grantee project staff to collect data, or conduct surveys or sampling activities; or
  • any grantee activity that may have an impact on U.S. foreign policy.

Examples of other grant-related activities that may be significant are:

  • collaborations with investigators at a foreign site anticipated to result in co-authorship;
  • use of facilities or instrumentation at a foreign site; or
  • receipt of financial support or resources from a foreign entity.

Foreign travel for consultation does not meet the definition of foreign component. See Section G of RPPR FAQs.

For questions about Funding Applications and Progress Reports, contact your SPA project officer

U.S. Department of Energy (DOE) contracts require disclosure of investigators’ affiliations, if any, with “foreign government-sponsored talent recruitment programs” in certain countries. This requirement applies to subcontracts to the University that involve work by an investigator at a DOE or contractor facility.

Definition of “Foreign government-sponsored talent recruitment program” 

In general, such programs include any foreign-state-sponsored attempt to acquire U.S. scientific-funded research or technology through government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the U.S. These recruitment programs are often part of broader whole-of-government strategies to reduce costs associated with basic research while focusing investment on military development or dominance in emerging technology sectors.

Distinguishing features of a foreign government talent recruitment program covered by this Order include:

  1. Compensation provided by the foreign state to the targeted individual in exchange for the individual transferring their knowledge and expertise to the foreign country. The compensation can take several forms, such as cash, research funding, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or other consideration.
  2. Recruitment in this context refers to the foreign-state-sponsor’s active engagement in attracting the targeted individual to join the foreign-sponsored program and transfer their knowledge and expertise to the foreign state. The targeted individual may be employed and located in the U.S., or in the foreign state. Recruitment would not necessarily include any invitation for engagement extended by the foreign state, for example, an invitation to attend or present work at an international conference.
  3. Many, but not all, programs aim to incentivize the targeted individual to physically relocate to the foreign state. Of particular concern are those programs that allow for continued employment at U.S. research facilities or receipt of DOE research funds while concurrently receiving compensation from the foreign state.

A copy of the DOE Order implementing this requirement can be reviewed at the following site: https://www.directives.doe.gov/directives-documents/400-series/0486-1-border/@@images/file.

For questions about the DOE Disclosure Requirement, contact your SPA project officer.