Disclosure Requirements

Reducing undue influence is a fundamental aspect of research security and integrity. In recent years, the U.S. Government has expressed concern regarding increased foreign influence in research at academic institutions. These are some of the identified areas of concern:  

  • Diversion of intellectual property to foreign entities  
  • Failure of researchers to disclose research resources and support made available to them by external entities, including foreign entities  
  • Disclosing confidential grant application information by peer reviewers to third parties  

The U.S. federal government emphasizes disclosing outside activities and interests, including relationships or affiliation with foreign entities, and research support from those entities. 

Outside Activities and Interests 

All researchers must disclose all applicable outside activities, relationships, or interests with an external entity (e.g., company, organization, etc.) such as compensation, company ownership, foreign academic appointments, foreign research support, and travel. 

See the following webpages for more information: 

Current and Pending Support 

Most federal sponsors require disclosure of Other Support or Current & Pending Support in grant and contract applications. Information may be disclosed in a proposal, during the Just-In-Time process, in a progress report, or at any time deemed appropriate by the sponsor. 

While Texas State strongly supports research collaborations with external entities, including non-U.S. entities, our researchers must carefully, completely, and accurately report these external relationships in a timely manner. Please refer to the following university policies and Significant Financial Interest (SFI) webpage to assist you with these collaborations, which will also guide what is allowable and adheres to federal and state regulations:   

Disclosure and transparency of potential conflicts of interest and/or commitment are essential to avoiding the appearance of undue influence. Texas State (Institutional) and federal & funding agency disclosure requirements are described below.  

Expand FAQ List

  • Researchers must disclose external financial interests and professional activities related to their institutional responsibilities on the annual Significant Financial Interest Disclosure in  Kuali. Outside employment and activities must comply with UPPS No. 04.04.06 and require written approval before outside employment may begin.   

    Engagement in external professional activities must be consistent with university policies (UPPS No.  02.02.07 & 08) and procedures and must align with sponsor requirements, and federal and state regulations.   

     Visit Texas State’s Significant Financial Interest (SFI) webpage for information conflicts of interest related policy, disclosure procedures, specific sponsor requirements and guidance.  

    Foreign Talent Recruitment Programs  

    Texas State researchers are required to disclose via Kuali any involvement in a Foreign Talent Recruitment Program. Please review Texas State’s Guidance on Foreign Talent Recruitment Programs.   

     State regulations prohibit Texas State faculty, staff, trainees, students, and visitors who engage in or propose to engage in research and development projects or who contribute in any way to the scientific development or execution of research and development projects from involvement in Malign Foreign Talent Recruitment Programs (MFTRP). 

  • Disclosure and transparency, especially with respect to relationships with foreign entities, are critical to complying with research security requirements and to avoiding the appearance of undue influence. Due to increased scrutiny of foreign engagements by the federal government, researchers must be vigilant in ensuring that they have complied with all requirements to disclose funding, appointments, relationships, and other necessary information on federal submissions, including in sponsored funding applications, Just-In-Time submissions, and progress reports.  

    Common Forms 

     Biographical Sketch & Other Support: The National Science and Technology Council (NSTC) Research Security Subcommittee has finalized the proposed common forms for the Biographical Sketch and Other Support, pursuant to the request of NSPM-33.  

     

    Agency Specific Guidance  

    National Science Foundation: The use of the common forms was effective May 20, 2024 pursuant to NSF 24-1 PAPPG.  

    National Institutes of Health: Current Guidance on NIH disclosures is available. NIH also provides FAQs for Other Support and FAQs for Biosketches. The common forms are expected to be effective for NIH applications and progress reports on May 25, 2025. Additional information on this change is available from NIH Office of Extramural Research.  

    National Aeronautics and Space Administration: NASA released a revised edition of the NASA Grant and Cooperative Agreement Manual (GCAM) on October 1, 2024. Additional information on this change is available from Grants Policy and Compliance Team - NASA.  

    Additional Resources for Other Support are available on the Division of Research’s Forms, Resources, and Policies webpage. 

    Foreign Contracts/Agreements  

    NIH requires the submission of copies of contracts/agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. The contracts/agreements must be included with the Other Support submission. If the contracts/agreements are not in English, translated copies must be provided.  

    Foreign Talent Recruitment Programs  

    MFTRP Certifications: Pursuant to the requirements of the CHIPS & Science Act, Texas State researchers have begun to see the implementation of restrictions on participation in Malign Foreign Talent Recruitment Programs (MFTRP) for federally funded researchers. Key personnel will need to attest to not participating in such programs at the time of proposal and on an annual basis (if awarded). This certification requirement went into effect on NSF proposals as of May 20, 2024.  

    Foreign Talent Recruitment Program: Section 223 of the FY21 National Defense Authorization Act requires covered individuals to disclose to sponsoring agencies if they are party to a foreign talent recruitment program. The Office of Science and Technology Policy has released the   Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs.  

    Agency Risk Assessments  

    As requested in NSPM-33, federal funding agencies are beginning to implement research security risk assessments, which are conducted on individual research proposals independent of the merit review process. The results of such an assessment may jeopardize the awarding of funds and may require the implementation of a research security plan and other terms and conditions to safeguard research as a condition of the award.  

    • As of August 2024, the following agencies have publicly released risk assessments for their fundamental research submissions:  
    • Digital Persistent Identifiers  

    Government agencies have begun to require the use of digital persistent identifiers (DPI) for proposal submissions. This may require investigators to register with an ORCID ID and submit via SciENcv.