Sponsor Disclosure Requirements/Foreign Support
Federal agency requirements and forms have recently been clarified or revised with a goal towards greater transparency for research activities and sources of support. It is important that each individual who has information submitted on their behalf review updated instructions and verify information. The resources on this page and linked sponsor-specific pages have been compiled to assist faculty and staff in navigating various disclosure requirements related to support, resources and time commitments. Federal agencies have expanded the definition of research support to include all paid or in-kind resources supporting a PI’s research program, whether the support is made through Dartmouth or provided directly to the PI.
Federal and other granting agencies use Other Support or Current and Pending Support to:
Assure researchers have time to conduct the proposed project, avoid instances where individual's time exceeds 100% (commitment overlap);
Identify instances where the project aims have already been funded by another sponsor for same time frame (scientific overlap);
Identifying instances where funds requested in the project have already been funded (budgetary overlap);
In recent years, there have been concerns raised about foreign influence and research security risk in relation to certain activities such as nondisclosure of foreign gifts and contracts and participation in foreign government-sponsored talent programs. In addition, sponsors may consider that foreign resources meet the definition of a foreign component and may have specific restrictions or requirements for appropriate prior approval.
Conflict of Interest and Conflict of Commitment
Dartmouth has established a comprehensive policy addressing conflicts of interest meeting all requirements of Federal Law and Regulation. https://policies.dartmouth.edu/policy/conflict-interest-policy
Accordingly, researchers must disclose all outside financial interests that are related to their institutional responsibilities above the value of $ 5000 annually. This includes salary, consulting income, payment for speaking engagements, and in certain cases reimbursement for travel expenses. The disclosure requirement includes all such payments from foreign sources. Dartmouth reviews research projects for the presence of conflicts of interest and manages conflicts when required and doable
In addition, researchers must take care to ensure that any outside commitments of time and effort do not conflict with Dartmouth or funding agency policies.
OSP Presentations May/June 2021
CITI Undue Foreign Influence: Risks and Mitigations Online Course
Explore key ethical, export, security, intellectual property, and transparency requirements related to international engagement. (contact OSP if questions on how to access CITI)
The requirements for disclosing information differ between agencies
The following table may assist in the determination of what should be disclosed to federal sponsors. As agencies have evolving and more detailed requirements, please refer to specific agency guidance and/or contact the Office of Sponsored Projects with questions:
Disclosure Requirements for Common Dartmouth Funders
Information specific to sponsors/agencies can be found at the links below: