Disclosure and transparency about relationships with, and research support from, foreign entities have been identified by the federal government as key to managing and protecting the security of research. Within the institution, researchers applying for federal funding opportunities are expected to disclose outside financial interests and External Professional Activities in their Annual Conflict of Interest Disclosure.  In addition, some External Professional Activities may require prior approval through the Consulting Authorization Request.   

What is commitment transparency?

Transparency and reporting of all research activities, domestic and foreign.

• Openness and transparency enables productive collaboration and helps ensure appropriate disclosure of potential conflicts of interest and commitment.
• Failure by some researchers at NIH-funded institutions to disclose substantial contributions of resources from other organizations, including foreign governments, threatens to distort decisions about the appropriate use of NIH funds.

Disclosure Requirements

To Federal Agencies:

• Ensure Biosketches, Current and Pending Support, and Collaborators and Other Affiliations information is updated to reflect the requirements of the funding agency prior to submitting grant applications.
• Principal investigators (PIs) and other senior/key personnel are required to disclose:
  • Organizational Affiliations/Employment
  • Positions/Appointments
  • Foreign government sponsored talent recruitment programs
  • Current and pending support/Other support

To the Institution:

• Disclose the following in your Annual COI Disclosure in Novelution:
  • outside appointments or positions (foreign and domestic)
  • significant financial interests
  • in-kind contributions.