Disclosure Requirements

Reducing undue influence is a fundamental aspect of research integrity and security. 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

While Yale strongly supports research collaborations with external entities, including non-U.S. entities, Yale researchers must carefully, completely, and accurately report these external relationships in a timely manner. Please refer to Yale’s External Professional Activities Guidance to assist you with these collaborations, which will also help guide what is allowable consistent with the Yale Faculty Handbook.

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

Institutional Disclosure Requirements

Researchers must disclose external financial interests and professional activities through the Research Enterprise Reporting portal, IRES.

Engagement in external professional activities must be consistent with the Yale University Faculty Handbook and align with sponsor requirements and federal regulations.  Pursuant to the Faculty Handbook, prior approval by the Provost’s Office is required for certain outside teaching and research activities.   Please see section XXIII.E of the Faculty Handbook and contact the Research Integrity & Security Office (RISO): external.activities@yale.edu or the Provost’s Office for assistance.

External Activities and Commitment Disclosures

Foreign Talent Recruitment Programs

  • Yale researchers are required to disclose via IRES any involvement in a Foreign Talent Recruitment Program. Please review Yale’s Guidance on Foreign Talent Recruitment Programs.
  • Yale prohibits 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). Please see the Yale MFTRP Policy (effective August 9, 2024) and FAQs for additional information on these programs.

Agency Disclosure Related Requirements

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 (FSF) – The use of the common forms was effective May 20, 2024 pursuant to NSF 24-1 PAPPG.
    • National Institutes of Health (NIH) – The Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support and NIH Biographical Sketch Supplement will be required for application due dates and all JIT, RPPR, and Prior Approval submissions on or after January 25, 2026. Current Guidance on NIH disclosures. A table entitled, NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support for NIH will be posted on Common Forms for Biographical Sketch and Current and Pending (Other) Support that provides helpful reference information regarding pre-award and post-award disclosures. The table includes the types of activities to be reported, where such activities must be reported in the application, as well as when updates are required in the application and award lifecycle. A final column identifies activities that are not required to be reported.
    • National Aeronautics and Space Administration (NASA) – 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.
    • United States Department of Agriculture (USDA) – Effective December 31, 2025, the recipient of a research award (whether an institution or individual), and all employees of the recipient who work on the research award, must complete the Common Form for Current and Pending (Other) Support and the Common Form for Biographical Sketch using SciENcv, submit the form(s) at time of application, and agree to update the form(s) at any time USDA deems appropriate during the term of the award, but no less than annually. Current USDA General Terms and Conditions for Federal Awards.
    • Additional Resources for Other Support are available on the Yale OSP Other Support page.

  • Foreign Contracts/Agreements

    National Institutes of Health (NIH)
    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.

    • To fulfill NIH reporting requirements, if a faculty member has an agreement with a foreign entity that requires disclosure on the Other Support page, please upload it to the Third-Party Agreements Library.
    • If the agreement is not in English, it must be translated. Please note agreements need to be uploaded a minimum of 30 days prior to JIT or RPPR due date.
    • Other Support and RPPRs will not be submitted until the agreements have been reviewed.

    National Science Foundation (NSF)
    NSF proposers and recipients are required to maintain supporting documentation, including copies of contracts, grants, or any other agreements specific to foreign appointments, employment with a foreign institution, participation in a foreign talent recruitment program and other information reported as current and pending (other) support for all senior/key personnel that must be available to NSF upon request.

    United States Department of Agriculture (USDA)
    The recipient must provide any supporting documentation, including copies of contracts, grants, or any other agreement, specific to foreign appointments, employment with a foreign institution, participation in a foreign talent recruitment program, and other information reported as current and pending support for all employees working on the award.

    • To fulfill USDA reporting requirements, if a faculty member has an agreement with a foreign entity that requires disclosure on the Other Support page, please upload it to the Third-Party Agreements Library.
    • If the agreement is not in English, it must be translated.

    Questions regarding Other Support submissions, please contact OSPHelp@yale.edu.
    Questions regarding foreign contract/agreements, please contact external.activities@yale.edu
    Third Party Agreements Training

    Foreign Talent Recruitment Programs

    • MFTRP Certifications
      Pursuant to the requirements of the CHIPS & Science Act, Yale researchers will start 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 will soon (if not already) begin 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.

Other Support Disclosures

Other support, also known as “current and pending support,” encompasses all resources provided to a researcher in support of and/or related to all their research endeavors, regardless of whether the research support is related to the current project/award.

This includes resources (material support) and financial support from all foreign and domestic institutions, sources, or entities available to the researcher. Examples include but are not limited to:

  • Financial support for laboratory personnel and provision of high-value materials that are not freely accessible (e.g., biologics, chemicals, model systems, technology, etc.).
  • Sponsored awards, projects, or grants held by Yale, other institutions or entities (foreign or domestic), or individuals that contribute to an investigator’s research.
  • Start-up packages provided by institutions other than Yale.
  • Consulting agreements in which the PD/PI or other senior/key personnel conduct research as part of the consulting activities. E.g., work that may result in publication.
    • Note that non-research consulting activities do not fall under Other Support.

Important: Yale core facilities or shared equipment do not need to be reported as Other Support. These institutional resources should be listed under Facilities and Other Resources.

In-kind support is non-monetary contributions that are uniquely available to senior/key personnel that provide valuable resources or services directly supporting the individual’s research and development efforts.

Below is a table of examples of in-kind support commonly reported in Current and Pending (Other) Support documents:

Types of In-kind Support Example
Equipment Provision of equipment requiring a commitment of time and directly supports the individual’s research and development efforts.
Supplies Provision of supplies requiring commitment of time and directly supports the individual’s research and development efforts.
Office/Laboratory Space Provision of office or laboratory space requiring a commitment of time and directly supports the individual’s research and development efforts.
Employee or Student Resources Employees, postdoctoral scholars, students, or visiting scholars who are supported by an external entity, whose research activities are not intended for use on the project/proposal being proposed and have an associated time commitment.
Consulting Services Consulting that falls outside of an individual’s appointment; separate from institution’s agreement.
Travel Travel supported/paid by an external entity to perform research activities with an associated time commitment.
Other Technology, data, chemicals

The location of the disclosure of in-kind contributions within a proposal is dependent on whether there is an associated time commitment and if the contribution is to be used for the proposal being submitted. If an in-kind contribution is not intended for use on the project being proposed, then the information must be included as part of Other Support. If the in-kind contribution is intended for use on the project being proposed, then information must be included as part of the Facilities and Other Resources or Equipment section of the application and does not need to be replicated on Other Support.

When reporting in-kind support, delineate the type of support, the provider, its estimated value, and how it directly supports the research endeavors.

*If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates. 

Resources:

Foreign Contracts/Agreements

National Institute of Health (NIH)

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.

National Science Foundation (NSF)

NSF proposers and recipients are required to maintain supporting documentation, including copies of contracts, grants, or any other agreements specific to foreign appointments, employment with a foreign institution, participation in a foreign talent recruitment program and other information reported as current and pending (other) support for all senior/key personnel that must be available to NSF upon request.

Contact Information

For questions regarding Other Support submissions, please contact OSPHelp@yale.edu.

For questions regarding foreign contract/agreements, please contact external.activities@yale.edu.

View Third Party Agreements Training.