University & Sponsor Disclosure Requirements
UNIVERSITY DISCLOSURE REQUIREMENTS
Faculty members and other researchers must disclose financial interests or other activities that might create the perception of or potential for a conflict of interest – both annually and within 15 days of acquiring any new interests, as required by the University Conflict of Interest Policy. They must also disclose or seek prior approval for activities described in the University Conflict of Commitment Policy, including support from foreign governments and foreign academic institutions, consulting relationships, visiting positions, and all investments in start-up companies. Faculty and other researchers must disclose any involvement in any foreign recruitment or “talent” programs. These programs are of particular interest to the federal government, as they are seen as presenting a uniquely high risk of undermining U.S. economic and security interests.
Compliance with the Foreign Corrupt Practices Act, which prohibits payments to foreign government officials to assist in obtaining or retaining business, is also required.
SPONSOR DISCLOSURE REQUIREMENTS
Faculty members and other researchers should be thorough and complete in accounting for all forms of research support, including from foreign sources and gifts, in NIH’s Other Support, the NSF's Current and Pending Support, and similar documentation submitted to other sponsors. These disclosures are important, as the University is responsible for disclosing receipt of foreign gifts and contracts under Section 117 of the Higher Education Act.
New resources to help researchers comply the evolving landscape of sponsor guidelines have been added into the proposal submission process. A new question about international engagements appears in the project form in the Pre-award Proposal Preparation Portal. This portal was created in 2020 to assist in the management of the thousands of proposals Notre Dame Research Administration (NDRA) assists with each year and can be accessed through InsideND. NDRA will review the information provided by researchers in the portal ensure their proposals meet reporting and compliance guidelines specific to their sponsors. Different information is required at different stages by different sponsors, so the information captured in this form will help streamline the process for everyone involved in the submission process.
Checklists for the National Institutes of Health and National Science Foundation help researchers prepare their proposal or reporting documentation:
NIH Checklist includes:
- Other Support & Just-in-Time
NSF Checklist includes:
- Current and Pending
NEED MORE INFORMATION?
For more information on the documents required for proposal submissions, please contact the Pre-Award Team. For more information on progress reports or post-award disclosures, please contact the Grants Program Management team. Both teams may be reached by email firstname.lastname@example.org.