2025 Federal Administration Transition Information & Resources - This will be updated as new information is available.

Stanford
Office of Research Administration

Disclosure Resources

The following resources and agency specific pages have been compiled to assist Stanford researchers and administrators with understanding the various Federal agency disclosure requirements.  Disclosures can be required at the time of proposal, just-in-time, prior to award acceptance, annual reporting and during the life of the award.  Federal agencies have expanded their disclosure requirements to include all paid or in-kind resources supporting a PI’s research program, whether the support is made through Stanford or provided directly to the PI.

Background

National Security Presidential Memorandum-33 (NSPM-33) directs federal research agencies to require principal investigators (PIs) and other senior/key personnel to disclose appropriate information that “will enable reliable determinations of whether and where conflicts of interest and commitment exist.”

The William M. (MAC) Thornberry National Defense Authorization Act for Fiscal Year 2021 (Section 223) requires all federal research agencies collect current and pending support disclosures as part of the application process.

Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232) directs federal agencies to establish policies that, as part of a proposal for a research and development award from the agency, each covered individual listed in the proposals certify as part of the proposal and annually thereafter that they are not a party to a malign foreign talent recruitment program.  The submitting institution of higher education (IHE) is also required to certify that each covered individual employed by the IHE has been made aware of the requirements and complied with the requirement.

Who must disclose

Covered Individuals are those people who contribute in a substantive, meaningful way to the scientific development or execution of a research and development project proposed. These individuals have responsibility for the design, conduct and reporting of the research. Covered Individuals typically includes PIs, Co-PIs, and individuals identified as Senior/Key Personnel but can very depending on the agency and/or specific Funding Opportunity Announcement ("FOA").

What must be disclosed

The NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support, provides reference information regarding pre-award and post-award disclosures. It includes:

  • The types of activities to be reported.
  • Where such activities must be reported in the application.
  • When updates are required in the application and award lifecycle.
  • Activities that are not required to be reported.

Biographical Sketch

Researchers must fully disclose all professional affiliations, funding, and collaborations with foreign entities. This includes positions, financial support, and any other ties that could present a conflict of interest.

Proposal FOAs and any subsequent awards received should be reviewed for requirements related to participation in Foreign Government Talent Recruitment Programs (“FGTRPs”). 

Malign Foreign Government Talent Recruitment Programs (“MFTRPs”) are FGTRPs sponsored by countries of concern (generally defined by the U.S. as China, Russia, Iran and North Korea but can be defined more broadly by agency). Individuals participating in MFTRPs are prohibited from participating in federally funded research and development by US government regulation and Stanford policy.

For additional information please see Stanford’s Academic Integrity and Undue Foreign Interference page.

Current and pending research support includes all:

  • resources made available, or expected to be made available, to an individual in support of the individual’s research and development efforts, regardless of whether the resource has monetary value;
  • resource made available through Stanford or directly to the individual; and
  • in-kind contributions requiring a commitment of time and directly supporting the individual’s research and development efforts, such as the provision of office or laboratory space, equipment, supplies, employees, or students.

Foreign Components and Supporting Documentation

Some federal agencies (e.g. NIH) require institutions to submit copies of 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.  

Additionally, effective October 10, 2025, the NSF reserves the right to perform risk assessments of proposals and awards to assess nondisclosures of required information from senior/key personnel, and establish other policies and procedures for identifying, communicating, and addressing security risks.  Proposers and award 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.

Investigators should submit copies of these external agreements for Stanford review through the Stanford Outside Professional Activities Certification System (OPACS) to ensure compliance with Stanford policy.  Additional information about this can be found on the DoR website

Proposal applications must require

  1. that each covered individual listed on the application:
    • (a) disclose the amount, type, and source of all current and pending research support received by, or expected to be received by, the individual as of the time of the disclosure;
    • (b) certify that the disclosure is current, accurate, and complete; and
    • (c) agree to update such disclosure at the request of the agency prior to the award of support and at any subsequent time the agency determines appropriate during the term of the award; and
  2. that the entity applying for the award certify that each covered individual who is employed by the entity and listed on the application has been made aware of the requirements.

Stanford Policy

Stanford secures PI and all Senior/Key Personnel understanding of the federal disclosure requirements as part of the SeRA Proposal Development Routing Form (PDRF).  The PI and all Senior/Key Personnel named in the proposal application must be listed in the SeRA PDRF associated with that proposal and will receive a “Certification of Responsibilities” task where they certify:

  • The attachments and statements herein and any information to be submitted to the sponsor in support of this project are true, complete and accurate to the best of my knowledge;
  • I have read and am aware of the requirements detailed in the Research Policy Handbook and Administrative Guide;
  • I have read and am aware of the specific sponsor requirements associated with this proposal submission, including federal disclosure requirements;  I confirm I have completed all applicable training as required by the specific sponsor;
  • I am not a member of a malign foreign talent recruitment program and am aware of the restrictions on foreign government talent recruitment programs including certifications required under the CHIPS and Science Act of 2022 (Public Law 117-167). I will ensure my research team is aware of these restrictions and obligations;
  • I acknowledge that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties;
  • If awarded, I will direct this project in compliance with the terms and conditions of Stanford's agreement with the sponsor, all applicable laws and regulations, and Stanford University policies;
  • If awarded, I accept the responsibility for scientific conduct of the project and to provide the required reports and deliverables in accordance with the timelines required by the sponsor;

Disclosure Webinars

Each academic quarter (Fall, Winter, and Spring) as part of CRAFT Level 2, ORA offers two disclosure related webinars with the most up to date agency and Stanford information.  Register for an upcoming session and/or view the most recent session recordings and slides from the ORA (CRAFT) program page. 

Historical Disclosure Webinars

Recording of ORA/RMG Federal Disclosures Town Hall - May 12, 2021

Slides for ORA/RMG Federal Disclosures Town Hall - May 12, 2021

Gifts Disclosures webinar -  Oct 26, 2021 -  Gift Disclosures Webinar Recording

In-Kind Contributions Disclosures - Nov 9, 2021 -  In-Kind Disclosures Webinar Recording

NIH Other Support Updates - Investigator Call to Action - Dec 15, 2021 - NIH Other Support Updates Webinar Recording - NIH Other Support Updates Webinar Slides

Need further assistance? Have questions and/or feedback? Please submit questions and/or feedback and a member of the ORA-RMG Disclosures Team will respond to you shortly.