Research Responsibilities and Compliance

Disclosure Requirements for International Engagements

Federal Research Sponsor Disclosure Requirements

Certain collaborations with domestic and foreign entities or individuals must be disclosed in federal research proposals and progress reports. Generally, to meet federal reporting requirements, investigators should:

  • carefully review sponsor guidelines, announcements, award documents and definitions
  • contact the Office of Sponsored Programs or the federal sponsor’s grant management staff with questions about guidelines or definitions
  • ensure Biosketch is up to date
  • disclose all outside activities and collaborations
  • seek prior approval for foreign components when required
  • disclose Other/Current and Pending Support
  • disclose inventions and intellectual property to Ohio State’s technology commercialization team
  • cite publications in progress reports and final reports only if the publication was specifically supported by, and directly related to, the award

Failure to fully disclose foreign or domestic collaborations, affiliations and resources in federal funding applications and grant-related documents can have serious consequences and may impact individual and institutional eligibility for future federal funding.

Federal Disclosure Policies

Each federal research sponsor has unique and evolving disclosure policies. Investigators should review program announcements and proposal preparation guidelines for specific disclosure policies and contact the Office of Sponsored Programs with any questions.

In 2021, the U.S. government issued National Security Presidential Memorandum-33 (NSPM-33), which directed federal funding agencies to standardize disclosure processes, definitions and forms across funding agencies to the extent practicable. In response, NSF developed the below common forms, definitions and guidance. Federal funding agencies are expected to adopt the common forms to the extent possible in 2024.

University Disclosure Requirements

Under the university’s Outside Activities and Conflicts Policy, investigators are required to:

  • annually disclose outside activities on the university’s eCOI Disclosure Form. Outside activities include any activity, paid or unpaid, that is related or similar to an employee’s university responsibilities and is performed outside the university
  • annually disclose professional service on the university’s eCOI Disclosure Form if required to complete a disclosure form and the professional service is responsive to a question
  • update eCOI Disclosure Form within 30 days of any change
  • request pre-approval before engaging in an outside activity (excluding domestic Professional Services). Submit the request via the Outside Activity Approval Form
  • obtain approval before accepting an academic, scientific, professional or institutional affiliation with a foreign government entity, including participating in a foreign government talent recruitment program (Submit the request for approval via the Outside Activity Approval Form. Note that researchers engaged in federally-funded research are prohibited from participation in a malign foreign talent recruitment program.)

Learn more about conflict of interests in research including tips for disclosing outside activities. For a listing of all university policies, rules and forms pertaining to conflicts of interest and outside activities visit the Office of University Compliance and Integrity.

Managing Conflicts of Interest and Conflicts of Commitment

A conflict of interest exists when outside activities or relationships have the potential to create an improper influence on an employee’s university decisions including designing, conducting or reporting research.

A conflict of commitment exists when outside activities interfere with an employee’s ability to fulfill university expectations, obligations, and/or responsibilities; or compete with the university’s interests, including its educational, research or service missions. 

To manage conflicts of interest and conflicts of commitment, all Ohio State employees must comply with university disclosure requirements.

Foreign talent recruitment program

The university’s Outside Activities and Conflicts Policy prohibits researchers involved in federally-funded research projects from participating in a malign foreign talent recruitment program.

Researchers who are participating in or applying for participation in a foreign talent recruitment program should

Active position or affiliation with a foreign institution

Researchers who have an active position or affiliation with a foreign institution (paid, unpaid or honorary) should:

Consulting or advisor relationship with a foreign entity

Researchers who have a paid or unpaid consulting or advisor relationship with a foreign entity should:

  • review federal sponsor disclosure requirements
  • seek approval from the researcher's primary college/unit by submitting an Outside Activity Approval Form and providing a copy of the contract
  • after the relationship has been approved by the college/unit, disclose the relationship on the researcher's eCOI Disclosure Form

Travel expenses that will be paid or reimbursed by a foreign entity

Researchers who have travel expenses that were paid or reimbursed by a foreign entity in connection with their work, should:

  • review federal sponsor disclosure requirements
  • seek approval from the researcher's primary college/unit by submitting an Outside Activity Approval Form and providing a copy of the invitation letter
  • after receiving approval from the college/unit, disclose on the researcher's eCOI Disclosure Form
  • complete the International Risk Assessment survey and reach out to the Export Control Team at exportcontrol@osu.edu

Item of value from a foreign entity

Researchers who have have received an item of value from a foreign entity in connection with their research, should: