SPONSORED PROGRAMS ADMINISTRATION
Guidance to Investigators to Disclose All Financial Interests
In recent months, NIH has issued communications to the research community at large and to its grantee institutions to convey NIH’s concerns about the integrity of the biomedical research it funds and the risk that foreign influence poses to that integrity. Specifically, NIH is troubled by:
- Diversion of intellectual property (IP) in grant applications or produced by NIH supported biomedical research to other entities, including other countries;
- Sharing of confidential information on grant applications by NIH peer reviewers with others, including foreign entities, or otherwise attempting to influence funding decisions; and
- Failure by some researchers working at NIH-funded institutions in the U.S. to disclose substantial resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds.
As a result, NIH is working with various government agencies and universities to better define the problem(s) and identify steps that can be taken to mitigate any risk. In the interim, NIH is reminding researchers that all forms of support, financial interests, and relevant affiliations must be fully disclosed; NIH’s reporting mechanisms include the proposal process, a response to a Just-In-Time request, annual progress reports, and through the disclosure of a significant financial interest (conflict of interest).
While NSF has not yet issued its own guidance on foreign influence or a reminder to report all forms of support, researchers should remember that the “Current and Pending Support” section of a NSF grant proposal requires that all “projects or activities requiring a portion of time of the PI and other senior personnel” must be disclosed. NSF proposals also require that researchers disclose all of their organizational affiliations for the previous 12 months and all co-authors/collaborators and their affiliations for the previous 48 months.
Those researchers who submit grant proposals to—or receive research or other sponsored funding from—federal agencies such as NIH and NSF should review and update their relevant documents and disclosures as needed:
- Documents such as the NIH “Other Support” and NSF “Current and Pending Support” should include all sources of support and commitments of time/effort.
- Biosketches and the NSF “Collaborators and Other Affiliations” (COA) documents should be current and thorough.
- Annual progress reports should reflect any changes to a key person’s level of support and sources of support over the previous year.
- Progress reports should also include any inventions; inventions must also be reported to the Office of Technology Management and Industry Relations (OTMIR). The University of Missouri Collected Rules and Regulations (CRR) require that the rights to any Invention made by an employee in the “general scope of his/her duties as an employee of the University” must be assigned to the Curators of the University of Missouri.
- External activities related to work within the scope of a researcher’s University responsibilities must be disclosed through the Conflict of Interest process and through any NIH or NSF required reporting mechanism.
Additional information about relevant University of Missouri policies and NIH and NSF requirements is provided below. Other federal agencies may have other, specific reporting requirements; the Office of Sponsored Programs Administration or the research administrators housed locally in schools, colleges, and departments can assist with the application of those requirements.
- Biosketch Instructions and Samples
- Other Support -- Just-in-Time (JIT) request or Research Performance Progress Report (RPPR)
Office of Technology Management and Industry Relations
- University of Missouri (Columbia) Office of Technology Transfer & Industry Relations
- University of Missouri (System) Office of Intellectual Property Administration
- Patent and Plant variety Regulations (Collected Rules and Regulations 100.020)
- Patent and Copyright Law (Collected Rules and Regulations 100.030)
Conflict of Interest
- University of Missouri Conflict of Interest Office
- Policy on Conflict of Interest (Collected Rules and Regulations 330.015) —Applicable to All University Employees
- Conflict with the Interests of Federal Grant Agencies (Collected Rules and Regulations 420.030) —Applicable to PHS-funded and NSF-funded Researchers
- University of Missouri-Columbia Conflict of Interest Procedures