In proposals and in subsequent steps in the pre-award process, federal agencies require complete listings of investigators’ other activities and the sources and nature of other resources supporting their professional activities. These support the agencies’ consideration and judgment of
- duplicative resourcing of an investigator’s work, whether by funding or in other forms, and whether at a single institution or across multiple institutions;
- over-commitment, or double-counting, of a person’s effort;
- undue influence stemming from commitments to entities other than domestic academic institutions and domestic government agencies.
This page describes general principles applicable to all Federal agencies, followed by specific guidance for agencies that have provided additional details.
What must be included
Prior to issuing an award, agencies require disclosure of the following:
- All professional activities and commitments
- All professional appointments and affiliations, paid and unpaid, including honorary positions
- All collaborations
- All consulting and business activities having any subject matter relationship with your academic work
- All sources of support, whether financial or in other forms, for your professional activities
Information is provided in the proposal or through the pre-award Just in Time process. Once provided, up to the time of award, any changes that occur and any omissions that are discovered must be promptly provided to the agency.
At the time of progress reporting, agencies require disclosure of the following:
- New outside professional activities, commitments or appointments
- New sources of support, whether financial or in other forms, for your professional activities
- New collaborations who are significant contributors
- Effort expended by visiting researchers and student volunteers
Each category is covered in more detail below.
All current projects and activities, regardless of
- whether supported by a grant, contract, fellowship, or other award, or only by expenditure of effort or in-kind (e.g. office/laboratory space, equipment, supplies, employees);
- whether conducted at Lehigh or elsewhere; and
- the magnitude of your commitment. Specifically, if you have a role, or have committed to having a role, in a project at another institution, the project is part of your portfolio even if the effort devoted is minimal.
All positions and scientific appointments both domestic and foreign whether or not remuneration is received
- Includes academic, professional or institutional appointments with any entity other than Lehigh, including affiliations with foreign entities or governments
- May provide access to lab space, research materials and staff
- Whether full-time, part-time or voluntary (including adjunct, visiting, or honorary)
- Collaboration related to funded research
- Selection to or participation in a foreign “talents” or similar type program
- Participation in a grant or contract issued by a foreign government to a foreign entity
- Generally, a foreign or international component involves performance of a significant aspect of a project outside the US or by someone employed by a non-US institution. Each agency provides its own definitions.
- Income and consulting activities in support of your research endeavors
- All current and pending support for your research efforts, regardless of whether it’s provided through Lehigh, through another domestic or foreign organization, or provided directly to you. Support provided through Lehigh includes both extramural grants and contracts, and internal grants.
- In-kind services and resources made available to you by a non-Lehigh source (including domestic and foreign universities, individuals and companies) in support of your research, that are not freely available to others
- whether or not they have monetary value, and
- regardless of whether they are based at the institution where you are appointed or at the institution awarded the current grant
- All in-kind contributions (e.g. office/laboratory space, equipment, supplies, employees, students) or items or services whether intended/not intended for use on the project/proposal, and with the expectation of an associated time commitment
- All research-related grants, contracts, cooperative agreements
- Financial support for laboratory personnel, including Postdoctoral Fellows
- Provision of high-value materials that are not freely available to others
Required disclosures and faculty Professional Activity Reports (PARs)
You should review the activities you list in your annual PAR for consistency with the activities you include in proposals, just-in-time submissions, and progress reports. Research projects, collaborations, and other activities listed in your PAR that fall within the scope of sponsor requirements should be included.
Keep in mind that federal sponsors require disclosure of all relevant professional affiliations and activities, whether at Lehigh or elsewhere. You may therefore have professional activities, such as activities undertaken outside of Lehigh in the Summer, that do not appear on your PAR but need to be included in disclosures to federal sponsors.
Agency-specific rules and guidelines
It is important to note that Federal Agencies have differing definitions of what needs to be reported. There is an effort underway for harmonization across agencies, however, it is unclear when this effort will be completed.
If you are unsure about what to disclose where, and when, do not hesitate to reach out to your Contract and Grant Specialist (CGS).
NOTE: This checklist is a helpful tool for compiling your list of what you should include. NIH and NSF provide the most guidance on where each item should be included, as indicated in the tables below. For other agencies, the closest equivalent to the NIH- or NSF-specified section may be used
|Outside Appointments, both paid and unpaid||Biosketch||Proposal, RPPR (if new)|
|Research, training and/or education carried out with international counterparts either overseas or using virtual technologies||Cover sheet (list countries), Project narrative||Proposal|
|Funding of a foreign organization including subaward or consultant arrangements as part of the award||Cover Sheet||Proposals or Requires Prior Approval|
|Unfunded substantial international collaborations with an associated time commitment||Current and Pending Support||Proposal, RPPR (if new)|
|Other sources of support for research including support to Lehigh and support directly to the individual (office/laboratory space, equipment, supplies, employees, students)||Current and Pending Support||Proposal, RPPR (if new)|
|International Collaborations in your lab (not key personnel)||Personnel report in RPPR||RPPR only if effort is expended|
|In-kind contribution intended for use on the project including all unfunded international collaborations contributing to the proposed project||Facilities, Equipment and Other Resources||Proposal, RPPR (if new)|
|In-kind contribution not intended for use on the project which has associated time commitment||Current and Pending Support||Proposal, RPPR (if new)|
|Support from other than the proposing organization (start-up package)||Current and Pending Support||Proposal, RPPR (if new)|
|Internal Grants from Lehigh||Current and Pending Support||Proposal, RPPR (if new)|
|Consulting and business activities where the individual will be conducting research as part of the consulting agreement||Current and Pending Support||Proposal, RPPR (if new)|
The NSF Website provides additional information:
- NSF Proposal and Award Policies & Procedures Guide
- Frequently Asked Questions on Current and Pending Support
|Outside Appointments, both paid and unpaid - even if labeled as "guest", "adjunct", "honorary"||Biosketch||Proposal, RPPR (if new)|
|All positions and affiliations, including volunteer positions, relevant to the applications||Biosketch||Proposal|
|Ongoing and completed research projects from the past three years that the applicant wishes to highlight||Biosketch||Proposal|
|Number of person months devoted to project, even if there is no salary support or direct personal payments to the scientist||Other Support||JIT, RPPR (if new)|
|Income, salary, consulting fees, and honoraria in support of individual's research endeavors||Other Support||JIT, RPPR (if new)|
|International Collaborations with activities outside of the US (performance of any significant part of the NIH project outside of the US whether or not funds are expended)||Foreign Component||Proposal. Requires prior approval thereafter.*|
|Participation in a foreign talent or similar type programs||Other Support||JIT, RPPR (if new)|
|All resources and other support, both domestic and foreign, for ongoing research projects, including those conducted at a different institution||Other Support||JIT, RPPR (if new)|
|Related sources of support including post-docs, students and visiting scholars funded by foreign sources||Other Support||JIT, RPPR (if new)|
|In kind contributions and resources provided by other institutions, both domestic and foreign that support research activities||Other Support||JIT, RPPR (if new)|
|Foreign grants direct to the investigator||Other Support||JIT, RPPR (if new)|
|International Collaborators in the investigator’s lab (not key personnel)||Personnel report in RPPR||RPPR only if effort exceeds one month|
* Foreign components need prior approval on NIH grants. They should be called out in proposals if known, and should be reported prior to engaging in the research activity if added after the start of the award. Foreign Components include:
NOTE: The foreign component needs to be reported and approved by NIH even if NIH funds are not being used to support the activity.
The NIH website has more information:
- Protecting U.S. Biomedical Intellectual Innovation
- Frequently Asked Questions (FAQs) - Other Support and Foreign Components
|Outside Appointments, both paid and unpaid||Biosketch||Proposal|
|Related sources of support||Other Support||Proposal|