Dear Colleagues,
We are writing to remind you of an important Office of Research and Sponsored Programs website that summarizes all Federal Agency Requirements for Reporting of Professional Activities and Sources of Support.
Why it matters
Federal sponsors require a complete picture of investigators' professional outside activities and sources of support. Sponsors use this information to identify duplicative funding, over-commitment of effort, and undue influence from entities other than domestic academic institutions and government agencies. Incomplete or inconsistent disclosures can create serious consequences for both investigators and the university. It is important to be aware that disclosures made to sponsors on proposals or awards are also different from COI disclosures made to Lehigh directly via LIRA.
What to disclose
All federal applications must report:
- all professional activities and commitments;
- all appointments and affiliations, paid or unpaid, including adjunct, visiting, and honorary roles;
- collaborations, including foreign collaborations and any participation in foreign talent programs;
- related consulting and business activities;
- and all current and pending support, including in-kind resources such as space, equipment, or personnel.
This applies whether or not the commitment includes remuneration, regardless of the amount of remuneration, and regardless of where the work takes place.
When to disclose
Disclosures are required at the time of proposal submission or during the pre-award Just In Time process, depending on each agency’s requirements. If changes or omissions to disclosures are identified after proposal submission but before the award is made, report them promptly. When reporting progress during the term of the award, you must also report new activities, appointments, and sources of support.
Agency-specific guidance
Each federal sponsor has its own disclosure requirements and definitions. The ORSP website includes clear tables for NSF, NIH, and DoD/DoW showing what information goes where (biographical sketch, Current and Pending/Other Support, Facilities and Other Resources, etc.) and when it is due (at proposal, JIT, or in progress reports). Please also note that NIH requires prior approval for any foreign component, even if no NIH funds are used for that project. Contact ORSP before proceeding if your project involves significant work performed outside the United States.
Your Professional Activity Report (PAR)
You are responsible for making sure your annual Professional Activities Report (PAR) does not conflict with what you disclose to federal sponsors. The two won’t always match exactly. Sponsors often require you to disclose more than the PAR covers. For example, outside activities during the summer may not appear on your PAR, but you may still need to report them to a sponsor under that agency’s disclosure requirements.
Additional resources
The website links to a "Proposal Checklist - Support" for compiling your disclosures, along with agency guides, FAQs, and related Lehigh policies on effort allocation, conflicts of interest, and foreign talent programs. If you are ever unsure what to disclose, where, or when, contact your Contract and Grant Specialist (CGS).
Thank you for your attention to these requirements.
Best regards,
Anand Jagota
Vice Provost for Research
Dominic Packer
Senior Advisor to the Vice Provost for Research
Cynthia J. Kane
Associate Vice Provost
Office of Research and Sponsored Programs