July 19, 2019

New Disclosure Requirements for New DoD Notices of Funding Opportunities

The following messages is from the UC Berkeley Vice Chancellor for Research.

Subject: New disclosure requirements for new DoD Notices of Funding Opportunities (NFOs) starting April 19

Dear Colleagues:

As you may have heard, federal agencies are increasing the requirements for PIs to disclose their foreign sources of support and to disclose how those sources are being used to support the proposed and related research. Last fall, Dr. Francis Collins, Director, National Institutes of Health, issued a letter that discussed several concerns, including grantee failures to disclose financial support from other organizations - including foreign governments, foreign institutions of higher education and corporations - in grant applications.

On March 20, the Undersecretary of Defense announced new requirements for all new DoD Notices of Funding Opportunities (NFOs) pertaining to new research and research-related educational activities after April 19, 2019. (See excerpt below and full memo attached.)

New requirements for DoD Notices of Funding Opportunities (NFOs) pertaining to research and research-related educational activities starting April 19, 2019:

Proposers must submit the following information for all key personnel—not just the PI and Co-PI—whether or not the individuals' efforts under the project are to be funded by the DoD:

  • A list of all current projects the individual is working on.
  • Any future (pending) support the individual has applied to receive, regardless of the source.
  • Title and objectives of each of these research projects.
  • The percentage per year each of the key personnel will devote to the other projects.
  • The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
  • Name and address of the agencies and/or other parties supporting the other research projects.
  • Period of performance for the other research projects.

DoD indicates that failure to submit this information may cause the proposal to be returned without further review. DoD also reserves the right to request further details from a proposer before making a final determination on funding the effort.

Please see the full March 20, 2019 memo attached for additional details.

We expect that in the coming months, additional federal agencies will issue revised guidelines for the type of information that is required, as well as the time frame for disclosure. Berkeley is committed to transparency with its federal sponsors, and we are committed to full disclosure. Our Sponsored Projects Office will continue to review disclosure sections of all federal proposals to ensure that comprehensive disclosures of current and pending sources of support are being met. However, PIs are responsible for ensuring that such disclosures are true and accurate.

Note that Phoebe Search can generate reports on key personnel working at Berkeley that include each individual’s current and pending research support (from industry, government and nonprofit sponsors). Projects can be listed by the name of the sponsor, project title, amount of funding (pending or received), and period of performance.

Information on gifts received can be provided by your academic unit’s UDAR development officer.

Responses to FAQs are listed below. If you have any further questions, contact vcr@vcresearch.berkeley.edu for clarifications.

Randy Howard Katz
Vice Chancellor for Research and
United Microelectronics Corporation Distinguished Professor in
Electrical Engineering and Computer Science

Questions for FAQs

Q: Do I have to report all of my projects, even if they are unrelated to my DoD-funded proposal?

A: Yes - the memo requests a list of all current projects that key personnel are working on, “whether or not the individuals’ efforts under the project are to be funded by the DoD”. We encourage PIs to be transparent in their disclosures, and include all projects funded by gifts, grants or contracts, as well as unfunded projects or collaborations that require disclosure on Conflict of Commitment reporting.

Q: Do I need to disclose US-based industrial support?

A: Yes. The memo does not distinguished between foreign and domestic sources of corporate support. In the spirit of complete transparency, philanthropic gift support as well as industrial alliances and contract and grant support from corporate entities should be disclosed.

Q: I am responding to an NFO that was issued prior to April 19, 2019. Do these rules still apply?

A: No: the March 20, 2019 memo only applies to new NFOs after April 19, 2019. Note that the memo only applies to research and research-related educational activities.