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Disclosing for Researchers

Disclosing for Researchers

Key personnel on sponsored projects make disclosures to funding agencies as well as in their Northwestern conflict of interest disclosure. Sometimes there is overlap between the two. The table below shows common types of activities and interests and where they must be disclosed.

Researchers looking for information on Current & Pending/Other Support should review the guidance provided by Sponsored Research. See also guidance on Protecting Against Improper Foreign Influence in Research from the Office for Research.

Disclosure Requirements for Federal Awards and per Northwestern Policy

Type of Entity or Activity	Conflict of Interest Disclosure (eDisclosure)	Biographical Sketch	Current & Pending (Other) Support	Facilities, Equipment, & Other Resources*	Project Reports**
Significant financial interests, i.e. compensation from outside entities, equity in companies, royalties, reimbursed travel	✓
Professional preparation, i.e. undergraduate, graduate, and postdoctoral training		✓
Academic, professional, and institutional appointments, paid and unpaid, at Northwestern		✓			✓
Serving as key personnel for research, paid and unpaid, outside of Northwestern	✓		✓		✓
Teaching, paid and unpaid, outside of Northwestern	✓	✓			✓
Academic appointments, paid and unpaid, outside of Northwestern	✓	✓			✓
Research achievements and products		✓			✓
Any research support that did not go through Sponsored Research or Alumni Relations and Development	✓		✓	✓	✓
Sponsored research at Northwestern and all proposals currently under consideration			✓		✓
In-kind contributions to research			✓	✓	✓
External support for students, postdocs, and visiting scholars			✓	✓	✓
Consulting agreements if research is part of the consulting work			✓		✓
Travel to perform research (paid by external entity)	✓		✓		✓
Startup companies based on non-Northwestern-licensed IP	✓		✓		✓
Startup packages other than from Northwestern	✓		✓		✓
Participation in foreign talent recruitment programs	✓	✓	✓	✓	✓

* Include in Facilities/Other Resources if it specifically benefits the research being proposed.
** Any information provided in the biographical sketch, current & pending support, and facilities & other resources section of a proposal should be updated in project reports as appropriate.

Frequently Asked Questions

Question: I'm paid to consult for an international pharmaceutical company. Where should I disclose this?
Answer: You should disclose this and all significant financial interests in your Northwestern conflict of interest disclosure. Additionally, consulting should be disclosed in your Current & Pending/Other Support if it involves research.

Question: I have disclosed payments from a foreign entity in my Northwestern conflict of interest disclosure. Do I also have to report them to federal funding agencies?
Answer: If the payments were for an activity that was of benefit to your research then yes, the activity should be disclosed in Current & Pending/Other Support. Federal agencies do not require reporting dollar values.

Question: I have an unfunded foreign collaboration that directly benefits my research and/or publications. Should I disclose this in my Current & Pending/Other Support?
Answer: Yes, include this in your Current & Pending/Other Support. Federal guidance on formatting this type of disclosure may be lacking, but for the sake of thoroughness you should find a way to disclose it.

Question: I have an unpaid appointment at a foreign university. I included this in my biographical sketch. Must I include it anywhere else?
Answer: Yes, this should be disclosed in the Other Activities section of your Northwestern conflict of interest disclosure and in your Current & Pending/Other Support if the appointment gives you access to lab space, research materials, and/or staff.

Question: I have a visiting scholar in my lab who is paid a salary by their home university. Where do I disclose this?
Answer: In your Current & Pending/Other Support.

Question: Travel to a conference was paid on my behalf. Where do I disclose this?
Answer: In your Northwestern conflict of interest disclosure.

Question: I formed a startup company based on Northwestern-licensed IP. Where do I disclose this?
Answer: In your Northwestern conflict of interest disclosure

Question: Do I need to disclose gifts to my lab?
Answer: It depends. If the gift contribution mentions research in general or a topic of research, then you should report it to your federal sponsors. If there is any expectation of something in return for the gift then it is reportable. If the gift is unrestricted it is not reportable to federal agencies. But when in doubt err on the side of reporting the gift to your lab in Facilities, Equipment & Other Resources.