Forms, Policies & Procedures

Policy on Disclosure of Other Support

1. PURPOSE

   This policy addresses the federal requirements for disclosing Other Support (also known as Current and Pending Support) and applies to all University faculty, or potential Senior/Key Personnel on Sponsored Federal Research Projects. The National Institutes of Health requires institutions to have a policy and training on the disclosure of other support.

2. SCOPE OF POLICY

   To comply with the provisions of federal law, the Office of Management and Budget’s regulations, including 2 CFR 200, the Uniform Guidance, and other relevant sponsor requirements.

   To establish expectations with faculty and staff about other support information.

3. DEFINITIONS
   1. Other Support– All resources made available to Senior and Key Personnel in support of and/or related to all their research endeavors, regardless of whether or not they have monetary value or are based at the institution the researcher identifies for the current grant or contract. This includes resources and/or financial support from all entities, foreign or domestic, including, but not limited to, financial support for laboratory personnel and provision of high-value materials that are not freely available (e.g. biologics, chemicals, model systems, technology, etc.).
   2. Senior and Key Personnel – An individual who contributes in a substantive, meaningful way to the scientific development or execution of the scope of work of a project proposed to be carried out with a sponsor, whether or not they receive salary or compensation under the grant. This definition may include consultants, postdoctoral research associates, or other roles beyond Project Director or Principal Investigator/Co-Investigator.
4. POLICY STATEMENT
   1. It is the policy of the University of Delaware that all researchers who engage in sponsored projects will comply with federal law, university policies, and sponsoring agency requirements regarding the provision of information on other support documents.
   2. University of Delaware requires that every disclosure to an external funding agency of a researcher’s active, pending, or previous sources of support for research and other sponsored activities be current, accurate, and complete to the best of the researcher’s knowledge.
      1. This requirement applies regardless of the source of support, whether or not University of Delaware is the recipient of the support. For example, if a researcher with a joint appointment is listed as a principal investigator on a award to another institution, that must be disclosed in the other support.
      2. The requirement for disclosure applies at the time of proposal submission, prior to the award of support, as part of the annual progress report, and at any subsequent time the agency determines appropriate during the term of the award.
   3. It is the investigator’s responsibility to ensure the accuracy of other support documents for the project team, in accordance with the application guidelines or the sponsor’s instructions.
   4. False, fictitious, or fraudulent statements or claims (including intentional omissions) in violation of this policy are a violation of UD policy and may lead to disciplinary action and may result in sponsor administrative, civil, or criminal penalties.
5. POLICY STANDARDS AND PROCEDURES
   1. Research Office Website: UD Procedure/Guidance for Preparation of Other Support (Current and Pending Support)