Federal Disclosure Requirements

In compliance with individual sponsor requirements, certain collaborations and/or affiliations with foreign as well as domestic entities or individuals must be disclosed in proposals and reports. Such collaborations may include exchanges of staff, materials, data, funding, or other significant activity which could result in joint authorship.

Failure to fully disclose foreign/domestic collaborations, affiliations, and resources in funding applications and other documents can have serious consequences, and may endanger MIT’s eligibility for future federal funding.

When an MIT Principal Investigator submits a proposal to the Kuali Coeus system for final review by MIT Research Administration Services (RAS) and further submission to a federal agency, the PI is certifying that all information is complete and accurate to the best of his or her knowledge, and failure to disclose may lead to charges of providing fraudulent information. In some cases, failure to disclose has led to criminal charges against individual researchers.

Additional information on recent actions taken by various government agencies against researchers who have not fully disclosed their foreign support and affiliations can be found in this July 7, 2020 article in Nature, this July 15, 2020 article in Chemistry World, and this November 27, 2020 article in Bloomberg Law.

Please contact the appropriate sponsor liaison or contract administrator in RAS if you have any questions on disclosure requirements. The policies of the various agencies are not consistent and are being continuously modified. The disclosure policies of some key agencies are summarized below:

For disclosure policies of other federal research sponsors, please review the program announcements and proposal preparation guides, and contact your RAS contract administrator with any questions.