To: all faculty with active support or pending proposals with federal sponsors
I am writing to update you on federal government agencies’ expanded disclosure requirements for outside activities. These changes will affect how you and your team prepare and manage biosketches, current and pending or other support pages, and disclosures during the life of the award. Please read on for agency-specific updates; Stanford’s new optional highly recommended External Activities Questionnaire (EAQ); and information on our internal webinars (next one is 10-11 am, Nov 9).
Ensuring that these documents are true, complete and correct is a PI responsibility – one of many responsibilities that we as PIs must meet. Many dedicated, professional staff have been working hard to keep up to date so that they can advise you and develop processes to decrease your burden as much as possible. Thank you for all that you do as researchers and educators and thank you for working with our dedicated staff in partnership. Please contact the VPDoR office, ORA, RMG, ERA, or your department or school research administrator with any questions or advice about existing or new disclosure requirements.
National Institutes of Health (NIH)
NIH has issued guidance for disclosing information about all resources available to a PI for their research program including some gift funds, in-kind support, and consulting activities. These changes will take effect on January 25th 2022. We recommend that you become familiar with the requirements and apply them to your annual progress reports or Just-in-Time requests beginning now. Importantly, senior/key personnel with certain types of outside professional activities or appointments with foreign entities must provide a translated copy of the agreement that has first been reviewed by Stanford. We are developing procedures and systems to expedite collection and review in the upcoming months, but meanwhile please let your Institutional Representative in RMG or ORA know if you have questions about your agreements before the January 2022 implementation. See RMG and ORA websites for more information and resources about the new NIH requirements.
National Science Foundation (NSF)
In October 2020, the National Science Foundation implemented its own expanded disclosure requirements. Investigators must disclose all available resources in support of their research efforts provided through Stanford or directly to the individual, regardless of whether they have monetary value. Investigators must also provide annual updates to active support as part of their Annual Progress Report. While those changes have been in effect for almost a year now, details have been updated with the release of a new Proposals and Award Policies & Procedures Guide (PAPPG) effective October 4, 2021. Please review the new PAPPG and let us know if you have questions about these expanded requirements. See the ORA NSF page for more information.
Department of Energy, Office of Science
DOE is closely aligning its disclosure requirements with NSF, although there are some differences. Other DOE components have been issuing specific requirements in grant solicitations. Read each solicitation carefully as you respond to it, and see the ORA DOE page for more information.
Department of Defense (DOD)
DOD has not changed its guidance significantly since March 2019, although new program-specific requirements have been identified in specific solicitations. Read each solicitation carefully as you respond to it, and see the ORA DOD page for more information.
Stanford’s new optional External Activities Questionnaire (EAQ)
We are here to help you meet these disclosure requirements. A cross-functional team has been working for several months to develop tools and FAQs. In addition, the team has developed a new External Activities Questionnaire (EAQ) in the SeRA system to help PIs provide complete and accurate information for disclosure to federal sponsors. The EAQ is optional and can be completed or updated by senior/key personnel at any time. We recommend that you use the EAQ tool when writing proposals, before receipt of an award (e.g., during the just-in-time period) and as you are writing your annual progress report.
Webinars
The Office of Research Administration and the School of Medicine Research Management Group has developed webinars to provide guidance for the expanded disclosure requirements. Please visit the ORA Disclosure Resources webpage to review the October 26 Gift Disclosure webinar recording, view future Disclosure webinar dates, and leverage the full suite of Stanford Disclosure resources. The next webinar is: In-Kind Contributions Disclosures Webinar - Nov 9, 2021 - 10 to 11 am. For details and to submit questions in advance, please use the hyperlink.
Thank you again for all that you do. Contact any of your research support professionals and administrators to ask questions, share thoughts about how to better support research, or just to thank them!
With much appreciation,
Kam