Responsible Conduct of Research

Disclosing Activities to Sponsors

It is very common for researchers to engage in professional activities outside of WashU. Most of these activities do not present concerns for the university or funding agencies, provided they are properly structured and disclosed.

It is important to be fully honest in all disclosures. Even if an activity does not feel relevant to disclose, it is relevant to the university and funding agencies.

Requirements for disclosing to the university are covered in the External Professional Activities Policy, Prior Approval Guidance, and Financial Conflicts of Interest training.

Funding agencies typically have their own reporting and disclosure requirements. These commonly include:

Documents such as the Biosketch and Current and Pending (Other) Support
Report external activities, research activities, and international activities. For more information, visit the NIH and NSF disclosure pages.

Certifications of no engagement in maligned foreign talent programs
Review the Guidance for Foreign Talent Programs page on the COI website.

Foreign components
Activities that contribute to a specific aim of your grant. Examples (adapted from the NIH):

  • Collaborations with investigators at a foreign site anticipated to result in co-authorship
  • Using facilities or instruments at a foreign site
  • Receiving financial support or resources from foreign entity
  • Involving human subjects or animals
  • Extensive foreign travel for the purpose of data collection, surveying, sampling, etc.

Funding agencies may use disclosed information to perform risk assessments to identify and counter foreign influence.

If you are ever unsure if something should be disclosed, it is best to ask the Conflicts of Interest (COI) office.