Disclosure Requirements

Reducing undue influence is a fundamental aspect of research integrity and security. In recent years, the U.S. Government has expressed concern regarding increased foreign influence in research at academic institutions. These are some of the identified areas of concern:

• Diversion of intellectual property to foreign entities
• Failure of researchers to disclose research resources and support made available to them by external entities, including foreign entities
• Disclosing confidential grant application information by peer reviewers to third parties

While Yale strongly supports research collaborations with external entities, including non-U.S. entities, Yale researchers must carefully, completely, and accurately report these external relationships in a timely manner. Please refer to Yale’s External Professional Activities Guidance to assist you with these collaborations.

Disclosure and transparency of potential conflicts of interest and/or commitment are essential to avoiding the appearance of undue influence. Yale (Institutional) and federal funding agency (Agency) disclosure requirements are described below.

Institutional Disclosure Requirements

Researchers must disclose external financial interests and professional activities through the Research Enterprise Reporting portal, IRES.

External Activities and Commitment Disclosures

• Visit Yale’s Conflict of Interest (COI) Office for information on COI policies, procedures, and guidance.
• Faculty members are also encouraged to review the External Professional Activities Guidance for an overview of their requirements, pursuant to the Yale Faculty Handbook.

Foreign Talent Recruitment Programs

• Yale researchers are required to disclose via IRES any involvement in a Foreign Talent Recruitment Program. Please review Yale’s Guidance on Foreign Talent Recruitment Programs.
• Yale prohibits faculty, staff, trainees, students, and visitors who engage in or propose to engage in research and development projects or who contribute in any way to the scientific development or execution of research and development projects from involvement in Malign Foreign Talent Recruitment Programs (MFTRP). Please see the Yale MFTRP Policy (effective August 9, 2024) for additional information on these programs.

Agency Disclosure Related Requirements

Disclosure and transparency, especially with respect to relationships with foreign entities, are critical to complying with research security requirements and to avoiding the appearance of undue influence. Due to increased scrutiny of foreign engagements by the federal government, researchers must be vigilant in ensuring that they have complied with all requirements to disclose funding, appointments, relationships, and other necessary information on federal submissions, including in sponsored funding applications, Just-In-Time submissions, and progress reports.

• Common Forms: Biographical Sketch & Other Support
  The National Science and Technology Council (NSTC) Research Security Subcommittee has finalized the proposed common forms for the Biographical Sketch and Other Support, pursuant to the request of NSPM-33.
  Agency specific guidance:
  • National Science Foundation – The use of the common forms is effective May 20, 2024 pursuant to NSF 24-1 PAPPG.
  • National Institutes of Health – The common forms are anticipated for January 2025. Guidance on NIH disclosures is available. NIH also provides FAQs for Other Support.
  • Additional Resources for Other Support are available on the Yale OSP Other Support page.
• Foreign Contracts/Agreements

  NIH requires the submission of copies of contracts/agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. The contracts/agreements must be included with the Other Support submission. If the contracts/agreements are not in English, translated copies must be provided.

  If a faculty member has an agreement with a foreign entity that requires disclosure on the Other Support page, please upload it to the Third-Party Agreements Library. If the agreement is not in English, it must be translated. Please note agreements need to be uploaded a minimum of 30 days prior to JIT or RPPR due date. Other Support and RPPRs will not be submitted until the agreements have been reviewed. Other Support & Third Party Agreements Training is available for your review.

  For questions regarding Other Support submissions, please contact OSPHelp@yale.edu.
  For questions regarding foreign contract/agreements, please contact external.activities@yale.edu

• Foreign Talent Recruitment Programs
  • MFTRP Certifications
    Pursuant to the requirements of the CHIPS & Science Act, Yale researchers will start to see the implementation of restrictions on participation in Malign Foreign Talent Recruitment Programs (MFTRP) for federally funded researchers. Key personnel will need to attest to not participating in such programs at the time of proposal and on an annual basis (if awarded). This certification requirement went into effect on NSF proposals as of May 20, 2024.
  • Foreign Talent Recruitment Program
    Section 223 of the FY21 National Defense Authorization Act requires covered individuals to disclose to sponsoring agencies if they are party to a foreign talent recruitment program. The Office of Science and Technology Policy has released the Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs.
    • Please also review Yale’s Guidance on Foreign Talent Recruitment Programs.
• Agency Risk Assessments
  As requested in NSPM-33, federal funding agencies are beginning to implement research security risk assessments, which are conducted on individual research proposals independent of the merit review process. The results of such an assessment may jeopardize the awarding of funds and may require the implementation of a research security plan and other terms and conditions to safeguard research as a condition of the award.

  As of August 2024, the following agencies have publicly released risk assessments for their fundamental research submissions:

  • National Institutes of Health: Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel
    • Statement from the NIH Director: NIH supports our valued Asian American, Asian immigrant and Asian research colleagues
  • National Science Foundation: Trusted Research Using Safeguards and Transparency
  • Department of Defense (DOD): Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education
  • ARMY: DEVCOM ARL Implementation of Army Futures Command (AFC) Army Research Risk Assessment Protection Program (ARRP) – DEVCOM Army Research Laboratory
• Digital Persistent Identifiers
  Government agencies will soon (if not already) begin to require the use of digital persistent identifiers (DPI) for proposal submissions. This may require investigators to register with an ORCID ID and submit via SciENcv.