PURPOSE OF THIS POLICY

Colorado State University (CSU) is committed to ensuring transparency and integrity in research by complying with federal requirements for disclosing Other Support. This policy establishes institutional expectations for the Disclosure of all research activities and affiliations—both active and pending—by Senior/Key Personnel involved in federally-funded sponsored activity. Further, this policy sets out required training for Senior and Key Personnel involved in federally-funded work on their responsibility to comply with other support disclosure requirements.

According to Federal requirements, institutions must maintain a written and enforced policy that ensures researchers understand their responsibility to disclose all resources made available in support of and/or related to their research endeavors. These Disclosures must include all domestic and foreign support, regardless of monetary value or institutional affiliation.

This policy supports CSU’s compliance with the updated Disclosure requirements of federal funding agencies and reinforces the university’s commitment to responsible conduct of research, research security, and stewardship of federal funds.

APPLICATION OF THIS POLICY

This policy applies to all CSU faculty, researchers, and professional staff who are designated as Senior/Key Personnel on proposals or awards to federal funding agencies that require Other Support training.

This policy ensures CSU’s institutional compliance with updated federal requirements and supports the responsible conduct of research by promoting transparency and accountability.

EXEMPTIONS FROM THIS POLICY

None.

DEFINITIONS USED IN THIS POLICY

Other Support (NIH): All resources made available to a researcher in support of and/or related to their research endeavors, regardless of whether they have a monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. Includes in-kind contributions, consulting arrangements, and research support from foreign and domestic entities. Excludes training awards, prizes, or legally valid gifts.

Current and Pending Support (NSF): Information about all current and pending research support, including internal and external sources of funding, regardless of whether they are federal, private, or foreign.

Disclosure. Disclosure is the act of formally reporting Other Support information to NIH or other federal sponsors. It includes the submission of accurate, complete, and timely documentation of all active and pending support, in-kind contributions, and affiliations that may influence or contribute to a researcher’s work. Disclosures must be made using sponsor-approved formats and systems and are required at specific stages of the funding lifecycle, including proposal submission, Just-in-Time, and annual progress reporting.

Federally-funded: Includes all sponsored activity funded directly by a federal agency or funded as pass-through from another type of entity.

Key Personnel: Individuals who contribute significantly to the development or execution of a project, including principal investigators and co-investigators.

POLICY STATEMENT

CSU requires all Senior/Key Personnel involved in federally-funded sponsored activity to fully and accurately disclose Other Support in accordance with federal requirements. Other Support includes all resources—financial and in-kind—made available to a researcher in support of and/or related to their research endeavors, regardless of monetary value or institutional affiliation.

This policy ensures that CSU maintains compliance with updated Disclosure requirements of federal funding agencies for transparency in research funding, effort allocation, and research security.

Disclosures must be made at the time of proposal submission, during Just-in-Time procedures, and in annual Research Performance Progress Reports (RPPRs), using federal agency-approved formats and systems.

Failure to disclose Other Support may result in noncompliance with sponsor requirements, potential duplication of funding, and risks to research integrity. OVPR will provide institutional oversight, training, and support to ensure that all Disclosures are complete, timely, and consistent with sponsor expectations.

POLICY PROVISIONS

1. Reporting Obligation:
   All investigators must disclose their current and pending research support and other support as required by each federal sponsor’s policies. These Disclosures must be truthful, complete, and submitted in the format and timelines specified by the sponsor.
2. Scope of Disclosure:
   Individuals must include all forms of research support—monetary or in-kind, domestic, or foreign—including support from internal CSU sources, consulting arrangements related to research, in-kind contributions, or facilities access. Exempt items include gifts and prizes not tied to specific research activities.
3. Format and Systems:
   Disclosures must be submitted using the appropriate sponsor system or form, such as SciENcv for NSF or the NIH Other Support template. CSU requires compliance with sponsor-specific guidelines, including digital signature and certification requirements (e.g., PDF uploads with PI certification for NIH).
4. Updates and Corrections:
   Investigators are responsible for updating their Disclosures during the life of the project if new support is received or previously undisclosed support is identified. Updated information must be submitted as required by the sponsor (e.g., at Just-in-Time or during annual progress reports).
5. Training and Internal Disclosure:
   Training and cadence will be developed and overseen by the Office of the Vice President for Research. CSU faculty and administrative professionals must also comply with institutional Conflict of Interest (COI) and Conflict of Commitment (COC) reporting policies using the Kuali COI system. These Disclosures are required annually, with additional updates as needed.
6. Consequences of Noncompliance:
   Failure to disclose required information may lead to sponsor-imposed penalties, including suspension or termination of awards, as well as institutional disciplinary action under CSU policies.

COMPLIANCE WITH THIS POLICY

Compliance with this policy is mandatory. For questions regarding Disclosure requirements or assistance with submission formats, contact the Office of Sponsored Programs.

REFERENCES

NIH Notice: NOT-OD-25-133

NIH Other Support Guidelines

NSF Current and Pending Support Guidelines

CSU Policy: Conflict of Interest

CSU Policy: Conflict of Commitment and Consulting

Faculty Manual Section D9

FORMS AND TOOLS

FCOI Training

APPROVALS

Effective September 22, 2025