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Disclosures of Other Support

A page within Research & Sponsored Programs

Purpose

This policy’s purpose is to:  

  • Comply with the provisions of federal law, the Office of Management and Budget’s regulations, including 2 CFR 200, the Uniform Guidance, and other relevant sponsor requirements. 
  • Establish expectations with faculty and staff about the disclosure of other support information. 
  • Promote the best possible alignment between faculty and staff activity and funding sources and, in so doing, enhance work at UW-La Crosse. 

UW-La Crosse recognizes the importance of providing good stewardship of institutional and extramural funds. The university’s stewardship responsibilities include complying with federal requirements for disclosing other support (also known as current and pending support). Other support may include active, pending, or previous sources of support for an individual’s research and other sponsored activities. 

Sponsoring agencies request information on other support as part of the proposal process, often prior to the issuance of an award, or as part of the annual progress report process. Sponsors use the information to ensure that scientific, budgetary, or commitment overlap do not occur. The requirement for disclosure is in place to demonstrate that: 

  • The funding agency is not providing funds for work that is already supported by another source; 
  • The individual has sufficient time available to conduct the work for which funds are being requested; and 
  • Only funds necessary to conduct the approved project are included in the award. 

Additionally, there is current interest in the federal government on undue foreign influence on the US research enterprise, and federal sponsors have emphasized that appropriate disclosures must be made as part of other support documents.

Scope

This policy applies to all faculty and staff who engage in or propose to engage in sponsored projects, including federal and nonfederal sponsored projects. 

Policy

It is the policy of UW-La Crosse (UWL) that all individuals who engage in sponsored projects will comply with federal law, university policies, and sponsoring agency requirements regarding the provision of information on other support documents. 

UWL requires that every disclosure to an external funding agency of an individual’s active, pending, or previous sources of support for research and other sponsored activities be current, accurate, and complete to the best of the individual's knowledge. This requirement applies regardless of the source of support, whether or not UWL is the recipient of the support. For example, if an individual with a joint appointment is listed as a principal investigator on an award to another institution, that must be disclosed in other support. The requirement for disclosure applies at the time of proposal submission, prior to the award of support, as part of the annual progress report, and at any subsequent time the agency determines appropriate during the term of the award. 

It is the individual’s responsibility to ensure the accuracy of other support documents for the project team, in accord with the application guidelines or the sponsor’s instructions. 

False, fictitious, or fraudulent statements or claims (including intentional omissions) in violation of this policy may result in university and sponsor administrative, civil, or criminal penalties. 

UWL personnel identified as senior/key personnel for covered federal awards, as described in the Research Security Training policy, will complete Research Security training within 12 months prior to a proposal submission deadline, or annually for active, covered awards. The training includes information on disclosures of other support to foster understanding and compliance with federal requirements.

Supporting Information

Procedures

General Guidelines

  • Include any activity conducted within the scope of an individual’s UWL appointment that provides funding or requires a commitment of time. Commitments are regular obligations of time (part of an individual's regular activities), not short-term obligations, such as attending a meeting and making a presentation. Examples of activities that provide funding or have a quantifiable commitment of time include federal, non-federal, UWs, or UWL sponsored projects. 
  • If an investigator has a commitment for an activity but is receiving no salary support from the activity (salary is cost shared by the University), that activity must be reported. Even if a research project does not involve a quantifiable commitment of time, if the PI/senior key personnel is spending time on the project, the project should be included. 
  • Awards resulting from internally funded competitions should be included. Examples include UWL Faculty Research Grants, UWL Faculty Development Grants, Freshwater Collaborative of Wisconsin Grants, WiSys Ignite Grants, and Thompson Center Research Grants. In general, consider including internal funds if they meet all of the following criteria: a proposal and budget for a specific project were submitted; funds were competitively awarded and will be separately accounted for; and a deliverable such as a project report is required.
  • Include all collaborations and affiliations that provide funding or require a commitment of time, whether foreign or domestic. 
  • Include the proposal being submitted as a pending proposal unless otherwise directed by the sponsor. 
  • Address potential overlap or over-commitments. As this is a primary concern of Federal agencies, be clear in your explanations. 
  • List projects with no-cost extensions. NIH has a policy that active awards (including projects in a no-cost extension period) must have a measurable level of effort. The NIH GPS states, “With the exception of grant programs that have an effort requirement, or where terms and conditions prohibit such reductions, NIH will not require prior approval for the reduction in effort for Senior/Key personnel named in the NOA. The recipient is reminded that active awards must have a measurable level of effort.” 
  • Update information as much as possible, e.g., remove outdated proposals or expired awards, unless specifically requested by sponsor, such as DoD.
  • For subawards to UWL, include only the total amount specific to the subaward requested or received by UWL. 
  • Include clinical trials. 
  • Include start-up funding provided by an organization other than UWL. 

Consulting

  • Include consulting agreements where the PI or senior/key personnel will be conducting research as part of the consulting activities must be reported.
  • If a consulting agreement will result in a co-authored publication, it may be considered research. 
  • Consulting may be outside of the scope of an individual’s UWL appointment, but may need to be included. See NIH FAQs B.4. and A.22. and the NSF Pre-award and Post-award Disclosures table.

In-kind Contributions

In-kind contributions should be reported per agency instructions. 

NIH 

  • If an in-kind contribution is not specific to the project being proposed but a resource available to the investigator, then it must be included as part of Other Support. 
  • If an in-kind contribution is intended for use on the project being proposed, it should be included in the Facilities and Other Resources or Equipment section. If included in the Facilities section, it does not need to be replicated on Other Support. 
  • For in-kind resources with no associated time commitment, individuals can list zero effort but must provide the estimated dollar value of the in-kind resource. The effort and dollar value cannot both be zero.
  • Information on high-value materials (e.g., data, samples) received from collaborators must be included in the in-kind contribution section of Other Support, including the source, a summary of the in-kind contribution, and the estimated value. Only resources uniquely available to the researcher must be reported. 
  • Institutional resources, such as core facilities or shared equipment that are made broadly available and will be used on the project being proposed, should not be included in Other Support, but rather listed under Facilities and Other Resources. 
  • For NIH Other Support documents, include an Investigator’s VA-funded activities.  
  • Do NOT include NIH proposals or projects for which the individual is an Other Significant Contributor. 

Refer to NIH Other Support information for more information. 

NSF 

  • If the in-kind contributions are not specific to the project/proposal but are available to the investigator and have an associated time commitment, the information must be included as part of the current and pending support section of the proposal. 
  • In-kind contributions with no associated time commitment that are intended for use on the project/proposal to NSF must be included as part of the Facilities, Equipment, and Other Resources section. These contributions do not need to be replicated in the individual’s Current and Pending Support submission. 

Refer to NSF Current & Pending Support for more information. 

  • Third party in-kind contributions are non-cash contributions from third parties external to the university. Instead of cash, the third party provides goods or services. This can include donated space, donated buildings or land, donated supplies, donated or loaned equipment, volunteer effort, or the paid effort of employees from an outside organization. 

Do Not Include

  • Do NOT include consulting agreements that involve non-research consulting activities. Consulting activities may need to be included in the Outside Activities Report. 
  • Do NOT include training awards, prizes, or gifts. Gifts are resources provided where there is no expectation of anything in return. Care must be taken to ensure that funds are appropriately categorized. 
  • Do NOT include fee-for-service agreements. 
  • Do NOT include internal departmental funds. 
Resources

Last updated: September 2025

Adapted with permission from UW-Madison