Disclosure Requirements for Outside Activities

All UO employees should disclose and seek prior approval for affiliations, collaborations, honorific titles, professional service, or other engagement with foreign organizations, companies, or institutions as required by the Conflict of Interest, Conflict of Commitment, and Outside Activities Policy, regardless of whether those activities are paid or unpaid.

Disclosures are submitted through the Research Administration Portal (link prompts you to enter your Duck ID), and the conflicts of interest team works with export controls to conduct compliance checks on foreign entities listed in disclosures.

If you are unsure whether you need to disclose an activity, we encourage you to submit a disclosure so that the conflicts of interest team and export controls can work together to complete a compliance check for the foreign entity.

Questions regarding the disclosure of outside activities should be directed to coi@uoregon.edu.

Disclosure Requirements for Researchers with Federal Funding

Researchers applying for federal funding need to disclose all foreign support and collaborations they are currently receiving or anticipate receiving at the time of their proposal submission. This includes support that may be unpaid or non-monetary, such as honorific titles or volunteer service.

Most frequently, this disclosure is done through a biosketch or a current and pending support document, although requirements vary by funding agency. Principal investigators (PIs), co-PIs, and key personnel should review any pending proposals and active awards to ensure that all foreign components have been fully disclosed in conformance with the specific federal sponsor’s guidelines.

If sponsored research results in a publication involving foreign components (such as a co-authorship at a foreign institution), some agencies, including the National Institutes of Health, require that those components also be reported in annual and final progress reports.

Always be sure to appropriately credit all foreign collaborators and funding sources in publications. Authors should ensure that information about the institutional affiliations in publications is accurate and complete, as funding agencies are increasingly checking this information against what's provided in a proposal. Both funding agencies and journals provide guidelines for information to be included in publications.

Any PI who identifies an omission or error in any disclosure, including international collaboration in a previously submitted proposal, should contact Sponsored Projects Services (SPS) to have the error corrected with the sponsor. In addition, researchers involved in international collaborations should determine if sponsor approval is required to perform the research.

In addition to disclosing foreign collaboration and support, PIs must also report to Industry, Innovation, and Translation (IIT) all innovations prior to publication to ensure that the federal government receives a non-exclusive license to use the innovation.

Working with foreign entities without properly scoping intellectual property rights can result in a PI losing:

• Access to use intellectual property needed for their future research
• The ability to obtain intellectual property rights in their work
• The ability to provide rights to intellectual property granted by the PI and university to a sponsor

Under the UO's Financial Conflict of Interest in Research Policy, those responsible for the design, conduct, or reporting of sponsored activity are required to submit a disclosure of Significant Financial Interests (SFIs):

• Annually
• Within 30 days of acquiring a new SFI
• Within 30 days of a change to a previously reported activity that now meets the threshold of an SFI

Disclosures are submitted using the Research Administration Portal (link prompts you to enter your Duck ID). In order to submit a proposal to a sponsor, researchers must have a disclosure that has been submitted to the UO in the previous 365 days.