Disclosure Requirements and Standardization

Purdue employees involved in federally funded research are required to complete and maintain up-to-date disclosures to both the University and to federal sponsors.

• Disclosures to the University. Submit and seek approval from the University, as necessary, prior to engaging in activities requiring disclosure to the University. Learn about Purdue disclosure requirements on these sites: Reportable Outside Activities and Conflict of Interest.

• Disclosures to Federal Sponsors. Submit reports for all research-related resources (i.e., Current and Pending/Other Support), outside activities, and potential conflicts of interest or commitment. Refer to the NSPM-33 Disclosure Table for federal guidance, and visit Sponsored Program Services for agency specific requirements.

The federal government has developed Common Forms for federal disclosures. Please carefully review the new NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Table. The table includes the types of activities to be reported, where such activities must be reported in the application, as well as when updates are required in the application and award lifecycle. A final column identifies activities that are not required to be reported.

While there are now Common Forms available, please keep in mind that each federal agency can set its own standards for disclosure based on the sensitivity of the research. It is important to also carefully review proposal and award requirements.

For additional information on your responsibilities, please visit the Sponsored Program Services page for detailed guidance.

Consequences for Violating Disclosure Requirements

Federal agencies are required by federal statute to conduct advanced monitoring and verification of activities related to research security. If a program officer observes an inconsistency in disclosure information or observes unreported open-source activities (such as co-authorships, foreign funding, etc), then they must notify the appropriate authority in their agency. If a concern with waste, fraud and/or abuse is identified, then the agency’s Inspector General is notified. Misrepresentations and/or omissions may be subject to prosecution and liability pursuant to, but not limited to, 18 U.S.C. §§ 287, 1001, 1031 and 31 U.S.C. §§ 3729-3733 and 3802.