Disclosure of Other Support – Federal Sponsor Requirements

1. Policy

Issued: October 8, 2025 
Last Revised:  N/A 
Last Reviewed: N/A 

Applies to: Faculty (including part-time and visiting faculty), postdoctoral scholars, staff and students (including graduate/undergraduate student workers and graduate assistants) employed by University of Southern California and its subsidiaries including Keck Medicine of USC (“USC employees”).  This policy continues to apply to individuals on sabbatical, other leaves or while visiting other institutions.  

2. Policy Purpose

This policy ensures that the University of Southern California (USC) complies with all federal funding agency requirements for disclosure of Other Support and Current and Pending Support by individuals engaged in federally sponsored research. The policy promotes transparency, research integrity, and protection of the federal research enterprise, as required under:

3. Scope

​​This policy applies to: 

• ​All USC faculty, staff, postdoctoral scholars, and trainees who are identified as Senior/Key Personnel (or equivalent) on proposals, progress reports, or other sponsor submissions to any federal agency. 

• ​Subrecipient investigators under federally sponsored projects administered by USC.​ 

4. Definitions

Term	Definition
Other Support and Current and Pending Support	All resources—financial or in-kind—available in direct support of an individual’s research endeavors, regardless of: Monetary value. Whether provided through USC or another institution. Whether the activity is domestic or foreign. Includes: Sponsored research funding (active and pending) from all sources. In-kind contributions (equipment, supplies, personnel, lab space). Outside consulting involving research or related activities. Visiting scholar or honorary/adjunct appointments. Participation in foreign talent recruitment programs.
Senior/Key Personnel	Individuals who make significant, measurable contributions to the scientific or technical execution of a project, such as the Principal Investigator (PI), Co-PIs, and Co-Investigators.

5. Policy Details

​​Disclosure Requirement – All Senior/Key Personnel must fully disclose Other Support and Current and Pending Support to the relevant federal sponsor at proposal submission, just-in-time request, progress report, or other sponsor-specified intervals. 

​Sponsor-Specific Requirements – Sponsors may have additional requirements so Senior/Key Personnel should also refer to specific proposal and award documents. 

​Foreign Engagement Review – Senior/Key Personnel must disclose all foreign research collaborations, appointments, or support to research sponsors.  Foreign appointments and financial interests must also be disclosed to USC and reviewed for compliance with U.S. research security requirements (e.g., NSPM-33 Guidance) as necessary. 

​Certification – If required by the sponsor, each submission must be signed and dated by the Senior/Key Personnel, certifying that the information is true, complete, and accurate. 

​Updates and Corrections – Any undisclosed Other Support or Current and Pending Support identified after submission must be reported to the Department of Contracts and Grants immediately for correction with the sponsor. 

​Failure to comply with this policy may result in: 

​• Delay, reduction, or termination of funding. 

​• Required sponsor reporting of non-compliance. 

​• Disciplinary action under USC Faculty Handbook or Staff Employment Policies.​ 

6. Procedures

​​National Institutes of Health (NIH) Grants Policy Statement 

​National Science Foundation Proposal & Award Policies & Procedures Guide (PAPPG) 

​International Collaborations and Disclosure Requirements​ 

7. Forms

N/A

8. Responsibilities

POSITION or OFFICE	RESPONSIBILITIES
Investigators	Identify and disclose all active and pending support and in-kind contributions.
Department Administrators	Assist in preparing accurate and complete disclosures.
Department of Contracts and Grants	Review and submit disclosures in the sponsor-required format.
Office of Ethics and Compliance	Monitor compliance, provide training, and manage corrective actions for non-compliance.

9. Related Information

​​Department of Energy Order 486.1A 

​National Institutes of Health (NIH) Grants Policy Statement 

​National Science Foundation Proposal & Award Policies & Procedures Guide (PAPPG) 

​USC Financial Conflict of Interest in Research Policy 

​USC International Collaborations and Disclosure Requirements​ 

10. Contacts

Please direct any questions regarding this policy to: 

OFFICE	PHONE	EMAIL
Office of Ethics and Compliance	(213) 740-8258	Compliance@usc.edu