New guidance about required disclosures by faculty and other researchers

Case Western Reserve University strongly urges its faculty and other researchers to include all outside activities in their annual Outside Financial Interest Disclosures to the university and in grant application and reporting forms to U.S. federal agencies. This includes any appointments or affiliations with foreign entities, such as “talent programs,” as well as consulting and other work performed outside of their CWRU employment.

This guidance is not an expansion of current implementation of CWRU’s Conflict of Interests policy. As a result of increased congressional attention to possible foreign interference in U.S. research programs by malevolent actors, the National Institutes of Health has clarified that they expect applicants and awardees to disclose all forms of other support and financial interests. This includes support coming from foreign governments (which includes local, provincial, or equivalent governments of another country) or other foreign entities (including foreign institutions of higher education).

As a result, the university is responsible for ensuring that this information is included in all U.S. federal grant applications or reporting materials that include requests for any sources of research support, financial interests and relevant affiliations by CWRU personnel.

While the National Institutes of Health is the first to document such a request in Notice Number NOT-OD-18-160 and in a letter from Francis Collins to grant recipient institutions dated Aug. 20, it is widely expected that other grant-making U.S. federal agencies will follow suit.

Those who have questions or concerns about this guidance can reach out to Stephanie Endy at