External Activities Disclosure

CLOSED:

The External Activities Disclosure (EAD) survey was closed 1/31/2024.  The Huron Conflicts of Interest (COI) solution in ResearchUVA (RUVA) allows investigators to make all required disclosures to the VPR's office in a single process.  A gradual rollout is planned; however, if you need to update information previously submitted via the EAD survey, email Ask_RCOI@virginia.edu to request access.  

 

 

Requirement

The Office of the Vice President for Research (OVPR) has determined that by December 1, 2021, all UVA "investigators," as defined in RES-005, Financial Conflicts of Interest for Research Investigators, must submit an External Activities Disclosure and complete the Undue Foreign Influence: Risks and Mitigations course. These new requirements supplement and do not replace other institutional and sponsor requirements. The new disclosure targets areas of heightened concern by federal sponsors and elements of recent enforcement actions against members of the academic community; your responses will allow the VPR's office to provide more tailored guidance and help fulfill our oversight/management obligations on to research sponsors. 

New "investigators" are strongly encouraged to complete the disclosure before submitting a proposal; however, all investigators named on an award must have completed their required disclosures before an award will be processed by the Office of Sponsored Programs. 

These requirement are issued pursuant to University policy RES-011, Investigator Eligibility Requirements and Responsibilities Related to Sponsored Programs. Compliance will be assessed for new proposals submitted and awards received on or after January 1, 2022

Background

The federal government continues to be concerned about undue foreign influence on research and the security of research data, including the results of fundamental research, more broadly.  As we have shared with you previously, this has led many federal research sponsors (e.g., NSF, NIH, and DOE) to expand or clarify their disclosure requirements. Investigator disclosures, whether direct (i.e., as part of a proposal or report) or indirect (i.e., through institutional processes) are required by sponsors:

  • to protect the integrity of the supported research.
  • to inform funding decisions by
    • identifying and preventing overlap in scientific or budgetary scope (double dipping); and
    • prioritizing funding to individuals with the necessary resources and available capacity (considering commitments to the applicant institution and other entities); and  
  • to ensure that the United States receives the benefits from its investment in research.

Similarly, federal sponsor expect and require that institutions review and, when necessary, manage conflicts of interest or commitment that arise in relation to an investigator's institutional responsibilities, including those related to research.

Although federal sponsors are principally concerned with impacts on federally-funded research our commitment to the research integrity/ethical principles and values that are the foundation for trust in the research enterprise does not change depending on the source of funding or area of study. For this reason, the VPR's requirement applies regardless of whether or not an individual investigator receives federal funding for research.

Recently, the research community has seen an increase in federal investigations and criminal prosecutions of researchers (see, Enforcement and In the News). A common element in these cases has been the researcher being charged with fraud (e.g., grant fraud or wire fraud) for failing to make required disclosures (e.g., regarding foreign academic/professional appointments, sources of research support, and/or participation in a foreign government talent recruitment program) to their U.S. employer or a federal sponsor. Federal fraud charges can be filed for non-compliance with institutional disclosure requirements if it leads the institution to make a false statement to a federal agency.

Historical Content

Submit:

External Activities Disclosure (behind NetBadge). We are using a Qualtrics survey to collect this information while we work to develop a consolidated process for disclosing both external activities and significant financial interests.

If you would like a pdf copy of your submitted External Activities Disclosure(s), email the Office of the Vice President for Research at foreigninfluence@virginia.edu.

Updates:

We encourage investigators to update their External Activities Disclosure on an as needed basis by simply using the original submission link, above, to make a new disclosure.  This will create a new disclosure record without altering any prior submission(s).