New Global Activities eDisclosure Requirement
As referenced in Provost Woodruff’s letter and the attached policies distributed on January 11, 2021, to Faculty and Academic staff, this email shares the new non-domestic disclosure requirement for faculty and academic staff that serve as principal investigators and key personnel on sponsored programs, whether or not they have global activities.
To: Faculty and Academic Staff
Deans, Directors and Chairpersons
From: Teresa K. Woodruff, Ph.D., Provost and Executive Vice President for Academic Affairs, MSU Foundation Professor
Douglas A. Gage, Ph.D., Interim Vice President for Research & Innovation
Subject: New disclosure requirement for principal investigators and key personnel, whether or not they have global activities, due March 8, 2021
MSU is an inclusive place of learning that welcomes and promotes international scholarship, partnerships, and exchanges. An essential, common element of scholarship, partnership, and respectful exchanges is candor, a virtue that is also required in extramural funding agreements. Undisclosed working relationships between scholars in US institutions and non-domestic entities (e.g., universities, companies, and governments) have increasingly been a concern of federal agencies. In its absence, legitimate concerns arise over risk to objectivity of research, overcommitment of investigators relative to federal obligations, loss of U.S. intellectual property and attribution, and trade sanctions or export control violations. The message from federal agencies is that investigators in U.S. labs must disclose activities supported by non-domestic entities in grant applications and during awards. More description and resources from federal agencies are provided in the Information section of the attached memo.
MSU has long had policies requiring approvals/disclosures through the Outside Work for Pay, Dual Appointments, and Conflict of Interest Policies. MSU is committed to complying with federal requirements, and we are working to reduce the legal risk and potential sanctions to our research members and to the university research enterprise. To support faculty in the required federal funding agency disclosures and to assist faculty in addressing any potential conflicts, the Office of Research & Innovation has developed the Global Activities e-Disclosure (GAED) web-based form to supplement other required disclosures. Some of the information provided on the form will overlap with other disclosures and processes. In the long-term, we anticipate combining and/or increasing the alignment of different disclosures, but because of the immediacy and intensity of the agencies’ expectations, we are instituting the GAED form now. The GAED Form will ask if principal investigators, co-investigators, and key personnel (as defined by sponsor) have any current or pending, compensated or uncompensated collaborations, appointments, affiliations, or resources with or from any non-domestic entities. Generally for Federal sponsors, the responses are in the context of identifying activities and resources related to or supporting an investigator’s research endeavors. If the response is yes, additional fields must be completed to identify those global activities.
Responses will help MSU understand the scope of interactions with non-domestic entities and what assistance is needed to enable compliance with university and federal agency requirements. Submission of the GAED form by principal investigators, co-investigators, and key personnel will be required for proposal submission to federal agencies sometime in the future. We encourage initial completion of the Form by March 8, 2021. The GAED Form can be accessed at: Global Activities e-Disclosure (log-in to the MSU system is required). Directions for completing the form are provided at: Completing the Global Activities e-Disclosure. The University acknowledges the sensitivity of some personal information to be disclosed via the GAED. MSU will not publicly disclose GAED responses outside MSU when there exists neither a legal duty to disclose nor a significant public interest in public disclosure.
Questions on various types of disclosures can be addressed by contacting the responsible office on the chart of commonly required disclosures for sponsored programs. Questions on the GAED Form can be directed to:
- Brian Mattes, Faculty Conflict of Interest Officer, Faculty Conflict of Interest Office, at firstname.lastname@example.org
- Laura Johnston, Asst. Director, Office of Sponsored Programs, at email@example.com
- Katie Cook, Director, Office of Sponsored Programs, at firstname.lastname@example.org
- Joseph R. Haywood, Asst. VP for Regulatory Affairs, Office of Regulatory Affairs, at email@example.com
- Twila Reighley, Asst. VP for Research & Innovation, Sponsored Programs Administration, at firstname.lastname@example.org
Additional information including the initial GAED question, footnotes, resources and a summary of Federal information are provided in the attachment.
Our thanks to each of you, in advance, for your prompt attention to this important disclosure.