Funding Acknowledgements and Publication Reporting
Guidance regarding acknowledgement of grant support in publications and listing of publications in progress reports and renewal applications
Federal agencies require University researchers to acknowledge federal funding that supports work described in research publications. Federal agencies also require that University researchers list or include publications supported by federal funding in applicable federal agency progress reports.
The following guidance is intended to assist researchers with specific considerations in acknowledging grant support and listing publications, including with issues of over citation, acknowledgement of multiple awards, multiple authorship situations, and foreign funding support.
Grants
Avoiding over-citation in grant progress reports and renewal applications
Researchers must include publications supported by federal funding in annual and final progress reports. However, at times researchers will list a publication in progress reports or renewal applications in a way that implies that the publication was supported by federal funding, though federal funding did not actually support the publication. For example, researchers may list a particular publication in the “Products” section of a research progress report, even though the applicable federal funding did not support the work in the publication.
When this occurs (whether mistakenly or intentionally), researchers misrepresent the productivity of their federal award. Federal agencies receive inaccurate information regarding the productively of their funding, which impairs their ability to make decisions about future funding decisions. When submitting research progress reports or renewal applications, University researchers must ensure that they accurately list publications that were supported by federal funding.
Publications
Avoiding over-citation in publications
As described by NIH in an article on why it is important to acknowledge NIH support in publications, citation of support allows funding agencies to accurately assess award outputs and make decisions about future research directions. NIH has also reminded the research community to avoid improperly overciting grants that are unrelated with NIH research.
Grants should only be cited in a paper if:
- the grant directly supported the work described in the paper, and
- work described in the paper is clearly within the scope of the grant award.
Situation-based publication guidance
Researchers may sometimes cite multiple federal awards in the acknowledgements section of a publication, even though one or more of those awards did not directly support the work described in the paper, and the work described in the paper is not within the scope of the grant. When this happens, federal agencies receive inaccurate information regarding what research the agency’s grant funds are supporting. If a University researcher has more than one grant, the researcher should cite only the grants that supported the research described in the article or presentation. If citing multiple grants, the researcher should also be able to distinguish how each grant supported the work.
When there are multiple authors with separate funding sources on a publication, each author should acknowledge the funders and grants which provided direct support of the work.
Where a University researcher plans to acknowledge federal funding support and co-authors plan to acknowledge foreign funding support in a publication, some additional considerations may apply. As described in other University guidance and policy (reference International Appointments and Affiliations, Disclosures to Federal Research Sponsors, Foreign Talent Recruitment Programs Overview, and the Policy on Malign Foreign Talent Recruitment Programs and Foreign Talent Recruitment Programs), federal agencies are increasingly concerned with potential overlap, undisclosed foreign components of research, and prohibited “malign foreign talent recruitment programs.” For example, if budgetary items are already funded by a foreign source but are also requested in a University researcher’s federal funding proposal, then the researcher should make the federal agency award of this through Current and Pending (Other) Support disclosures to avoid budgetary overlap. Federal agencies also require prior approval of “foreign components” or “international activities” related to federally funded research.
University researchers should take care when participating in projects that will lead to the researcher’s acknowledgement of federal funding and a co-author’s acknowledgment of foreign funding support. In particular, it may be prudent to specify which authors did (and did not) receive federal funding and foreign funding. In addition, researchers should ensure that they have fully disclosed all Current and Pending (Other) Support to applicable federal agencies and have received prior approval of “foreign components” or “international activities” related to federally funded research. Researchers should also disclose their collaborators (including co-authors) in accordance with federal agency requirements. If the University researcher is funded by NASA, the researcher should be aware that NASA prohibits “bilateral activities” with institutions or entities in China. For more information, please review this NASA Prohibitions and Disclosures resource.
Occasionally, University researchers will receive research funding from foreign sources. It is critical that if the researcher has other federally funded projects, that the researcher disclose the foreign funding support as Current and Pending (Other) Support and make any related disclosures accordance with the Policy on Faculty Conflict of Commitment and Interest reporting procedures. With respect to foreign funding in particular, federal agencies may be concerned that such funding may be part of a “malign foreign talent recruitment program” or “foreign talent recruitment program”, that the funding may lead to undisclosed conflicts of commitment or interest, undisclosed affiliations, or undisclosed Current and Pending (Other) Support, or may lead to overlap with other federally funded research.
Where a University researcher plans to acknowledge foreign funding support in a publication, the researcher should ensure the following:
- The award directly supported the work described in the paper, and the work described in the paper is clearly within the scope of the award;
- The researcher has previously disclosed the foreign funding support as Current and Pending (Other) Support to applicable federal agencies;
- The researcher has received prior approval by the University for any appointments or affiliations that relate to the foreign funding support, has disclosed any appointments or affiliations that relate to the foreign funding support in their Biographical Sketch submitted to federal agencies, and has disclosed the appointments or affiliations in accordance with the Policy on Faculty Conflict of Commitment and Interest reporting procedures;
- The researcher has previously disclosed any applicable financial interests related to the foreign funding support to the University in accordance with the Policy on Faculty Conflict of Commitment and Interest.
- If the foreign funding support also relates a federal award, the researcher has received prior approval by applicable federal agencies for any “foreign component” or “international activities” related to the federally funded research.
Situations where a University researcher should acknowledge both foreign funding support and federal support in a publication should be rare. Unless the federal agency has prior knowledge of the foreign funding support, the agency will likely be concerned that the federally funded award inappropriately overlaps with the foreign funding support or that federal and foreign funds are being comingled.
In these cases, it must be clear that both awards directly supported the work described in the paper, and the work described in the paper is clearly within the scope of both awards. If this is the case, it is possible that the federally funded award inappropriately overlaps with the foreign funding support, or that the University researcher did not fully disclose the foreign funding support as Current and Pending (Other) Support to applicable federal agencies.
In these cases, researchers should ensure that they have followed steps (1) – (5) described above, and have ensured that each award supported the work described in the publication in a distinct manner.
There are times where a University researcher is named as an author of a publication and does not acknowledge any funding support, and where the researcher’s co-authors acknowledge foreign funding support. In these cases, federal funding agencies may potentially conclude that the University researcher is supported by the foreign funding sources cited by the co-authors. If this is the case, the University researcher should ensure that they have disclosed the foreign funding support as Current and Pending (Other) Support to applicable federal agencies. If the University researcher is not supported by the foreign funding, then to avoid this potential misunderstanding, researchers should consider including the following in the acknowledgements section of these publications:
[Name of University Researcher] was not financially supported by the awards acknowledged by the other author(s) of this publication.