NASA, NSF and Other Non-PHS Federal Financial Disclosure

Applicants to the National Science Foundation or to NASA for Assistance (grants or cooperative agreements) must disclose project-related financial interests for themselves and all other project investigators at the proposal submission stage. This requirement also applies to subawards, to other federal non-PHS agencies, and to other agencies that have adopted the NSF requirements (e.g., UCOP Research Programs: CBCRP, CHRP, TRDRP; the California Institute for Regenerative Medicine, U.S. Environmental Protection Agency).

Proposal Stage

At the proposal stage, investigators must fill out Conflict of Interest screening questions in Phoebe Proposal.

If disclosure is required but the screening questions are not available in Phoebe, contact your Sponsored Projects Office (SPO) Contract and Grant Officer (CGO). Your CGO will provide you with a Non-PHS Financial Interest Screening Questions Form. You will need to complete the Non-PHS Financial Interest Screening Questions Form and upload it in Phoebe.

Note: If an investigator provides any “yes” responses to the screening questions, the investigator will be required to complete the Non-PHS Financial Disclosure Form and upload it into Phoebe with the proposal.

Subrecipients: If subrecipients are included in your proposal, see the SPO subrecipient commitment form instructions for conflict of interest requirements. Note: A subaward cannot be issued to a subrecipient that does not have a non-PHS compliant COI policy in place.

During Life of Award

Investigators must disclose new Significant Financial Interests as they are acquired by submitting a Non-PHS Financial Disclosure Form by email to their SPO CGO.


NOTE: Please use Adobe Acrobat or Reader to fill out PDF forms. (If you have difficulty filling out the form, please download the form to a local computer before filling it out.)



Related information