Common Disclosure Forms
Beginning May 20, 2024, each person identified as a senior/key person on NSF funded research projects are required to use new “Common Disclosure Forms” for “Current and Pending (Other) Support Information” and “Biographical Sketch.” In an effort to harmonize disclosure requirements, other federal agencies are expected to adopt the common disclosure forms over time.
The new common forms and related definitions are available on NSF’s website.
A table entitled NSTC Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support has been created to provide helpful reference information regarding pre-award and post-award disclosures.
Malign Foreign Talent Recruitment Program
Both common forms require each senior/key person to certify that they do not participate in a Malign Foreign Talent Recruitment Program. If you have questions about whether a program you are currently participating in or are considering participating in what could be considered a malign foreign talent recruitment program, review this guidance, and please contact your Dean, Research Dean, ORPA, or the University’s Research Security Officer (joe.doyle@rochester.edu) to discuss the program further.
“Current and Pending (Other) Support”
To assess issues including the researcher’s capacity to carry out proposed research efforts, any conflicts of commitment, and any potential scientific and budgetary overlap/duplication with the project being proposed, each senior/key person must disclose all “Current and Pending (Other) Support”. A separate submission must be provided for each proposal and active project.
Current and Pending (Other) Support includes:
All resources made available, or expected to be made available, to an individual in support of the individual’s research and development efforts, regardless of (i) whether the source is foreign or domestic; (ii) whether the resource is made available through the entity applying for a research and development award or directly to the individual; or (iii) whether the resource has monetary value; and (b) includes in-kind contributions requiring a commitment of time and directly supporting the individual’s research and development efforts, such as the provision of office or laboratory space, equipment, supplies, employees, or students. This term has the same meaning as the term Other Support as applied to researchers in NSPM-33. For researchers, Other Support includes all resources made available to a researcher in support of and/or related to all of their professional R&D efforts, including resources provided directly to the individual rather than through the research organization, and regardless of whether or not they have monetary value (e.g., even if the support received is only in-kind, such as office/laboratory space, equipment, supplies, or employees). This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and participation of student and visiting researchers supported by other sources of funding.
Consulting activities must be disclosed when: (i) the consulting activity will require the senior/key person to perform research as part of the consulting activity; (ii) the consulting activity does not involve performing research, but is related to the senior/key person’s research portfolio and may have the ability to impact funding, alter time or effort commitments, or otherwise impact scientific integrity; or (iii) the consulting entity has provided a contract that requires the senior/key person to conceal or withhold confidential financial or other ties between the senior/key person and the entity, irrespective of the duration of the engagement.
In-kind contributions with an estimated dollar value of $5,000 or more, not intended for use on the project being proposed, and have an associated time commitment must also be disclosed under “Current and Pending (Other) Support.”
Postdoctoral scholars, students, or visiting scholars who are supported by an external entity, whose research activities are not intended for use on the project/proposal being proposed and have an associated time commitment must be disclosed under Current and Pending (Other) Support.
Travel supported/paid by an external entity to perform research activities with an associated time commitment must be disclosed under Current and Pending (Other) Support. Travel supported/paid by an external entity to attend a conference or workshop does not require disclosure.
Biographical Sketches
The Biographical Sketch is used to assess how well qualified the individual, team, or organization is to conduct the proposed activities. As part of the grant or contract proposal package, funding agencies require that each senior/key person disclose all academic, professional, or institutional appointments and positions. Appointments and positions include any titled academic, professional, or institutional position whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
Senior/key persons must only identify all domestic and foreign professional appointments and positions outside of the University of Rochester for a period up to three years from the date the applicant submits the application to the agency for funding consideration.
Facilities, Equipment & Other Resources
Postdoctoral scholars, students, or visiting scholars who are supported by an external entity, and whose research activities are intended for use on the project/proposal being proposed, must be disclosed under “Facilities, Equipment & Other Resources.” In-kind contributions with an estimated dollar value of $5,000 or more that support the research activity for use on the project/proposal being proposed must also be disclosed under “Facilities, Equipment & Other Resources.”
For questions regarding any of these disclosure requirements, please contact your ORPA Research Administrator.