Disclosures to Federal Research Sponsors

Current as of April 15, 2024

Learn about disclosures that must be to federal research sponsors as part of research security.

Overview

Federal sponsors currently have varying requirements for the “Current and Pending (Other) Support” and “Biographical Sketch” disclosures. Beginning May 2024, NSF has adopted new “Common Disclosure Forms” for “Current and Pending (Other) Support” and “Biographical Sketch.” Other federal agencies are expected to adopt the Common Disclosure Forms over time. For more information on the Common Disclosure Form requirements, please review the University’s Common Disclosure Form guidance.

The following is intended to provide general guidance to researchers and departments regarding disclosures that support research security. For more specific agency requirements, researchers should consult the resources identified below, or contact their ORPA Research Administrator.

Current and Pending (Other) Support Information

Federal sponsors have expressed increasing concern over full and complete disclosure of all applicable “Current and Pending (Other) Support.” Such disclosures assist federal agencies in identifying potential financial conflicts of interest, and may help prevent scientific, budgetary, or commitment overlap. Federal sponsors currently have varying requirements for the reporting of “Current and Pending (Other) Support.” “Current and Pending (Other) Support” can come in many forms, such as resources and financial support, both domestic and foreign. University researchers should ensure they disclose all applicable “Current and Pending (Other) Support” as required by federal sponsors.

As discussed further in this University guidance, the CHIPS and Science Act of 2022 prohibits research and development awards from being made for any proposal in which a covered individual is participating in a “malign foreign talent recruitment program.” Nevertheless, researchers should disclose whether they are party to any type of foreign talent program in “Current and Pending (Other) Support.” Likewise, support provided in connection with an appointment or affiliation at a foreign institution should be disclosed in “Current and Pending (Other) Support.”

For more information on “Current and Pending (Other) Support” requirements, please review this compilation of requirements.

Biographical Sketches

Federal sponsors also currently have varying requirements regarding Biographical Sketch disclosures. Generally, individuals must disclose current positions and scientific appointments both domestic and foreign, including affiliations with foreign entities or governments. This includes titled academic,professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

Though the CHIPS and Science Act of 2022 prohibits research and development awards from being made for any proposal in which a covered individual is participating in a “malign foreign talent recruitment program,” researchers should disclose whether they are party to any type of foreign talent program in their Biographical Sketch. In addition, appointments or affiliations at foreign institutions should be disclosed in the Biographical Sketch.

Foreign Components of Research

Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports.

Under the NIH Grants Policy Statement, a Foreign Component is defined as “any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.” For example, if a researcher has a collaboration with investigators at a foreign institution that is anticipated to result in co-authorship, if the researcher uses the facilities or instrumentation of a foreign institution for grant related activities, or if the researcher receives financial support or resources from a foreign institution for grant related activities, this may require prior approval from NIH as a “foreign component” of the research.

NSF requires that applicants list planned “international activities” (defined as “research, training, and/or education carried out in cooperation with foreign counterparts either overseas or in the U.S. using virtual technologies”) for proposed projects. For more information, ORPA has issued guidance regarding foreign component disclosure matters.

Federal agencies differ with respect to the reporting and updating of current/pending support, biographical sketches and foreign components. It is expected that in time agencies will align to the NSTC Pre-Award and Post-Award Disclosures. Information on when to report current/pending support for the University of Rochester’s major sponsors (NIH and NSF) is included below. Please contact your ORPA Research Administrator for information on reporting or updating this information for other sponsors.

When to Report Current and Pending (Other) Support

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NIH reporting

Just-in-Time (upon request by NIH after proposal submission but prior to award);
After Just-in-Time but prior to receipt of award (reporting required only if changes are substantive* in nature; consult ORPA if you are uncertain);
Via Prior Approval Request for substantive* changes that occur during the award period but prior to the due date of the next Research Performance Progress Report (annual progress report);
Research Performance Progress Report – report changes only; and
Upon request by NIH.

*While NIH does not define “substantive,” the concept is that the change is of a magnitude that NIH might prudently need to review the new arrangements to ascertain whether the existence, timing or the amount of NIH’s award might need to change in light of the new information (e.g. substantive new support that alters the reporting investigators availability or where a prudent person might question whether there is scientific or financial overlap).

NSF reporting

At proposal submission;
Just-In-Time (upon request by NSF after proposal submission but prior to award);
After Just-in-Time but prior to receipt of award by accessing the proposal within Research.gov;
Research Performance Progress Reports – report changes only; and
Upon request by NSF.

In addition, if the University discovers that a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process, ORPA must submit the information specified in the applicable general term and condition article entitled, “Post-award Disclosure of Current Support and In-kind Contribution Information” within 30 calendar days of the identification of the undisclosed current support or in-kind contribution through use of the Notification and Request Module in Research.gov.

Learn about disclosures that must be made to the University of Rochester as part of research security.

Internal disclosure requirements