Learn about disclosures that must be to federal research sponsors as part of research security.<\/p>\n
Federal sponsors currently have varying requirements for the \u201cCurrent and Pending (Other) Support\u201d and \u201cBiographical Sketch\u201d disclosures. Beginning May 2024, NSF has adopted new \u201cCommon Disclosure Forms\u201d for \u201cCurrent and Pending (Other) Support\u201d and \u201cBiographical Sketch.\u201d 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\u2019s Common Disclosure Form guidance<\/a>.<\/p>\n 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.<\/p>\n <\/p>\n","protected":false},"excerpt":{"rendered":" Learn about disclosures that must be to federal research sponsors as part of research security. Overview Federal sponsors currently have varying requirements for the \u201cCurrent and Pending (Other) Support\u201d and…<\/p>\n","protected":false},"author":76,"featured_media":0,"parent":3312,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"footnotes":"","_members_access_role":[],"_members_access_error":""},"class_list":["post-10362","page","type-page","status-publish","hentry"],"acf":{"lead_in":"","display_title":"","subtitle":"Current as of April 15, 2024","call_to_action":"","hero_image_placement":"no_image","hero_media":"images","hero_pattern_option":"","hero_video":"","hero_image_landing":"","hero_image_landing_two":"","hero_image_landing_three":"","content_modules":[{"acf_fc_layout":"text","anchor":"","css_class":"","title":"Current and Pending (Other) Support Information<\/h2>","content":"Federal sponsors have expressed increasing concern over full and complete disclosure of all applicable \u201cCurrent and Pending (Other) Support.\u201d 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 \u201cCurrent and Pending (Other) Support.\u201d \u201cCurrent and Pending (Other) Support\u201d can come in many forms, such as resources and financial support, both domestic and foreign. University researchers should ensure they disclose all applicable \u201cCurrent and Pending (Other) Support\u201d as required by federal sponsors.\r\n\r\nAs discussed further in\u00a0this University guidance<\/strong><\/a>, 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 \u201cmalign foreign talent recruitment program.\u201d Nevertheless, researchers should disclose whether they are party to any type of foreign talent program in \u201cCurrent and Pending (Other) Support.\u201d Likewise, support provided in connection with an appointment or affiliation at a foreign institution should be disclosed in \u201cCurrent and Pending (Other) Support.\u201d\r\n\r\nThe National Institutes of Health (NIH) requires<\/a> (1) supporting documentation, which includes copies of contracts\/agreements specific to senior\/key-personnel foreign appointments and\/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support, and (2) immediate notification to NIH of undisclosed Other Support.\r\n\r\nEffective October 10, 2025, the National Science Foundation (NSF) requires that proposers and recipients maintain supporting documentation, including copies of contracts, grants, or any other agreements specific to foreign appointments, employment with a foreign institution, participation in a foreign talent recruitment program and other information reported as current and pending (other) support for all senior\/key personnel that must be available to NSF upon request.\r\n\r\nFor more information on \u201cCurrent and Pending (Other) Support\u201d requirements,\u00a0please review this compilation of requirements<\/strong><\/a>.","background_color":"#f4f4f4","width":"width-medium"},{"acf_fc_layout":"text","anchor":"","css_class":"","title":"
Biographical Sketches<\/h2>","content":"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).\r\n\r\nThough 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 \u201cmalign foreign talent recruitment program,\u201d researchers should disclose whether they are party to any type of foreign talent program<\/strong> in their Biographical Sketch. In addition, appointments or affiliations at foreign institutions should be disclosed in the Biographical Sketch.","background_color":"#ffffff","width":"width-medium"},{"acf_fc_layout":"text","anchor":"","css_class":"","title":"
Foreign Components of Research<\/h2>","content":"Foreign components of federally funded research should be disclosed on proposals, progress reports, and final technical reports.\r\n\r\nUnder the NIH Grants Policy Statement, a Foreign Component is defined as \u201cany 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<\/strong>.\u201d 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 \u201cforeign component\u201d of the research.\r\n\r\nNSF requires that applicants list planned \u201cinternational activities\u201d (defined as \u201cresearch, training, and\/or education carried out in cooperation with foreign counterparts either overseas or in the U.S. using virtual technologies\u201d) for proposed projects. For more information, ORPA has issued guidance regarding foreign component disclosure matters<\/a>.\r\n\r\nFederal 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<\/a>. Information on when to report current\/pending support for the University of Rochester\u2019s 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.","background_color":"#f4f4f4","width":"width-medium"},{"acf_fc_layout":"accordion_new","anchor_id":"","classes":"","title":"
When to Report Current and Pending (Other) Support<\/h2>","description":"","background":"plain","background_color":"#ffffff","style":"row_blank","expand":"yes","accordions":[{"acf_fc_layout":"accordion","accordion_title":"NIH reporting","icon":"","row_content":"