Clarifying guidance from NSF about disclosing current and pending support, biographical sketches, and foreign partnerships.
Over the last few years, the FBI and federal lawmakers have raised concerns regarding undue foreign influence on federally funded research. As a result, many federal funding agencies, including the National Science Foundation (NSF), are revisiting what information they require from investigators to appropriately assess other sources of support. As part of this effort, NSF included updated requirements in the annual release of the Proposal & Award Policies & Procedures Guide (PAPPG), expected to be implemented effective June 1, 2020. This clarifying guidance from NSF outlines requirements that differ from what was previously understood to be required of applicants and awardees. A summary of these current NSF requirements follows.
A summary of NSF’s current requirements as of June 2021 is available in the NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support table on the NSF site.
Disclosing Current & Pending Support
NSF policy now requires applicants and awardees to disclose “all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value. Current and pending support also includes in-kind contributions (such as office/laboratory space, equipment, supplies, employees, students). In-kind contributions not intended for use on the project/proposal being proposed also must be reported. Current and pending support information must be provided for this project, for ongoing projects, and for any proposals currently under consideration from whatever source, irrespective of whether such support is provided through the proposing organization or is provided directly to the individual.”
With this clarification, NSF researchers are now required to disclose within their Current & Pending document as follows;
- Financial Support. This includes sponsored awards held at Cornell, held at another institution/entity, or held as an individual that support an investigator’s research efforts. This also includes start-up packages from entities other than Cornell. Investigators do not need to disclose Cornell start-up packages or gifts.
- In-kind contributions. This includes non-monetary resources that are uniquely available to key personnel such as office/laboratory space, equipment, supplies, employees, students. The location of the disclosure of in-kind contributions within the proposal depends upon whether there is a time commitment associated and if the contribution is to be used for the proposal being submitted (see chart below). Such disclosures do not need to be replicated across proposal documents.
|Intended for use on the project being proposed to NSF||Not intended for use on the project being proposed to NSF|
|In-kind item or service received with an associated time commitment||Facilities, Equipment, and Other Resources||Current & Pending|
|In-kind item or service received without an associated time commitment||Facilities, Equipment, and Other Resources||Not required to be reported to NSF|
NSF policy remains consistent regarding location and timing of such disclosures, and all current and pending support must be reported within the proposal.
Additionally, concurrent with the implementation of the updated PAPPG on June 1, 2020, all Current & Pending documents must be submitted through the use of an NSF-approved format, namely SciENcv and a NSF fillable PDF.
Effective October 5, 2020, the National Science Foundation (NSF) standard terms and conditions establishes a post-award disclosure requirement for undisclosed current support and in-kind contribution information. Therefore, as of this date if Cornell discovers that a PI or Co-PI on an active NSF award failed to disclose current support or in-kind contributions within their proposal, OSP must submit a notice to NSF informing them of the undisclosed support or contribution within 30 days of identification of the oversight by Cornell. NSF will review the disclosure and, after possible consultation with OSP, determine the impact of the new information on the award and, where necessary, take appropriate action.
Researchers and research administrators are encouraged to review submitted current and pending documents to ensure that all required disclosures have been made. In the event current support or in-kind contributions not previously disclosed to NSF are identified, please notify your assigned Grant & Contract Officer as soon as possible.
With the release of the PAPPG effective June 1, 2020, NSF researchers are now required to disclose within their Biographical Sketch as follows;
- Positions, Appointments, and Affiliations. All academic, professional, or institutional appointment held by investigators whether current or previously held must be disclosed including domestic or foreign, paid or unpaid, or full/part-time/voluntary. Titled academic, professional, or institutional appointments, including adjunct, visiting, or honorary must be disclosed.
These clarified requirements extend the scope of required reporting beyond that which is attributable to an investigator’s affiliation with Cornell. Investigators must complete and update their Biographical Sketch based on the totality of their positions, appointments, and affiliations, both within and outside of Cornell.
Concurrent with the implementation of the updated PAPPG on June 1, 2020, all Current & Pending documents must be submitted through the use of a NSF-approved format, namely SciENcv and a NSF fillable PDF.
Within each proposal, applicants are required to mark intended partnerships with international collaborators on the NSF Cover Page under three circumstances;
- International Activities: Each proposal that describes an international activity, defined as research, training, and/or education carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies, must list the country(ies) with which project participants will engage on the NSF Cover Page.
- Funding of an International Branch Campus of a U.S. Institution of Higher Education (IHE): Each application that proposes to fund an international branch campus of a U.S. university (e.g. Weill Qatar) must check the International Activities Country Name(s) box and enter the name of the applicable country(ies) on the NSF Cover Page.
- Funding of a Foreign Organization: Each application that proposes to fund a foreign organization, including through use of a subaward or consultant arrangement, must check the Funding of a Foreign Organization box and enter the name of the applicable country(ies) on the NSF Cover Page.
For questions regarding NSF current and pending support, biographical sketches, and foreign partnerships, please contact your assigned Grant & Contract Officer.