NIH | NSF | DOD | DOE| NASA| Disclosure of Foreign Components to Federal Agencies | Sponsor Requests for Citizenship Information

 

Federal sponsors are focusing more closely on the full disclosure of project support than in years past.  There is concern about ‘under-reporting’ of available research funding and of foreign sources of research support (i.e., foreign components, defined below).  It is critically important that complete and accurate information about research support is included in all grant and contract proposals whenever required.  This requirement will vary from sponsor to sponsor, so be sure to include other support information in conformance with each Agency’s instructions.

Should you identify an omission or error in a previously submitted proposal, you must contact the Office of Sponsored Programs OSP Grant & Contract Administrator or BMRA. These offices will work in conjunction with the Office of Research Integrity to determine how best to update this information with the relevant sponsor. OSP, ORI, and BMRA are also available to answer any questions you may have about these requirements. 

NIH Other Support - Updated 12/05/22

Information on other active and pending support may be requested by NIH to ensure there is no scientific budgetary or commitment overlap. This applies to proposals, Just-in-Time and RPPR progress reports. Specifically, NIH requires that Other Support include:“… all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant”. Training awards, prizes, or gifts do not need to be included.

NIH regularly updates their standard instructions and sample document for Other Support. The agency also updates a Disclosures Table (rev 6/8/22) that outlines what information must be disclosed and which section of the proposal is most appropriate for the disclosure.

These changes are effective for all proposals. Because these revised instructions include many substantial revisions, we have developed a new Guidance and Resources page for NIH's updated Other Support and Biosketch Requirements which contains instructions, samples, and FAQ.  These new instructions require that the following items be included in Other Support:

  • Resources and/or financial support from all foreign and domestic entities, that are available to the researcher.  This includes but is not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.). Institutional resources, such as core facilities or shared equipment that are made broadly available, should not be included in Other Support, but rather listed under Facilities and Other Resources.
  • Consulting agreements, when the PD/PI or other senior/key personnel will be conducting research as part of the consulting activities. Non-research consulting activities are not Other Support.
  • In-kind contributions, e.g. office/laboratory space, equipment, supplies, or employees or students supported by an outside source. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates. Please see the *new* OSP In-Kind Other Support Job Aid. 
  • Supporting documentation, which includes copies of contracts, grants or any other agreement 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. If the contracts, grants or other agreements are not in English, recipients must provide translated copies.

There is also a new Signature field, which must be signed by the Investigator to certify the accuracy of the information PRIOR to submission. Standard instructions for completing Other Support documents can be found here.

NIH has also released multiple Notices addressing this topic, NIH Notice NOT-OD-21-073, NIH Notice NOT-OD-19-114 and posted FAQS  on Other Support and Foreign Components here. 

In addition, NIH published Protecting U.S. Biomedical Intellectual Innovation, which summarizes NIH’s position on international collaborations and foreign influence, and provides additional guidance on the disclosure of other support, foreign relationships and activities, and conflicts of interest.

On October 27, 2020 NIH gave a presentation entitled "Commitment Transparency" at its Virtual Seminar on Program Funding and Grants Administration.


NSF Current and Pending Support - Updated 3/20/24

NSF PAPPG 24-1 Effective May 20, 2024

According to the most recent Proposal and Award Policies and Procedures Guide (PAPPG), Current and pending (other) support information is used to assess the capacity or any conflicts of commitment that may impact the ability of the individual to carry out the research effort as proposed. The information also helps assess any potential scientific and budgetary overlap/duplication with the project being proposed.

Current and pending (other) support information must be provided separately for each individual designated as a senior/key person through use of SciENcv (Science Experts Network Curriculum Vitae). Senior/key personnel must prepare, save, certify, and submit these documents as part of their proposal via Research.gov or Grants.gov.

This document should include 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 with an estimated dollar value greater than $5,000 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.

As part of a change in the 2024 PAPPG, consulting activities must be disclosed under the proposals and active projects section of the common form when any of the following scenarios apply:

• The consulting activity will require the senior/key person to perform research as part of the consulting activity;

• 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

• 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.

To help Senior/Key Persons determine whether consulting activities must be disclosed, Brown’s Office of Sponsored Projects has developed a new NSF Consulting Disclosure Guide, which can be found here

NSF also maintains a Disclosures Table that provides guidance regarding what information must be disclosed as part of a grant proposal. This document provides clarity regarding the disclosure of In-Kind Contributions, Consulting and Start-Up companies. Please follow this link to locate the most recent Table.

NSF published helpful FAQs on this topic, which can be found here (version dated February, 2023).

NSF also has additional requirements for the Research Performance Progress Report (RPPR), including a question on current and pending support to be answered by PIs when submitting their annual and final reports.

Malign Foreign Talent Recruitment Program Requirements

Consistent with NSPM-33, senior/key personnel are required to disclose contracts associated with participation in programs sponsored by foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs. Further, if an individual receives direct or indirect support that is funded by a foreign government-sponsored talent recruitment program, even where the support is provided through an intermediary and does not require membership in the foreign government-sponsored talent recruitment program, that support must be disclosed. Senior/key personnel must also report other foreign government-sponsored or affiliated activities. In accordance with 42 U.S.C. § 19232, individuals are prohibited from being a party in a malign foreign talent recruitment program.

Each senior/key person is required to complete the following certifications regarding the information provided in their Current and Pending (Other) Support:

I certify that the information provided is current, accurate, and complete. This includes, but is not limited to, information related to current, pending, and other support (both foreign and domestic) as defined in 42 U.S.C. § 6605.

I also certify that, at the time of submission, I am not a party in a malign foreign talent recruitment program.

Misrepresentations and/or omissions may be subject to prosecution and liability pursuant to, but not limited to, 18 U.S.C. §§ 287, 1001, 1031 and 31 U.S.C. §§ 3729-3733 and 3802.

Post-award Disclosure of Current Support and In-Kind Contribution Information (effective October 5, 2020)
If an organization discovers that a PI or co-PI on an active NSF grant failed to disclose current support or in-kind contribution information as part of the proposal submission process , OSP or BMRA  must submit the following information within 30 calendar days of the identification of the undisclosed current support or in-kind contribution through use of the “Other Request” category in the Notification and Request Module in Research.gov.

Post-award Disclosure of Project Support Information

•   PI/co-PI Name:
•   Project Title:
•   Award Number (if available):
•   Source of Support:
•   Primary Place of Performance:
•   Project Start and End Date:
•   Total Award Amount (including Indirect Costs): $
•   Brief Description of the Major goals of the project:
•   Description of any Overlap/Duplication of the project with the NSF award:
•   Impact on the ability of the PI/co-PI to carry out the NSF award:
•   Person-Month(s) (or Partial Person-Months) Per Year Committed to the Project:

  • Enter the applicable year (e.g., 2020, 2021):
  • Enter the number of person-month(s) (or partial person-months):

The post-award disclosure requirement applies to current support (including in-kind contributions) that was active as of the date the proposal was submitted to NSF. Upon receipt and review of the information provided, NSF may consult with the AOR (at OSP or BMRA), or designee, if necessary. Based on the results of this review, the Foundation will determine the impact of the new information on the NSF-funded grant, and, where necessary, take appropriate action. 

 

Department of Defense (DoD)

All new DoD Notices of Funding Opportunities (NFOs) pertaining to research and research-related educational activities include the following requirements:

Proposers must submit the below information for all key personnel, whether or not the individuals' efforts under the project are to be funded by the DoD:

  • A list of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of the source.

  • Title and objectives of the other research projects.

  • The percentage per year to be devoted to the other projects.

  • The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.

  • Name and address of the agencies and/or other parties supporting the other research projects.

  • Period of performance for the other research projects.

Deparment of Energy (DOE)

DOE requires full disclosure of current and pending support, which includes domestic support, and any foreign support or engagement.

DOE Office of Science FY 2021 Continuation of Solicitation for the Office of Science Financial Assistance Program issued on October 1, 2020 states:

Provide a list of all current and pending support for the PI and senior/key personnel, including subawardees, regardless of funding source. Provide the Current and Pending Support as an appendix to your project narrative. Concurrent submission of an application to other organizations for simultaneous consideration will not prejudice its review.

Current and Pending support is intended to allow the identification of potential duplication, over commitment, potential conflicts of interest or commitment, and all other sources of support. The PI and each senior/key person at the prime applicant and any proposed subaward must provide a list of all sponsored activities, awards, and appointments, whether paid or unpaid; provided as a gift with terms or conditions or provided as a gift without terms or conditions; full-time, part-time, or voluntary; faculty, visiting, adjunct, or honorary; cash or in-kind; foreign or domestic; governmental or private-sector; directly supporting the individual’s research or indirectly supporting the individual by supporting students, research staff, space, equipment, or other research expenses. 

All foreign government-sponsored talent recruitment programs must be identified in current and pending support. Office of Science requires the use of the format approved by the National Science Foundation (NSF), which may be generated by the Science Experts Network Curriculum Vita (SciENcv), a cooperative venture maintained here and is also available as a pdf here. The use of a format required by another agency is intended to reduce the administrative burden to researchers by promoting the use of common formats.

For every activity, list the following items:

  • The sponsor of the activity or the source of funding

  • The award or other identifying number

  • The title of the award or activity. If the title of the award or activity is not descriptive, add a brief description of the research being performed that would identify any overlaps or synergies with the proposed research.

  • The total cost or value of the award or activity, including direct and indirect costs. For pending proposals, provide the total amount of requested funding.

  • The award period (start date – end date).

  • The person-months of effort per year being dedicated to the award or activity

Please note that DOE Offices other than the Office of Science (e.g., NETL, EERE) may have different requirements; check the program solicitation.

National Aeronautics and Space Administration (NASA)

2023 NASA PI Checklist

NASA: Participation, Collaboration, Coordination Presentation  Nov 2023

NASA has had a longstanding prohibition in its agency appropriation language with respect to the People’s Republic of China (PRC) and Chinese-owned companies. Since 2011, NASA is restricted from using funds to enter into or fund any grant, cooperative agreement or contract to participate, collaborate, or coordinate bilaterally in any way with PRC or any Chinese-owned company.

Should you identify an omission or error in a previously submitted proposal, you must contact the Office of Sponsored Programs OSP Grant & Contract Administrator or BMRA. These offices will work with you to determine how best to update this information with the relevant sponsor. OSP and BMRA are also available to answer any questions you may have about these requirements.

NASA Guidebook for Proposers Responding to a NASA Funding Opportunity, revised as of Feb 2023.

 

2.16 Current and Pending Support (emphasis added)

PIs and CoPIs shall provide all ongoing and pending projects and proposals (regardless of salary support) in which they are performing or will perform any part of the work. Co-Is proposing to spend 10 percent or more of their time in any given year to the proposed effort shall provide a list of ongoing and pending projects and proposals (regardless of salary support) that require more than 10 percent of their time in any given year. Proposals do not need to include the current proposal on the list of pending proposals unless it has been submitted in response to another federal funding opportunity (i.e., NASA or another sponsor).

PIs and Co-PIs also shall list any current and pending support with China, including Chinese universities and other similar institutions or a Chinese-owned company at the prime recipient level and at all subrecipient levels, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement. * (see section 2.2.1 below)

For those investigators for whom it is required (see above), the proposal shall provide the following information for each current and pending project:

  • Title of funded project or proposal title;

  • Name of PI on award or proposal;

  • Program name (if appropriate) and sponsoring agency or organization, including a point of contact with their telephone number and email address;

  • Performance period;

  • Total amount proposed (if pending) or received by that PI (including indirect costs) for that award or the amount per year if uniform (e.g., $50k/year); and

  • Time commitment by the PI for each year of the period of performance.

The proposing PI shall notify the NASA Program Officer identified in the NOFO immediately of any successful proposals that are awarded by any federal agency for substantially overlapping work as proposed to NASA any time after the proposal is submitted and until NASA announces its award selections.

Current and pending support is not required for Co-Is at non-U.S. institutions. Current and pending support is usually not required for students, but it may be requested, depending on the requirements of the NOFO. Proposers may request student funding in one of three different ways:

  • As a direct labor cost, the same as a key or other personnel;

  • As a scholarship or other student aid that shall comply with the requirements in 2 CFR 200.466, Scholarships and student aid costs; or

  • As a participant support cost as defined in 2 CFR 200.1, Definitions

* "China or Chinese-owned Company" means the People's Republic of China (PRC), any company owned by the PRC, or any company incorporated under the laws of the PRC. Chinese universities and other similar institutions are considered to be incorporated under the laws of the PRC and, therefore, the funding restrictions apply to grants and cooperative agreements that include bilateral participation, collaboration, or coordination with Chinese universities.

 

2.2.1 Special Restrictions for Non-U.S. Organizations

 In general, per 2 CFR 1800.3, Applicability, research with foreign organizations will not be conducted through grants or cooperative agreements. Typically, NASA conducts research with non-U.S. organizations on a cooperative, no-exchange-of-funds basis. Although Co-Investigators (Co-Is) or Collaborators employed by non-U.S. organizations may identify themselves as part of a proposal submitted by a U.S. organization, NASA funding does not normally support research efforts by non-U.S. organizations and Collaborators at any level, including travel by investigators at non-U.S. organizations. This policy pertains to the nature of the proposing organization and not the nationality or citizenship of the individuals listed in the proposal. However, the direct purchase of supplies and/or services, which do not constitute research, from non-U.S. sources with NASA-awarded funds is permitted.

 In accordance with China restrictions set forth in section 526 of PL 117-103, and all applicable subsequent appropriations acts, NASA is prohibited from funding any work that involves the bilateral participation, collaboration, or coordination with China or any Chinese-owned company or entity, at the prime recipient level or at any subrecipient level, whether funded or performed under a no-exchange-of-funds basis. Accordingly, proposals shall not include bilateral participation, collaboration, or coordination with China or any Chinese-owned company or entity, whether funded or performed under a no-exchange-of funds basis. Proposals involving bilateral participation, collaboration, or coordination in any way with China or any Chinese-owned company, whether funded or performed under a no-exchange-of-funds basis, will be ineligible for award.

 

Templates for the Summary Table of Work Effort and Current and Pending Support for ROSES Proposals

Disclosure of Foreign Components to Federal Agencies

There is heightened concern from federal agencies about the lack of disclosure of collaborations with, and/or funding by, foreign entities. This includes both foreign governments and foreign institutions of higher education. Here again, each agency provides its own definition of what constitutes a “foreign” or “international” component.

NIH’s comprehensive definition of a foreign component can be found here.  It includes:

  • collaborations with investigators at a foreign site anticipated to result in co-authorship

  • use of facilities or instrumentation at a foreign site;

  • receipt of financial support or resources from a foreign entity.

  • Foreign travel for consultation is not considered a foreign component.

    Disclosure of a Foreign component to the NIH:

    There are multiple ways in which foreign components can be appropriately disclosed to NIH. For example:

  • Identifying a “foreign component” in an NIH grant application;

  • Listing a “non-U.S. performance site”;

  • Identifying foreign relationships and activities in a Biosketch;

  • Checking “yes” to the question on the Cover Page Supplement Form asking, “Does this project involve activities outside of the United States or partnerships with international collaborators?”

  • NIH employs the Foreign Award and Component Tracking System (FACTS) system to record all activities involving foreign countries.

    This NIH Blog here also describes the purpose and obligation to disclose properly and fully. 

    NSF asks for information on International Activities on the Cover sheet with the following instruction:

     “For each proposal that describes an international activity, proposers should list the primary countries involved.  An international activity is defined as research, training, and/or education carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies. Proposers also should enter the country/countries with which project participants will engage and/or travel to attend international conferences.”

    A fuller definition of International Activities is found here.

Sponsor Requests for Citizenship Information

Brown University does not share citizenship information with sponsors, unless it is a condition of eligibility to apply for funding (e.g., NIH fellowships).

Providing citizenship information to a sponsor for pre-approval of research participants may violate Brown’s Openness in Research policy and may jeopardize the Fundamental Research status of the research project. It is also contrary to Brown's statement on Terms and Conditions in Sponsored Research Agreements.  Importantly, only the Brown Principal Investigator has the authority to identify and hire project personnel. This is to protect the PI's freedom to manage the project as they deem appropriate and prevent potential discriminatory practices.

Given Brown generally does not accept agreements or contracts that give sponsors the right to review and pre-approve research participation based on citizenship, you should not receive any requests for sharing of citizenship information from sponsoring agencies. In the event that you do receive such a request from your program officer, contact or refer them to the Office of Sponsored Projects (OSP) for assistance.