Council on Governmental Relations (COGR) Matrix of Science & Security Laws, Regulations, and Policies
Federal Agency Guidance Regarding Disclosures of Other Support (Current and Pending Support)
Regardless of the sponsor, information provided in Other/Current and Pending Support documents must be current, accurate, and complete.
Sponsors have varying expectations for disclosure of information in biosketch, current and pending, and other support documents. To comply with federal law, federal agencies must require all individuals listed on an application for funding of research and development to:
- disclose current and pending research support (sponsor definitions vary),
- certify that the disclosure is current, accurate and complete, and
- update such disclosures based on agency specific requirements.
They must also require the applying institution to certify that individuals listed on the application are aware of the requirements. Details related to NSF and NIH are identified below. Other sponsors are anticipated to implement requirements over the next few months.
- NSF implemented these requirements in its most recent Proposal and Award Policies and Procedures Guide.
- NIH implemented these requirements in NOT-OD-25-133.
You can download a high-level overview of the Federal Agency Disclosure Lifecycle which identifies timing of and types of disclosures using the button below.
Federal Agency Disclosure Lifecycle
Georgia Tech Policies on Disclosure
Please refer to the policies linked below for specific information about expectations on disclosure in alignment with the federal guidance listed above.
Why is accurate and complete disclosure of research support and activities outside my Georgia Tech appointment important?
- Sponsors require it for assessment of conflict of interest and conflict of commitment
- There are consequences for incomplete disclosure, both for the individual and the institution.
- For federal sponsors any false representations 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.
- Stanford University Agrees to Pay $1.9 Million to Resolve Allegations That it Failed to Disclose Foreign Research Support in Federal Grant Proposals
- Cleveland Clinic Foundation to Pay $7.6 Million to Settle Foreign Funding False Statement Allegations
Federal Agency Guidance
National Science Foundation (NSF)
- NSF Pre- and Post-Award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support
- For proposals submitted or due on or after January 30, 2023, PI/PDs and senior personnel must certify their NSF Current and Pending Support documents. The certification will be included in both SciENcv and the NSF fillable format.
- Starting October 23, 2023, SciENcv is required for preparation of Current and Pending Support. Until then, proposers may use either the NSF-fillable PDF or SciENcv to prepare Current and Pending Support.
- NSF is also requiring a certification for Biographical Sketches
- For additional OSP resources and guidance regarding NSF submissions click HERE and review the NSF Resources section.
National Institutes of Health (NIH)
- NIH Disclosure Guidance and Table
- NIH FAQs on Other Support and Foreign Components
- For additional OSP resources and guidance regarding NIH submissions click HERE and review the NIH Resources section.
Department of Defense (DOD)
- The Department of Defense has indicated that information provided in Previous/Current/Pending Support will be used to support protection of intellectual property, national security, and to limit undue influence. See Memorandum.
- The Defense Advanced Research Agency (DARPA) and Army are using risk assessments to help identify potential conflicts of commitment and/or interest. Additional information can be found here: DARPA Countering Foreign Influence, Risk-Based Measures to Assess Potential Undue Foreign Influence of Interest or Conflicts of Commitment and AFC ARMY RESEARCH RISK ASSESSMENT PROTECTION PROGRAM (ARRP)
Department of Energy (DOE)
- DOE employees and funding recipients are subject to limitations on participation in foreign talent recruitment programs of countries determined sensitive by DOE.
- The DOE has released an order and FAQs to implement this memo.
National Aeronautics and Space Administration (NASA)
- NASA Guidebook for proposers responding to a NASA Notice of Funding Opportunity (NOFO)
- Section 2.16 Current and Pending Support: PIs and Co-PIs 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-PIs 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 funding opportunity (i.e., NASA or another sponsor).
- Section 2.2.1 – PIs and Co-PIs also shall list their current and pending support with 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 the required NASA Certifications, Assurances, and Representations form.