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Adjusted Timeline for NIH's Implementation of Common Forms (NOT-OD-26-033)
An NIH Guide Notice issued February 4, 2026 confirming that NIH will not withdraw initial applications, JITs, RPPRs, or Prior Approvals submitted on or after January 25 that fail to use the Common Forms via SciENcv for Biographical Sketches, Current and Pending (Other) Support, and NIH Biographical Sketch Supplements. Instead, NIH will provide a warning message when the Common Forms are not used, while still encouraging applicants and recipients to begin using the Common Forms as soon as possible.
DOE Financial Assistance Letter FAL 2026-02: Biographical Sketch and Current and Pending (Other) Support Common Form Usage
Financial Assistance Letter FAL 2026-02, issued by the U.S. Department of Energy on December 3, 2025, mandating that any DOE notices of funding opportunities (NOFOs), including those from the National Nuclear Security Administration, issued on or after December 3, 2025, require use of the Common Forms via the SciENcv system for Biographical Sketches and Current and Pending (Other) Support (CPS). DOE's adoption of the Biosketch Common Form replaces its prior use of the Resume form, with program offices retaining latitude to specify certain data requirements (such as digital persistent identifier requirements or additional CPS disclosures) within a given NOFO.
Matrix of Science & Security Laws, Regulations, and Policies
A chart that compares federal laws, regulations, and policies in the area of science and security. The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy, (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies. Updated September 30, 2025.
Quick Reference Table of Current & Upcoming Federal Research Security Requirements
A matrix that lists policies and requirements under the headings of: Disclosures, Agency Risk Assessment, FCOI & COC, Training, Certifications, and Research Security Program for each federal agency. Per COGR, this tool is frequently updated to reflect the release of new documentation. Updated September 30, 2025.
Simplifying Research Regulations and Policies: Optimizing American Science
Published September 3, 2025, a National Academies Committee conducted an expedited study to examine federal research regulations and identify ways to improve regulatory processes and administrative tasks, reduce or eliminate unnecessary work, and modify and remove policies and regulations that have outlived their purpose while maintaining necessary and appropriate integrity, accountability, and oversight. Research security specific options include: implement the NSPM-33 common disclosure forms and disclosure table without deviation; establish common principles for agency research security risk reviews for fundamental research; continue prior efforts to streamline and clarify export controls; and adapt cybersecurity requirements for university settings.
NIH Announces a New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements (NOT-OD-25-133)
Effective October 1, 2025, recipient institutions must train senior/key personnel on the requirement to disclose all research activities and affiliations in Other Support and maintain a 'written and enforced policy on requirements for the disclosure of other support to ensure Senior/Key Personnel fully understand their responsibility to disclose.'
America First Memorandum for USDA Arrangements and Research Security
Issued July 8, 2025. This memorandum: a. Requires all USDA Mission Areas, Agencies, and Offices to: i. Within 30 days, conduct a comprehensive review of all current USDA awards/subawards with foreign persons/entities and provide justification as to why a US recipient was not selected, ii. Effective immediately, request approval (including justification) prior to issuing an award/subaward to a foreign person/entity. b. Requires applicants (i.e., covered individuals) to: i. Complete the Common Forms for Biographical Sketches and Current and Pending (Other) Support and provide updated information annually, ii. Certify they are not a participant in a malign foreign talent recruitment program (MFTRP) and recertify annually, iii. Certify that they are not contracting with or providing benefit to any foreign person/entity in a country of concern, iv. Certify that they are not party to utilizing forced labor, v. Complete an annual disclosure of contracts associated with participation in programs sponsored by foreign governments/entities, vi. Seek approval from USDA to subaward any portion of a funded arrangement, including university students, post-doctoral fellows, and visiting researchers. c. Requires Employing Entities to: i. Certify to applicants' completion of research security training, ii. Prohibit applicants who either are currently or have in the past 10 years participated in MFTRPs from working on USDA projects, iii. Provide supporting documentation for foreign activities reported as current and pending support, iv. Review any documents required under the memorandum for compliance with USDA award terms and conditions.
Notice of Information: NIH SBIR and STTR Foreign Disclosure Post-Award Requirements for Active SBIR and STTR Awardees (NOT-OD-25-102)
Effective immediately (April 29, 2025), the SBIR and STTR Foreign Disclosure and Risk Management Requirements described in NOT-OD-23-139 and NOT-OD-24-029 may be applied to all active SBIR and STTR awards regardless of the due date the competing application was submitted. Recipients with active awards that did not undergo foreign risk assessment at the time of their original application may be required to disclose all funded and unfunded relationships with foreign countries, using the Required Disclosures of Foreign Affiliations or Relationships to Foreign Countries Form. If the recipient reports a covered foreign relationship that meets any of the risk criteria prohibiting funding, NIH may deem it necessary to terminate the award for material failure to comply with the federal statutes, regulations, or terms and conditions of the federal award.
Required Disclosures of Foreign Affiliations or Relationships to Foreign Countries Form
An NIH form used by recipients with active SBIR and STTR awards to disclose all funded and unfunded relationships with foreign countries. Per NOT-OD-25-102, recipients whose awards did not undergo foreign risk assessment at the time of their original application may be required to use this form, and NIH may terminate awards where a reported covered foreign relationship meets risk criteria prohibiting funding.
Most Institutions That Received NIH Funding Did Not Fully Understand When They Must Report Monetary Donations
A March 2025 HHS Office of Inspector General review finding that many institutions receiving NIH funding did not fully understand when monetary donations must be reported as 'Other Support' versus when they qualify as unrestricted gifts. The scenarios in this review correspond with the illustrative scenarios later posted by the NIH Office of Policy for Extramural Research Administration (OPERA) to help investigators and institutions make this determination.
NIH Scenarios of Monetary Donations as Other Support vs. Gifts
An NIH OPERA document providing illustrative scenarios to help investigators and institutions determine when monetary donations must be disclosed as Other Support versus when they qualify as unrestricted gifts. It explains that donations must be reported as Other Support when intended to directly support an investigator's research activities and carrying explicit or implicit expectations, such as use for specific projects, placement into a research account, or requirements to provide updates to donors. The scenarios correspond with those in the Office of the Inspector General's March 2025 review of institutional understanding of monetary donation reporting.
DoE Financial Assistance Letter (FAL): Digital Persistent Identifier Requirements for Certain Individuals for Research and Development
Issued on August 8, 2024. Effective May 1, 2025, applicants are required to have a Digital Persistent Identifier or Persistent Identifier (PID) if: 1. Individuals are listed within financial assistance applications that will fund R&D activities, or technical assistance to support R&D activities; and 2. Individuals are required to submit Biographical Sketch and/or Current and Pending (Other) Support disclosure. A PID is defined as globally unique, persistent, machine resolvable and processable, and has an associated metadata schema (example: ORCID iD). PIDs must be provided in the Biographical Sketch and/or Current and Pending (Other) Support disclosures as part of the application. This requirement is optional until May 1, 2025, and mandatory thereafter.
NIH Decision Matrix for Assessing Potential Foreign Interference for Covered Individuals or Senior/Key Personnel
August 2024. Assists agency staff in assessing grant applications and ongoing awards for potential foreign interference. Factors considered include: (1) current or past participation in a malign foreign talent recruitment program, which is prohibited by law, (2) undisclosed current or prior funding from a foreign country of concern (FCOC), or connected entity (currently China, Russia, North Korea, and Iran (higher risk)) or other foreign country (lower risk) and, (3) Indicators of an undisclosed current or past affiliation with an institution or entity located in or connected to a FCOC (higher-risk/mitigation) or foreign country (lower-risk/mitigation). Per the matrix, mitigation is either required, recommended, suggested, or not required based on the timing of the engagement and if accurate and complete disclosure information was provided. Mitigation conditions include: (1) specific award conditions, (2) modification of terms and conditions of award, (3) suspension, termination, or withdrawal of an award, (4) conversion from advance payment to reimbursement, and (5) recovery of funds.
Trusted Research Using Safeguards and Transparency (TRUST)
June 2024. NSF initiated a proposal risk review process similar to that of DoD but with some notable differences. NSF's process will focus on critical technologies, beginning with a pilot of quantum technologies proposals in FY25, expanding to other key technologies in phase 2, and scaling up for all key technologies identified in the CHIPS and Science Act in phase 3. NSF will evaluate Three Criteria: 1. Appointments and positions with U.S. proscribed parties (e.g., U.S. BIS Entity List) and currently party to a MFTRP; 2. Non-disclosures of appointments, activities, and financial support; and 3. Potential foreseeable national security applications of the research. NSF will consider only current foreign appointments and affiliations and is not considering co-authorship in risk assessment.
NSTC Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support
A matrix developed to assist in determining if specific activities are required to be disclosed and what form is appropriate for reporting. Last updated May 2024.
Policy Regarding Use of Common Disclosure Forms for the "Biographical Sketch" and the "Current and Pending (Other) Support" Sections of Applications by Federal Research Funding Agencies
Issued by the White House OSTP in February 2024, this policy requires federal agencies to use the Common Forms for current and pending support and biosketches, noting that NSF will serve as steward. Deviation from the common disclosure forms will require Office of Management and Budget (OMB)/Office of Information and Regulatory Affairs (OIRA) review and clearance under the Paperwork Reduction Act (PRA).
Clarification of Implementation of the NIH SBIR and STTR Foreign Disclosure Pre-award and Post-Award Requirements (NOT-OD-24-029)
Issued November 14, 2023, this Notice provides clarification regarding findings of foreign involvement with countries of concern related to grants and cooperative agreements under the NIH, CDC, and FDA SBIR and STTR programs. It clarifies the specific changes to competing application instructions first implemented in NOT-OD-23-139, which apply to competing applications submitted for due dates on or after September 5, 2023.
Current and Pending (Other) Support Common Form
The common form for federal-wide use for current and pending (other) support disclosure, created as directed by NSPM-33 with NSF serving as steward. The form includes certification by each senior/key person at the time of submission that they are not a party to a malign foreign talent recruitment program as defined in the CHIPS and Science Act of 2022. As of November 2025, the form has been implemented by NSF and the National Aeronautics and Space Administration (NASA).
Biographical Sketch Common Form
The common form for federal-wide biographical sketch disclosure, created as directed by NSPM-33 with NSF serving as steward. Includes certification by each senior/key person at the time of submission that they are not a party to a malign foreign talent recruitment program as defined in the CHIPS and Science Act of 2022. As of November 2025, the form has been implemented by NSF and NASA.
Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education
Issued June 29, 2023 by DoD. The document includes: 1. A Policy on Risk-based Security Reviews of Fundamental Research, 2. A Decision Matrix to Inform Fundamental Research Proposal Mitigation (Amended May 5, 2025), 3. A list of foreign institutions identified as engaging in problematic activity (Part 3, Table 1, Amended June 24, 2025), and 4. A list of foreign talent recruitment programs identified as posing a threat to U.S. national security interests (Part 3, Table 2). The Decision Matrix contains four factors for assessing senior/key personnel disclosures: a. Participation in foreign talent recruitment programs, b. Current or prior funding from foreign countries of concern (FCOCs), c. Filing a patent in an FCOC or on behalf of an FCOC-connected entity, or in a non-FCOC country, without disclosure, and d. Associations or affiliations with organizations on U.S. Entity (trade restriction) and other indicated (U.S. restricted) lists.
Implementation of the NIH SBIR and STTR Foreign Disclosure Pre-award and Post-Award Requirements (NOT-OD-23-139)
Issued June 12, 2023, this Notice implements additional disclosure and post-award reporting requirements for small business concerns (SBCs) participating in the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs regarding covered relationships. It also serves as notification of NIH's due diligence program to assess security risks and to deny award where foreign relationships meet the risk criteria prohibiting funding. The requirements apply to competing applications submitted for due dates on or after September 5, 2023.
NASA Proposer's Guide
The NASA Proposer's Guide (February 2023) includes similar language to the Wolf Amendment in a footnote of section 2.16, Current and Pending Support. Per the footnote, '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.
NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 23-1)
The NSF Proposal and Award Policies and Procedures Guide (NSF 23-1, January 2023). Post-award Disclosure of Current Support and In-Kind Contribution Information: PAPPG Chapter II.D.2.h(ii).
Research Security Training
Research security training developed by institutions and organizations under cooperative agreements funded by NSF in collaboration with the National Institutes of Health (NIH), Department of Energy (DoE), and Department of Defense (DoD), with engagement from the Federal Bureau of Investigation (FBI). The training consists of 4 modules: 1.) What is Research Security?; 2.) Disclosure; 3.) Manage and Mitigate Risk; 4.) International Collaboration.
SBIR and STTR Extension Act of 2022
September 2022. Requires agencies to implement a due diligence program to assess security risks for SBIR and STTR proposals. Disclosure requirements include information on foreign ties, business relationships, investment, and ownership. [Source: AAU, January 2024].
CHIPS Act Sec. 10339B: Foreign Financial Support
Directs NSF to collect annual summaries of foreign financial support from universities. The provision establishes a reporting threshold of $50,000 or more in [cumulative] financial support, including gifts and contracts, received directly or indirectly from a foreign country of concern (China, Russia, North Korea, and Iran at the time the law was enacted), or any other country determined to be a concern by the Secretary of State. This is in addition to the reporting of gifts and contracts from all foreign countries with a cumulative value of $250,000 or more via the Higher Education Act and Department of Education.
CHIPS Act Sec. 10336: Authorities
Authorizes the NSF OCRSSP, in coordination with the Office of Inspector General (OIG), to conduct risk assessments, including through the use of open-source analysis and analytical tools, of R&D award applications and disclosures to NSF.
CHIPS Act Sec. 10337: Responsible Conduct in Research Training
Expands the requirement for RCR training to include faculty and other senior personnel on [NSF] awards and expands the scope of such training to include mentoring training and training to raise awareness of research security risks as well as Federal export control, disclosure, and reporting requirements.
CHIPS Act Sec. 10631: Requirements for Foreign Talent Recruitment Programs
OSTP to issue guidance to Federal research agencies to prohibit participation in 'foreign talent recruitment programs' by agency personnel and provide additional clarification to the research community regarding which activities are considered 'foreign talent recruitment programs.' OSTP is also directed to issue guidance clarifying that researchers working on Federally supported research projects must disclose participation in FTRPs in Federal research award proposals. OSTP is further directed to issue guidance for Federal research agencies to prohibit researchers working on agency-funded projects from participating in 'malign foreign talent recruitment programs,' and certify both at the time of proposal and annually that they are not part of a malign foreign talent recruitment program.
Guidance for Implementing NSPM-33
A January 2022 report by the White House OSTP/NSTC Research Security Subcommittee providing additional details on 1.) Disclosure Requirements and Standardization 2.) Persistent Identifiers 3.) Consequences for Violation of Disclosure Requirements 4.) Information Sharing and 5.) Research Security Programs. Largely superseded by the final July 9, 2024 guidelines.
Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021 (NOT-OD-21-073)
Issued March 2021. Requires immediate notification of undisclosed Other Support. If a recipient discovers Other Support information on an active NIH grant that should have been, but was not, disclosed during just-in-time or in an annual progress report, updated Other Support must be submitted to the Grants Management Specialist as soon as the undisclosed information is known.
National Security Presidential Memorandum-33 (NSPM-33): Presidential Memorandum on U.S. Government-Supported Research and Development National Security Policy
A Presidential Memorandum issued in January 2021 to strengthen protections of U.S. Government-supported R&D against foreign government interference and exploitation. It focuses on ensuring full disclosure of potential conflicts of interest and commitment by recipients of federal R&D and requires research institutions receiving over $50 million in federal R&D funding to certify they operate a research security program covering cybersecurity, foreign travel security, insider threat awareness, and export control training. As of November 2025, federal agencies continue to coordinate and work to implement this requirement for awardee institutions.
FY2021 NDAA
Signed January 3, 2020. Section 223 mandates disclosure of funding sources in applications for federal R&D awards and holds universities accountable for ensuring faculty awareness. Section 1299C is an amendment to FY 2019 NDAA Section 1286 requiring designation of an official responsible for liaising with academic institutions and briefing them on espionage risks. Section 1062 restricts DoD and NSF funds to institutions hosting a Confucius Institute. Section 9907 prohibits any funds for microelectronics initiatives to a foreign entity of concern.
Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114)
Issued July 10, 2019. Reminds institutions receiving NIH funding of the requirement for researchers to disclose all sources of support for their research endeavors, regardless of the source, value, or whether monetary or in-kind, and to disclose all scientific appointments and positions, whether foreign or domestic, paid or unpaid, etc. The notice also reminds the extramural community of the requirement to comply with HHS regulations regarding Financial Conflicts of Interest, as well as the requirement to report all Foreign Components involved in NIH-supported activities.
Transparency of Foreign Connections Disclosure and Certification
For applicants, recipients, and subrecipients that are required to submit transparency of foreign connections disclosures, DOE provides this format for the convenience of the entity providing the disclosure and certification; however, the entity is not required to use this specific format. If another format is used, the signatory must include the same substantive information, a signature, date, and the certification statement provided in Section 3 of the document.