Federal Sponsor Disclosure Requirements
In response to the concerns about undue foreign influence, many federal agencies have adjusted or clarified their disclosure requirements. Please always refer to the terms and conditions in the award. The information below highlights some of the main clarification and requirements of the federal sponsors.
Public Health Service (National Institutes of Health)
Update: NIH is adopting the Biographical Sketch Common Form for applications and Research Performance Progress Reports effective for application due dates and report submission dates on or after May 25, 2025 (currently postponed)
Timing: Submit with application
Applies to: All Senior/Key Personnel and Other Significant Contributors
What to disclose:
List in reverse chronological order all 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). High school students and undergraduates may include any previous positions. For individuals who are not currently located at the applicant organization, include the expected position at the applicant organization and the expected start date.
List any relevant academic and professional achievements and honors. In particular:
- Students, postdoctorates, and junior faculty should include scholarships, traineeships, fellowships, and development awards, as applicable.
- Clinicians should include information on any clinical licensures and specialty board certifications that they have achieved.
For Applications and Research Performance Progress Reports due on or after May 25, 2025 (postponed):
- The approved Common Forms for Biographical Sketch can be accessed at NSF’s website at NSTC Research Security Subcommittee NSPM-33 Implementation Guidance Disclosure Requirements & Standardization. NIH will no longer accept the NIH Biographical Sketch format page.
- Will require use of SciENcv to complete Common Forms
- Will require all Senior/Key Personnel to enter their ORCID ID into SciENcv in the Persistent Identifier section of the Common Forms
- NIH will continue collecting Personnel Statement, Contributions to Science, and Honors separately from the Common Forms on a new NIH Biographical Sketch Supplement.
Resources:
- Biosketch and Other Support Checklist
- UCI NIH Biosketch & Other Support
- NIH Biosketch Forms
- NIH Biosketch Sample (Non-Fellowship) Note: Sample includes positions like consultant, membership in organizations, Board membership, etc.
- NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support
- NIH Notice on Updated Biosketch and Other Support format page templates and requirements (Effective 5/25/21)
- NIH FAQs on Biosketch
After May 25, 2025:
Update: NIH will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project effective May 1, 2025. NIH will not issue awards to entities (new, renewal, or non-competing continuation) that include a foreign subaward.
Timing: Submit with application
Applies to: PHS Project- It is the Program Director/Principal Investigator's responsibility to include foreign component information in the application and request prior approval if necessary
What to disclose:
Foreign Component: performance of a significant scientific element of the NIH-supported project outside of the US, whether or not funds are expended
- Examples of “significant”:
- 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
- "Outside of the US" or Foreign: organization located in a country other than the US and its territories that are subject to the laws of that country, regardless of the citizenship of the proposed Program Director/Principal Investigator
Resources:
Timing:
- KR Federal Disclosure and Certification required prior to proposal submission and at least annually for the duration of the award
- Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award and at least annually for the duration of the award
Applies to: All Investigators on PHS compliant proposals or flow-through excluding SBIR/STTR Phase I proposals are required to disclose their significant financial interests.
Investigator(s) include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by PHS, or proposed for such funding, which may include, for example, collaborators or consultants.
- For non-UCI Investigators on the UCI's award/proposal and any subrecipients following UCI's PHS COI Policy, all individuals that meet the definition of an Investigator must submit the Form 800SR.
What to disclose:
"Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the Investigator's Institutional Responsibilities includes the following:
- Total income or payment of services received over the past 12 months and/or equity interest (includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value) in a publicly traded entity exceeding $5,000 when aggregated
- Total income or payment of services received over the past 12 months from a non-publicly traded entity exceeding $5,000
- Any equity interest (includes any stock, stock option, or other ownership interest) in a non-publicly traded entity
- Total payments received over the past 12 months for any intellectual property rights and interests (e.g., patent, copyright, assigned or licensed to a party other than the Regents) exceeding $5,000
- Any reimbursed or sponsored travel
The term "Significant Financial Interest" does not include: salary, royalties, or other remuneration paid by the UCI to the Investigator if the Investigator is currently employed or otherwise appointed by the UCI, including intellectual property rights assigned to the UCI and agreements to share in royalties related to such rights; income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; income from seminars, lectures, or teaching engagements sponsored by a US federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a) within the US, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education; or income from service on advisory committees or review panels for a US federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a) within the US, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education. All significant financial interests from a foreign entity (governmental, non-profit, for-profit, etc.) must be disclosed.
Resources:
Update: Effective October 1, 2025, NIH requires all faculty and researchers identified as Senior/Key Personnel to complete training on Other Support disclosure requirements.
Timing: Submit at Just-in-Time and update in annual progress reports
Applies to: All individuals designated in an application as senior/key personnel except:
- Program Directors, training faculty, and other individuals involved in the oversight of training grants
- Individuals categorized as Other Significant Contributors
What to disclose:
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All foreign and domestic 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. This includes but is not limited to:
- 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.
Other support does not include training awards, prizes, or gifts. Gifts are resources provided where there is no expectation of anything (e.g. time, services, specific research activities, money, etc.) in return. An item or service given with the expectation of an associated time commitment is not a gift and is instead an in-kind contribution and must be reported as such.
- Signature block added. The Program Director (PD)/Principal Investigator (PI) and Other Senior/Key Personnel must electronically sign the other support form to certify its accuracy.
- Supporting documentation. If Other Support includes foreign activities or resources, the PI/PD or Other Senior/Key personnel much attach copies of contracts, grants, or any other agreement specific to their foreign appointments and/or employment with a foreign institution, as well as for all foreign activities and resources reported in Other Support. If these documents are not in English, they must provide translated copies.
- Immediate notification of undisclosed Other Support. As soon as it becomes known to UCI that a PI/PD or Other Senior/Key personnel on an active NIH grant failed to disclose Other Support information when submitting the Just-in-Time information or RPPR, as applicable, UCI must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known. Even accidental oversight may have individual and/or institutional reputational consequences. Therefore, PIs/PDs and Other Senior/Key Personnel should take great care to ensure that Other Support is properly and completely disclosed.
- NIH reorganized the Other Support page to separate funded projects from in-kind contributions.
Resources:
- Biosketch and Other Support Checklist
- UCI NIH Biosketch & Other Support
- UCOP Other Support Infographic
- NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support
- NIH Other Support Foreign Components FAQs
- Reminders of NIH Policies on Other Support and on Policies Related to Financial Conflicts of Interests and Foreign Components
- NIH Notice on Updated Biosketch and Other Support format page templates and requirements (Effective 5/25/21)
After May 25, 2025:
NIH Recommendation: "In the interest of full transparency, recipients should err on the side of disclosure. Researchers should consult with their institutional officials for guidance to ensure compliance with institutional and NIH policies. NIH requires complete and accurate reporting of all sources of research support, financial interests and affiliations, both foreign and domestic.”
Purpose: NIH evaluation of Other Support to ensure:
- All resources, domestic or foreign, directly supporting the individual’s research endeavors have been reported
- Sufficient levels of effort are committed to the project
- There is no scientific, budgetary, or commitment overlap
- Only funds necessary to the approved project are included in the award
- Any foreign resources that meet the definition of a foreign component have received appropriate prior approval.
NIH developed a Matrix a guide to assist NIH in reviewing grant applications and ongoing awards for signs of potential foreign interference, and in appropriately mitigating risk. The Matrix describe conditions in which NIH will contact the grant applicant or recipient for further information, and in which mitigation may be required, recommended, or not needed.
Note: NIH considers undisclosed or incompletely disclosed foreign engagements a potential risk factor that may require a risk mitigation plan.
Resources:
National Science Foundation
June 6, 2025: NSF Secure Center website online.
June 7, 2025: All PIs or co-PIs named on an NSF award made on or after May 20, 2024, must certify annually in Research.gov that they are not party to a MFTRP.
Timing: Submit through SciENcv with application
Applies to: All Senior Personnel
What to disclose: Using SciENcv include education and training, all titled foreign or domestic academic, professional, or institutional appointments and positions outsides of the primary organization whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary) for a period of up to 3 years from the date the propose submits the proposal to NSF
Resources:
- NSF Pre-award and Post-award Disclosures Relating to Biographical Sketch and Current and Pending Support
- NSF-Approved Formats for Biographical Sketch(es)
- Biographical Sketch instructions: PAPPG
- NSF FAQs (Biographical Sketches on Page 2)
- Best Way to Reduce Administrative Burden when Creating a Biosketch (Youtube Video)
- Populate Your SciENcv Biographical Sketch Using ORCiD (Youtube Video)
Timing: Submit with application by listing primary countries involved on the coversheet
Applies to: NSF Project
What to disclose: International Activities include:
- International Research/Education/Training Activities: research, training, and/or education carried out in cooperation with foreign counterparts either overseas or in the US using virtual technologies.
- International Conferences: enter on the Cover Sheet country/countries with which project participants will engage and/or travel to attend international conferences
- Work in foreign countries: PI responsible for obtaining required authorizations if necessary to conduct work in foreign countries.
Resources:
Timing:
- KR Federal Disclosure and Certification required prior to proposal submission
- Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award- COI Team will send a follow-up NSF/NASA question if the Investigator has a positive KR Federal Disclosure and Certification at award stage to determine if a COIOC review is required
- Investigators are required to disclose if they acquire or discover a new significant financial interests during the period of the NSF award
Applies to: All Investigators are required to disclose their significant financial interests.
"Investigator(s)" include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by NSF, or proposed for such funding, which may include, for example, collaborators or consultants. For more clarification, please visit Identifying NSF Investigators.
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- For any non-UCI Investigators on the UCI proposal/award and any subrecipients following UCI's NSF COI policy, all individuals who meet the definition of an Investigator must complete the Form 900SR
What to disclose:
"Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the NSF project includes the following:
- Total income or payment of services received over the past 12 months exceeding $10,000
- Includes salary, consultant payments, honoraria, royalty payments, dividends, loan or any other payments or consideration with value, including payments made to the University Health Sciences Compensation Plan). Please exclude income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities and income from service on advisory committees or review panels for public or nonprofit entities
- Equity interest (e.g., stock, stock options, real estate, or any other investment or ownership interest in an entity exceeding $10,000 (current market value) or a 5% or greater ownership interest
- Any intellectual property rights and interests (e.g., a patent, patent application, copyright of software assigned or licensed to a party other than the UC Regents)
Related Financial Interest: Work to be performed under the sponsored project and results therefore that would reasonably appear to affect the Significant Financial Interest of the Investigator or the financial interests of the entity in which the Investigator has a financial interest.
Resources:
Timing: Submit through SciENcv with application and update in annual and final progress reports
- If an organization discovers that a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process (see PAPPG, the AOR must submit the information specified in the applicable general term and condition article entitled, “Post-award Disclosure of Current Support and In-kind Contribution Information” within 30 calendar days of the identification of the undisclosed current support or in-kind contribution through use of the Notification and Request Module in Research.gov.
- RPPR: PIs and co-PIs on active NSF awards must indicate if there has been a change in active other support since submission of the proposal, or the last reporting period in their annual and final project report. If there has been a change, the individual must submit a revised current and pending support document prepared in SciENcv as part of their project report.
Applies to: All Senior Personnel
What to disclose:
- Includes 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 including but not limited to the following:
- All existing projects, as well as all projects currently under consideration for funding
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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.
- 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.
- All in-kind contributions with the expectation of an associated time commitment (such as office/laboratory space, equipment, supplies, employees, students) not intended for use on project/proposal being proposed
- Notes: In-kind contributions intended for use on the project being proposed to NSF should be included as part of the Facilities, Equipment and Other Resources section of the proposal and need not be replicated in the current and pending support submission. Gifts (such as services, lodging, equipment time, etc.) are by definition given without the expectation of anything in return and do not need to be reported.
Resources:
- NSF Pre-award and Post-award Disclosures Relating to Biographical Sketch and Current and Pending Support
- FAQs on Current and Pending Support- June 2021
- NSF-Approved Formats for Current & Pending Support
- Current and Pending Support Instructions: PAPPG
Article 38: Post-award Disclosure of Current Support and In-Kind Contribution Information- Effective 10/5/2020, if an organization discovers that a PI or co-PI on an active NSF award failed to disclose current support or in-kind contribution information as part of the proposal submission process, the Authorized Organizational Representative must submit the information outlined in the article within 30 calendar days of the identification of the undisclosed current support or in-kind contribution.
Update: Starting June 7, 2025, all PIs or co-PIs named on an NSF award made on or after May 20, 2024 must certify annually in Research.gov that they are not a party to a MFTRP. NSF is working to expand the MFTRP Annual Certification for all senior/key personnel roles at a future date. This is a post-award annual certification separate from the required pre-award disclosure in Biographical Sketch and Current and Pending (Other) Support proposal sections.
Timing: Prior to proposal application submission and at least annually for duration of the award
Applies to: All Senior/Key Personnel
Ineligibility: Individuals who are a current party to a Malign Foreign Talent Recruitment Program are not eligible to serve as a senior/key person on an NSF proposal or on any NSF award made after May 20, 2024.
What to certify: Each individual identified as senior/key person must certify in the KR Federal Disclosure and Certification prior to proposal submission that they are not a party to a malign foreign talent recruitment program and annually thereafter for the duration of the award.
Resource:
NSF's decision tree approach to assess research proposals and ongoing projects for concerning appointments and research support, non-compliance with disclosure and other requirements, and potential risks to national security.
Three Branches of TRUST:
- Assessing active appointments, positions, and research support
- Identifying instances of nondisclosure
- Including national security considerations
Branches 1-2: Office of the Chief of Research Security Strategy and Policy (OCRSSP) team will conduct an analysis using proposal submission and other data to flag areas of potential concern. The OCRSSP team will then assess whether any flagged proposals warrant engagement with the awardee institution to gather additional information and consider whether risk mitigation and management may be required.
Branch 3: Convene Research Security Review Team to review results of analyses from the first two branches and assess potential foreseeable national security concerns. If the Review Team determines that there is sufficient national security risk associated with the project, or if they confirm a concern raised in the first two criteria, OCRSSP staff and the awardee institution will work collaboratively to gather additional information that can inform the exploration of the necessity and options for mitigating those risks.
Beginning in fiscal year 2025, the first phase is a pilot program in which TRUST will be applied to quantum-related proposals after undergo merit review.
Resources:
- Trusted Research Using Safeguards and Transparency (June 5, 2024)
Department of Energy
May 6, 2025: DOE covered individuals must complete Research Security Training
Timing: With application attached to the Research and Related Senior/Key Person Profile (Expanded) form.
Applies to: Principal Investigator and all senior/key personnel who will be identified by name in Section A of the application's budget and all other personnel who contribute in a substantive, meaningful way to the scientific development or execution of the project, whether or not salaries are requested (including Consultants if they meet this definition).
What to disclose: A biosketch is to provide information that can be used by reviewers to evaluate the PI’s potential for leadership within the scientific community. Examples of information of interest are invited and/or public lectures, awards received, scientific program committees, conference or workshop organization, professional society activities, special international or industrial partnerships, reviewing or editorship activities, or other scientific leadership experiences.
SC 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 at https://www.ncbi.nlm.nih.gov/sciencv/.
The biographical information (curriculum vitae) must include the following items within its page limit:
- Education and Training: Undergraduate, graduate and postdoctoral training, provide institution, major/area, degree and year.
- Research and Professional Experience: Beginning with the current position list in chronological order, professional/academic positions with a brief description.
- Publications: Provide a list of up to 10 publications most closely related to the proposed project. For each publication, identify the names of all authors (in the same sequence in which they appear in the publication), the article title, book or journal title, volume number, page numbers, year of publication, and website address if available electronically. Patents, copyrights and software systems developed may be provided in addition to or substituted for publications. An abbreviated style such as the Physical Review Letters (PRL) convention for citations (list only the first author) may be used for publications with more than 10 authors.
- Synergistic Activities: List no more than 5 professional and scholarly activities related to the effort proposed.
Resources:
Timing:
- KR Federal Disclosure and Certification required prior to proposal submission and at least annually for the duration of the award
- Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award and at least annually for the duration of the award
- With the acquisition or discovery of a new significant financial interest during an active DOE award
Applies to: All Investigators on DOE proposals or flow-through excluding SBIR/STTR Phase 1 and Office of Indian Energy proposals are required to disclose their significant financial interests .
"Investigator(s)" include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the purpose, design, conduct, or reporting of research funded by DOE, or proposed for such funding, which may include, for example, collaborators or consultants. Note: DOE Program Officers retain discretion to expand the definition of an Investigator for a specific award.
- For non-UCI Investigators on the UCI's award/proposal and any subrecipients following UCI's DOE COI Policy, all individuals that meet the definition of an Investigator must submit the Form 800SR.
What to disclose:
"Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the Investigator's Institutional Responsibilities includes the following:
- Total income or payment of services received over the past 12 months and/or equity interest (includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value) in a publicly traded entity exceeding $5,000 when aggregated
- Total income or payment of services received over the past 12 months from a non-publicly traded entity exceeding $5,000
- Any equity interest (includes any stock, stock option, or other ownership interest) in a non-publicly traded entity
- Total payments received over the past 12 months for any intellectual property rights and interests (e.g., patent, copyright, assigned or licensed to a party other than the Regents) exceeding $5,000
- Any reimbursed or sponsored travel
The term "Significant Financial Interest" does not include: salary, royalties, or other remuneration paid by the UCI to the Investigator if the Investigator is currently employed or otherwise appointed by the UCI, including intellectual property rights assigned to the UCI and agreements to share in royalties related to such rights; income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; income from seminars, lectures, or teaching engagements sponsored by a US federal, state, or local government agency, a domestic institution of higher education, or a domestic research institute that is affiliated with an institution of higher education; or income from service on advisory committees or review panels for a US federal, state, or local government agency, a domestic institution of higher education, or a domestic research institute that is affiliated with an institution of higher education. All significant financial interests from a foreign entity (governmental, non-profit, for-profit, etc.) must be disclosed.
Resources
Resources:
Updated to reflect new DOE Financial Assistance Letter 2022-04 issued on June 1, 2022
Timing:
- Submit with application as required by funding opportunity announcements.
- After selection and during the life of the award, if there are changes to or additions of PIs or other senior/key personnel, such person(s) must also submit current and pending support disclosures within 30 days of joining the project team, or on a timeline consistent with the program office instructions.
- For all PIs and other senior/key personnel, if there are changes to the previously submitted current and pending support disclosures, the individuals must update their disclosures within 30 days of the change, or on a timeline consistent with the program office instructions.
Applies to: Principal Investigator and senior/key personnel, including subawardees
What to disclose:
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 involvement in foreign government-sponsored talent recruitment programs must be identified in current and pending support.
Program offices may also require disclosure of past support, limited to a reasonable time period to be determined by the program office.
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 and cost share. 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.
- If required to identify overlap, duplication of effort, or synergistic efforts, append a description of the other award or activity to the current and pending support.
Each current and pending support disclosure must be signed, dated, and include a certification statement. The information may be provided in the formats approved by the National Science Foundation (NSF):
- SciENcv: a signature, date, and a certification statement must be attached until the website automatically attaches a certification statement (anticipated Spring 2022).
- NSF Fillable PDF: a signature, date, and a certification statement must be attached.
Certification Statement:
“I, [Full Name and Title], certify to the best of my knowledge and belief that the information contained in this Current and Pending Support Disclosure Statement is true, complete, and accurate. I understand that any false, fictitious, or fraudulent information, misrepresentations, half-truths, or omissions of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (18 U.S.C. §§ 1001 and 287, and 31 U.S.C. 3729-3733 and 3801-3812). I further understand and agree that (1) the statements and representations made herein are material to DOE’s funding decision, and (2) I have a responsibility to update the disclosures during the period of performance of the award should circumstances change which impact the responses provided above.”
Resources:
Purpose: 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 risk review and mitigation process is led by DOE's Office of Research, Technology, and Economic Security (RTES).
Timing of Review
- Phase 1: A review is conducted on Notices of Funding Opportunities (NOFOs), Prize Rules, Partnership Intermediary Agreements (PIAs), Other Transaction Authorities (OTAs), and other such solicitations prior to publication. This ensures that appropriate language is included in the published document, such that potential applicants understand the RTES-related requirements to which their projects will be subject. This review also includes an assessment of the technology risk level of the solicitation.
- Phase 2: Before selection, financial assistance projects undergo an RTES due diligence review, with consideration of the technology risk assessment during Phase 1 review. For Loan applications, an RTES due diligence review is conducted prior to finalizing the application’s term sheet.
- Phase 3: During the life of a project, an RTES review may be triggered in situations where there are changes to the project, personnel, or ownership/control that could affect RTES. The entities selected for funding are responsible for notifying DOE of these types of changes, as outlined in their agreements with DOE. DOE, in turn, conducts its own due diligence to verify the information and will take a risk-based approach to continuous monitoring.
Resources
Department of Defense
May 5, 2025- DoD released updated Decision Matrix to Inform Fundamental Research Mitigation Decisions effective for proposal submitted after May 9, 2025.
Timing: With proposal application and possibly during an award's performance period as specified by the DOD agency
In general, researchers should disclose all paid or unpaid positions with non-profit or commercial entities or academic or research institutions, including honorary positions, affiliated positions, joint positions, participation in Talents Programs, and relevant honors. Biographical sketch requirements vary depending on the DOD agency and funding opportunity. Consequently, to help prevent accidental non-compliance, please carefully review the disclosure requirements associated with each funding opportunity announcement. Questions about biographical sketch requirement should be directed to the Contract and Grant Officer assigned to your unit.
In addition, please note that a DOD agency may require updated biographical sketch information during an award’s performance period. Please be sure to carefully read the award terms and conditions to learn when such updates, if required, must be submitted.
Note: In some cases, NIH biographical sketches could be used.
Timing: Submit with application
Applies to: Proposals for all non-procurement research and research-related educational activities (i.e., grants, cooperative agreements, Technology Investment Agreements) should include the below information for all key personnel, whether or not the individuals’ efforts under the project are to be funded by DoD in the Senior Key Person Profile form included in the Notice of Funding Opportunities
Please note that DOD proposals for other types of awards may have other requirements so please check the program solicitation.
What to disclose:
- List of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of source
- Title and objectives of other research projects
- Percentage per year to be devoted to other projects
- Total amount of support the individual is receiving in connection to each of the other projects or will receive if other proposals are awarded
- Name and address of agencies and/or other parties supporting the other research projects
- Period of performance of other research projects
Resources:
Timing: Prior to proposal application submission and at least annually for duration of the award
Applies to: All Covered Individuals
Ineligibility: Individuals who are a current party to a Malign Foreign Talent Recruitment Program are not eligible to serve as a covered individual on a DOD proposal or on any DOD award made after August 9, 2024.
What to certify: Each individual identified as a covered individual must certify in the KR Federal Disclosure and Certification prior to proposal submission that they are not a party to a malign foreign talent recruitment program and annually thereafter for the duration of the award.
Definitions:
- Covered Individual: An individual at an extramural research institution who contributes significantly to the design and/or execution of a fundamental research project that is, or if selected for award would be, funded, in whole or in part, by the Department of Defense, and who is considered essential to the successful performance of the fundamental research project. Covered individuals include those listed as key personnel in fundamental research project proposals, such as the principal investigator or co-principal investigators.
Resource:
DoD released a new DoD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions in effect for proposals submitted after May 9, 2025.
Some DoD components have issued their own risk rubric/procedures.
DARPA
DARPA released a memo to DARPA staff and contractors announcing their Countering Foreign Influence Program (CFIP) will create risk assessments of all proposed Senior/Key Personnel selected for negotiations of a fundamental research grant or cooperative agreement award. The CFIP risk assessment process will be conducted separately from the DARPA scientific review process and adjudicated prior to final award. More details are available in the risk rubric.
Resources:
- Countering Foreign Influence Program (CFIP) DARPA slides
- DARPA- Universities
- Countering Foreign influence Program Frequently Asked Questions
Army
The Army Research Risk Assessment Protection Program (ARRP) issued a Risk Matrix/Rubric and FAQs related to the identification and mitigation of conflicts of commitment/conflicts of interest in Army research grants and cooperatives agreements. These two resources are available on the ARRP website.
National Aeronautics and Space Administration
Oct. 1, 2024- New Grants and Cooperative Agreements Manual issued.
Timing: Submit with application
Applies to: Each senior/key person listed on a NASA grant or cooperative agreement proposal. NASA will designate as a senior/key person all Principal Investigators (regardless of level of effort), all co-Principal Investigators (regardless of level of effort), and co-Investigators (Co-Is) proposing to spend 10 percent or more of their time in any given year on a NASA-funded grant or cooperative agreement. NASA program offices may designate additional personnel categories as a senior/key person on a project-by-project basis, and these designations must be explicitly stated in all Notices of Funding Opportunities (NOFO).
What to disclose: Using the NASA Biosketch Form, include professional preparation, appointments and positions (domestic and foreign for period of up to 3 years from date application submitted), and products. There is no page limit.
Failure to disclose: If UCI discovers that a senior/key person has failed to disclose reportable information in the Biosketch, then UCI shall notify NASA within 30 calendar days per the award's terms and conditions. Upon receipt of the information, NASA will consult with UCI as necessary and take appropriate action.
Resources:
Timing: Submit with application and update in annual progress reports.
Applies to: Each senior/key person listed on a NASA grant or cooperative agreement proposal. NASA will designate as a senior/key person all Principal Investigators (PIs), all co-Principal Investigators (CoPIs), and co-Investigators (Co-Is) proposing to spend 10 percent or more of their time in any given year on a NASA-funded grant or cooperative agreement. NASA program offices may designate additional personnel categories as a senior/key person on a project-by-project basis, and these designations must be explicitly stated in all Notices of Funding Opportunities (NOFO).
What to disclose: Using the Current and Pending Support (CPS) Form, all senior/key personnel will need to disclose (a) 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 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.
Failure to disclose: If UCI discovers that a senior/key person has failed to disclose reportable information in Current and Pending Support, then UCI shall notify NASA within 30 calendar days per the award's terms and conditions. Upon receipt of the information, NASA will consult with UCI as necessary and take appropriate action.
Resources:
Timing: With proposal submission and award certifications
Applies to: Grants, cooperative agreements and contracts
What to do:
- Assistance Awards (Grants and Cooperative Agreements): Assure will not participate, collaborate, or coordinate bilaterally with China or any Chinese-owned company, at the prime recipient level or at any subrecipient level, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement. This assurance requirement imposes an award restriction which is broader than the "contracting with China" restriction under NASA contracts and extends to individuals performing part of the NASA-funded scope of work who have an affiliation with China or a Chinese-owned company.
- Contracts: Assure will not enter into bilateral written contracts or subcontracts with China for the performance of any part of the NASA scope of work.
Resources:
Timing:
- KR Federal Disclosure and Certification required prior to proposal submission
- Positive disclosures (Investigators with significant financial interests) are reviewed prior to the release of the award- COI Team will send a follow-up NSF/NASA question if the Investigator has a positive KR Federal Disclosure and Certification at award stage to determine if a COIOC review is required
- Investigators are required to disclose if they acquire or discover a new significant financial interests during the period of the NSF/NASA award
Applies to: All Investigators on NASA proposals and flow-through are required to disclose their significant financial interests.
"Investigator(s)" include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by NASA, or proposed for such funding, which may include, for example, collaborators or consultants.
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- For any non-UCI Investigators on the UCI proposal/award and any subrecipients following UCI's NSF/NASA COI policy, all individuals who meet the definition of an Investigator must complete the Form 900SR
What to disclose:
"Significant financial interests" (foreign and domestic) of Investigator, Investigator's spouse/registered domestic partner, and dependent children related the NASA project includes the following:
- Total income or payment of services received over the past 12 months exceeding $10,000
- Includes salary, consultant payments, honoraria, royalty payments, dividends, loan or any other payments or consideration with value, including payments made to the University Health Sciences Compensation Plan). Please exclude income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities and income from service on advisory committees or review panels for public or nonprofit entities
- Equity interest (e.g., stock, stock options, real estate, or any other investment or ownership interest in an entity exceeding $10,000 (current market value) or a 5% or greater ownership interest
- Any intellectual property rights and interests (e.g., a patent, patent application, copyright of software assigned or licensed to a party other than the UC Regents)
Related Financial Interest: Work to be performed under the sponsored project and results therefore that would reasonably appear to affect the Significant Financial Interest of the Investigator or the financial interests of the entity in which the Investigator has a financial interest.
Resources:
Update: The following requirements will be implemented on any proposal or award made after October 1, 2024.
Timing: Prior to proposal application submission and at least annually for duration of the award
Applies to: All Senior/Key Personnel
Ineligibility: Individuals who are a current party to a Malign Foreign Talent Recruitment Program are not eligible to serve as a senior/key person on a NASA proposal or on any NASA award made after October 1, 2024.
What to certify: Each individual identified as senior/key person must certify in the KR Federal Disclosure and Certification prior to proposal submission that they are not a party to a malign foreign talent recruitment program and annually thereafter for the duration of the award.
Resource: