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Research Security Disclosures and Training by Sponsor

Overview

In response to NSPM-33 and the CHIPS and Science Act, many federal agencies have started to require a new format for Current and Pending Support and Biographical Sketches, and many are starting to require Research Security Training. Each agency is implementing these changes slightly differently; therefore, this webpage organizes information by sponsor to easily identify the information that is applicable to your proposal. If a sponsor isn't listed, please follow the instructions provided in your solicitation or in the sponsor's proposal guide. In the new Common Format for Current and Pending Support and Biographical Sketches, please note the following:

  • Malign Foreign Talent Recruitment Program Certification – the new Common Form formats include the following certification, “…I am not a party in a malign foreign talent recruitment program.” For guidance on what a Malign Foreign Talent Recruitment Program is, see the chart available on MSU’s Research Security webpage.
  • Covered Individuals – Current and Pending Support and Biographical Sketch documents must be submitted by all Covered Individuals included in the proposal. An overarching definition was included in the CHIPS and Science Act (see Definitions section of this webpage); however, federal agencies differ on who falls under the Covered Individual definition. See additional guidance provided in the sponsor areas of this webpage or refer to your solicitation for guidance.
  • ORCID – the new Common Form formats include a Persistent Identifier (PID) field, and many federal agencies are requiring an ORCID ID be used as the PID. Visit the ORCID webpage to register for an ORCID ID.
  • SciENcv – some federal agencies have or will require Current and Pending Support and Biographical Sketches be created in SciENcv. Review the specific agency requirements below to determine if SciENcv is required.
  • Federal Disclosure Table – federal agencies worked together to create a disclosure table that helps determine what research activities need to be disclosed and where to disclose them. See the NSTC Pre-award and Post-award Disclosure as a resource for disclosures.
  • MSU Report – to assist MSU personnel with completing their Current and Pending/Other Support form, a report was created in MSU Business Intelligence (RA029). This report only reflects activity routed in MSU's Research Administration System (Kuali Research), and therefore, is not an all-inclusive list of what might need to be disclosed. Please visit the Current and Pending Report Job Aid for instructions on how to run the report and how to interpret the returned results.

Research Security Disclosures and Training by Sponsor

Agency Current & Pending Suport and Biographical Sketch RS Training Persistent Digital Identifiers / ORCID ID Covered Individual MFTRP COI / COC
NIH

Pre-award:
POSTPONED implementation of the Common Forms formats in SciENCv.

Other Support is being relabeled to Current and Pending Support and will continue to be collected at the Just-in-Time stage.

Biographical Sketch - Personal Statement, Contributions to Science, and Honors are not on the new Common Form, so NIH will collect as a separate form/attachment.

Post-award:
Updates to Current and Pending support should be included in annual RPPRs.

Has not been announced by NIH.

POSTPONED the mandatory date.

Still recommend signing up for an ORCID ID and linked in eRA Commons profile.

Senior Key Personnel – excludes Other Significant Contributors.

MFTRP certification will be implemented with the Common Forms. Transition to the Common Forms has been postponed.

Institution policy required.

Pre-award:
Must disclose SFIs before application submission.

Post-award:
Disclosures must be updated within 30 days of obtaining new SFI or at least annually during period of award.

NSF

Pre-award:
May 2024 – Required the Common Form formats and must be completed in SciENcv.

At the Just-in-Time stage, NSF is asking for updated Current and Pending documents.

Post-award:
Changes to Current and Pending Support should be reported in annual technical reports.

Required with PAPPG 26-1, planned for October 2025 implementation.

ORCID ID is currently optional. It becomes mandatory with PAPPG 26-1, planned for October 2025 implementation.

Senior Key Personnel

Pre-award:
Covered individual certifies on Current and Pending Support and Biographical Sketch form that are included in proposal submission.

Institution policy required.

Pre-award:
Investigators are required to provide all financial disclosures at proposal submission.

Post-award:
All financial disclosures to be updated during award period.

DOE

Pre-award:
Common Form formats are currently required. Use of SciENcv to generate the Common Forms is required in May, 2025.

Post-award:
Changes to Current and Pending Support should be disclosed within 30 days of the change or on a timeline provided by the program office.

Pre-award:
Mandatory for any solicitation due after May 1, 2025. Must be completed within the 12-months prior to the application. Certify via the Current and Pending Support disclosure.

Post-award:
Any new covered individual at the recipient and subrecipient level added to the project must certify within 30 calendar days of joining project.

Covered individuals previously identified by the recipient who have already certified and completed the research security training do not need to complete it again for this project, even if they are submitting an updated Current and Pending Support Form during the life of the award.

Pre-award:
Mandatory for any solicitation due after May 1, 2025. Required to submit in Biographical Sketch and Current and Pending disclosure.

Varies by solicitation.

Pre-award:
Certify not participating in MFTRP as a certification on Current and Pending and Biographical Sketch disclosures.

Post-award:
Notify DOE if there are any changes to MFTRP participation status within 5 business days of the proposed change.

Pre-award:
Covered Individuals must provide required disclosures for COIs and COCs on or before proposal submission.

Post-award:
Disclosures must be updated on an annual basis and as soon as any new, actual, apparent or potential COC arises.

DOD

Pre-award:
Potentially implementing the Common Form formats in May 2025. Check the solicitation for requirements.

Has not been announced.

Potentially in May 2025.

Varies by solicitation.

Will be implemented with the Common Forms.

 

NASA

Pre-award:
In October 2024, required the Common Form formats, which can be found on the 2024 Grants and Compliance page.

Post-award:
Changes to Current and Pending Support must be submitted to the NASA Program Officer within 30 calendar days.

Has not been announced.

Suggests using ORCID ID, but does not require it.

Varies by solicitation.

Pre-award:
Certify not participating in MFTRP as a certification on Current and Pending and Biographical Sketch disclosures.

Post-award:
Certifications will need to be signed and submitted annually.

Pre-award:
Initial disclosure must be made at the time of application.

Post-award:
Disclosure must be updated during the period of award performance either annually, or as new SFIs are disclosed.

MFTRP = Malign Foreign Talent Recruitment Program

Common Forms = Current and Pending/Other Support and Biographical Sketch format – includes MFTRP certification statement and requires individual's signature

SFI = Significant Financial Interest

Impacts To Proposal Process

MFTRP Common Form RS Training ORCID ID Non-MSU Covered Individuals (CIs)

MSU faculty/staff:
Must have an updated annual disclosure that includes a response to the MFTRP question prior to proposal submission. This response feeds into the Kuali Research system.

Common Forms must be signed prior to proposal submission. It is the unit's responsibility to retain the version with the electronic signature, where applicable. We recommend uploading to Kuali Research.

MSU faculty/staff:
Training certificates must be provided to OSP prior to proposal submission. Working toward having training completion dates feed into Kuali Research.

Senior/Key persons will have to create their ORCID ID and link it within SciENcv and some sponsor systems (e.g. NIH's eRA Commons). KR has an ORCID ID field, but it does not populate federal forms or systems.

Subrecipients:
Updating our subrecipient commitment form to add certifications for MFTRP and Research Security training.

Other Non-MSU CIs:
Asking the Big Ten to see how others are verifying compliance for these individuals. MSU is thinking of creating a separate certification form.

MFTRP = Malign Foreign Talent Recruitment Program

Common Forms = Current and Pending/Other Support and Biographical Sketch format – includes MFTRP certification statement and requires individual's signature

CI = Covered Individual

Current & Pending / Biographical Sketch Requirements

National Institutes of Health (NIH)

Here is a short summary about current and pending requirements for the National Institutes of Health (NIH) as a sponsor.

Current and Pending Requirements

Biographical Sketch Requirements

Research Security Training

National Science Foundation (NSF)

Here is a short summary about current and pending requirements for the National Science Foundation (NSF) as a sponsor.

Current and Pending Requirements

Biographical Sketch Requirements

Research Security Training

Department of Defense (DOD)

Here is a short summary about current and pending requirements for the Department of Defense (DOD) as a sponsor.

Current and Pending Requirements

Biographical Sketch Requirements

Research Security Training

Department of Energy (DOE)

Here is a short summary about current and pending requirements for the Department of Energy (DOE) as a sponsor.

Current and Pending Requirements

Biographical Sketch Requirements

Research Security Training

National Aeronautics and Space Administration (NASA)

Here is a short summary about current and pending requirements for the National Aeronautics and Space Administration (NASA) as a sponsor.

Current and Pending Requirements

Biographical Sketch Requirements

Research Security Training

Definitions:

CHIPS and Science Act

The CHIPS and Science Act is a federal statute signed into law on August 9, 2022 that will boost American semiconductor research, development, and production, ensuring U.S. leadership in the technology that forms the foundation of everything from automobiles to household appliances to defense systems. CHIPS and Science Act

Conflict of Interest

According to the 18 U.S.C.§208, a conflict of interest is a personal interest or relationship that conflicts with the faithful performance of official duty. – Situation in which an individual, or the individual’s spouse or dependent children, has a significant financial interest, or financial relationship that could directly and significantly affect the design, conduct, reporting, or funding of research.

Conflict of Commitment

A conflict of commitment is a situation in which an individual accepts or incurs conflicting obligations between or among multiple employers or other entities. Many organizational policies define conflicts of commitment as conflicting commitments of time, including obligations to dedicate time in excess of institutional or funding agency policies or commitments. Other types of conflicting obligations, including obligations to share information improperly with, or to withhold information from, an employer or funding agency, can also threaten research security and integrity, and are an element of a broader concept of conflicts of commitment.

Covered Individual

The CHIPS and Science Act defines a “Covered Individual” as an individual who (A) contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and (B) is designated as a Covered Individual by the Federal research agency concerned.

The definition of “Covered Individual” can be sponsor and solicitation specific. For example, DOE has indicated that they have three different definitions of Covered Individuals for their program offices, and that their solicitations will vary, so it’s important to carefully review each solicitation.

*NOTE: the definition of a “covered individual” can vary by sponsor, and by individual sponsor solicitation. It is important to read through each solicitation to understand how this term is defined.

Foreign Country of Concern

The term "foreign country of concern" means:

  1. A country that is a covered nation (as defined in 10 U.S.C. 4872(d)); and
  2. Any country that the Secretary, in consultation with the Secretary of Defense, the Secretary of State, and the Director of National Intelligence, determines to be engaged in conduct that is detrimental to the national security or foreign policy of the United States. Preventing the Improper Use of CHIPS Act Funding.

Malign Foreign Talent Recruitment Program

Foreign government-sponsored talent recruitment program operated with the intentto import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. For additional information and resources to help identify Malign Foreign Talent Recruitment Programs, please visit the chart on MSU’s Research Security website.

Persistent Digital Itentifier

A digital identifier that is globally unique, persistent, machine resolvable and processable, and has an associated metadata schema. Consistent with NSPM-33, digital persistent identifiers for individuals are used to disambiguate and identify an individual person.ORCID ID is a Persistent Digital Identifier.

Principal Investigator

A Principal Investigator or PI is the individual responsible for the preparation, conduct, and administration of a research grant, cooperative agreement, training or public service project, contract, or other sponsored project.

Research Security

Safeguarding the research enterprise against the misappropriation of research and development to the detriment of national or economic security, related violations of research integrity, and foreign government interference.

Resources:

 

The Office of Research and Innovation hosts a helpful Research Security webpage to help faculty and staff stay current on emerging and federal guidelines.The website includes information on Research Security Training, understanding whatisand whatis nota Malign Foreign Talent Recruitment Programs, and Cybersecurity guidance related to encryption and travel security. Faculty can send specific questions about Malign Foreign Talent Recruitment programs to ORI.TalentPrograms@msu.edu

The Council of Government Relations maintains a Quick Reference Table of Current and Upcoming Federal Agency Requirements/Tools Concerning Implementation of NSPM-33

Since DoD is a member of the NSTC group, it is expected to require the Common Disclosure Form, (SciENcv), as well as the NSF created training modules. Institutions must have a policy prohibiting Malign Foreign Talent Recruitment Programs.

DOE has created a dedicated RTES webpage to increase transparency and inform the research community about their phased approach to changes to proposal requirements.

NASA: The 2024 Grant and Cooperative Agreement Manual contains information on NASA’s new Biosketch and Current and Pending Support requirements. NASA pre-award disclosure requirements can be found in section 10.5 Biographical Sketches; 10.6 Current and Pending (Other) Support Disclosures; and 10.9 Facilities, Equipment, and Other Resources.Post award disclosure requirements can be found in section 29.8.

For further training on the biosketch and current and pending support forms, GPC has a training video on the subject on the NASA Grants YouTube playlist: NASA – Biographical Sketch and Current and Pending Support Disclosure Requirements

NIH: With NOT-OD-24-163, NIHintends to adopt ScIEnCV for all submissions of Biographical Sketches and Current and Pending (Other) Support starting May 25, 2025. With regard to Biosketches, NIH will collect Personal Statement, Contributions to Science, and Honors separate from Common Forms. NIH is currently using this Other Support guidance, which contains links to the Other Support Format page, and information about NIH disclosure requirements.

NSF: The Proposal & Award Policies and Procedures Guide (PAPPG) is always an excellent resource for information regarding Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C § 19232) and certifications regarding Malign Foreign Talent Recruitment Programs and Research Security Training. In addition to the PAPPG, National Science Foundation has developed other resources such as NSPM-33 Implementation Guidance that explain disclosure requirements for Current and Pending Support forms and Biographical Sketches.

NSPM-33 Implementation Guidance

In cooperation with the National Science and Technology Council (NSTC) as well as several other Federal agencies, National Science Foundation has developed other resources such as NSPM-33 Implementation Guidance that explain disclosure requirements for Current and Pending Support forms and Biographical Sketches.

The U.S. National Science Foundation, in partnership with the National Institutes of Health, the Department of Energy and the Department of Defense, is sharing online research security training for the research community.

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