Important Reminders Regarding Current and Pending (Other) Support and Biosketch Disclosures (Effective May 20, 2024 for NSF)
Dear Principal Investigators and Senior/Key Personnel:
We write to remind you of significant changes to Current and Pending (Other) Support and Biosketch disclosures that will take effect beginning May 20, 2024 for the National Science Foundation, and later this year for Department of Defense, National Institutes of Health and other federal funders. See this Research Security Update hand-out with more information. The key details are below:
- New Certification: No participation in malign foreign talent recruitment programs (MFTRPs)
The CHIPS & Science Act of 2022 (“CHIPS Act”) prohibits federally-funded senior and key persons from participating in any MFTRPs. By definition, MFTRPs must involve China, Iran, North Korea, or Russia, or entities in those countries, and must meet certain other criteria. Researchers who participate in MFTRPs are not eligible to serve as senior/key persons on federally funded projects.
The definition of MFTRP is complex. If you are not certain whether an engagement meets the definition, please contact [email protected] for a consultation.
As of May 20, 2024, NSF will require senior/key persons to certify on their Current and Pending Support and Biosketch disclosures that they are not currently participating in an MFTRP. Researchers must use SciENcv to complete these disclosures. The SciENcv forms will automatically include the certification for completion.
The Department of Defense MFTRP certification requirement will take effect in August 2024, but the mechanism has not yet been announced. Because the mechanism is unclear, we are developing a stand-alone institutional certification for Department of Defense funded individuals. More about this stand-alone certification will be forthcoming.
NIH’s MFTRP certification requirement will take effect in January 2025.
False representations regarding this MFTRP certification 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.
Anyone with questions regarding MFTRPs should feel free to contact the Office of Research Compliance and Training at [email protected].
- Disclosure of Consulting Required in Current and Pending (Other) Support
New, federal-wide Current and Pending (Other) Support disclosure forms require disclosure of consulting activities under the proposals and active projects section of the 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.
- Disclosure of Start-up Companies Based on Non-Organizational Intellectual Property in Current and Pending (Other) Support
The new Current and Pending (Other) Support forms require senior and key persons to disclose any start-up companies if they are based on non-organizational intellectual property. This would include, for example, start-up companies based on intellectual property relinquished by Columbia University or never owned by Columbia University.
- Biographical Sketch: 3-Year Look-back for Professional Appointments
The new, federal-wide biographical sketch requires disclosure of all academic and institutional appointments in reverse chronological order. It also requires disclosure of all domestic and foreign professional appointments and positions for a period of three years prior to the date the applicant submits the funding application. Examples of professional appointments could include service as a grant reviewer or on the board of an academic society or journal.
Over the past several years, Current and Pending (Other) Support and Biosketch disclosures have taken on additional importance, as you know, and funding agencies are scrutinizing them closely. Please treat them with the greatest seriousness, ensure they are current, accurate, and complete, and if you have questions, please do not hesitate to contact your SPA project officer or the Office of Research Compliance and Training. More information is also available on the University’s Research Security webpage and on the federal-wide common disclosure webpage.
Thank you.
Naomi Schrag William Berger
VP for Research Compliance, Training and Policy AVP for Sponsored Projects Administration