Over the past several years, Current and Pending (Other) Support and Biosketch disclosures have taken on additional importance, and funding agencies are scrutinizing them closely.
The U.S. Government has implemented common disclosure forms for “Current and Pending (Other) Support Information” and “Biographical Sketch” (“Common Forms”) The Common Forms are part of the Government’s effort to harmonize disclosure requirements across federal agencies. The Common Forms and related definitions are available on NSF’s website at https://www.nsf.gov/bfa/dias/policy/nspm-33-implementation-guidance.
Please treat these disclosures 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.
Key information is summarized below and in these general FAQs. For agency-specific information, please see the agency-specific links at the bottom of this webpage.
What is Current and Pending (Other) Support?
Many sponsors require that applicants provide summaries of their current and anticipated grant and contract funding, and other resources that may be available for the individual’s research. The definition of what must be disclosed has expanded over the last several years.
Current and Pending (Other) Support includes “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…. This includes resources and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and participation of student and visiting researchers supported by other sources of funding. Information requested usually includes sponsor, project title, period of performance, committed effort, amount funded or sought and in-kind contributions.”
The Common Forms also require disclosure of certain consulting activities in Current and Pending (Other) Support, including consulting that requires performing research; consulting that is related to the individual’s research portfolio and may have the ability to impact funding, time or effort commitments, or otherwise impact scientific integrity; or consulting that requires the individual to conceal or withhold information about the activity.
Please review these consulting frequently asked questions regarding the circumstances under which consulting activity must be disclosed.
Columbia Policy on Disclosure of Current and Pending (Other) Support
In accordance with funding agency policies, Columbia University requires all Senior/Key Personnel to disclose all active and pending sources of funding and in-kind contributions to their research, as required by funding agencies. This Current and Pending (Other) Support disclosure requirement includes all resources, regardless of monetary value or institutional source, that are made available to a researcher in support of and/or related to their research endeavors, as defined in the Common Forms. Faculty and other Senior/Key Personnel must ensure that such disclosures are current, accurate, and complete, and must update them throughout the life of the award. The University maintains mandatory training and oversight procedures to help ensure compliance with these requirements. Failure to comply may result in corrective action and/or sanctions in accordance with University policies, sponsor terms and conditions, and federal law and regulation.
Biographical Sketches/Biosketches
Senior personnel (or Senior Key Personnel), as well as Other Significant Contributors (NIH only), are required to submit biographical sketches as part of the grant or contract proposal package, and occasionally in progress reports. They are also provided whenever new senior/key persons are added to an award. The biographical sketch must include:
“A list, in reverse chronological order by start date, of all the individual’s academic, professional, or institutional appointments and positions, beginning with the current appointment (including the associated organization and location). Appointments and positions include any titled academic, professional, or institutional position, whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
Senior/key persons must only identify all domestic and foreign professional appointments and positions outside of the primary organization for a period up to three years from the date the applicant submits the application to the agency for funding consideration.”
NIH, NSF, and USDA Supporting Documentation Requirements
NIH, NSF, and USDA require submission and/or retention of written contracts or other agreements for appointments, consulting or employment specific to foreign (non-U.S.) appointments, employment, or other foreign activity disclosed in Current and Pending (Other) Support. NIH and USDA require including this supporting documentation as part of Current and Pending (Other) Support, e.g., at Just-in-Time or in progress reports, with an English translation as needed. NSF requires providing the agency such documentation upon request.
Columbia has established the Rascal Upload Foreign (Non-U.S.) Agreement module to collect this supporting documentation. Senior or Key Personnel on submissions to NIH, NSF and/or USDA are expected to upload copies of this supporting documentation to the Rascal module.
Columbia is collecting this supporting documentation to meet the requirements of federal sponsors for the sole purpose of identifying risks to the University and its research programs and/or to provide the documentation upon request from the sponsor. Columbia will not review the supporting documentation for any other purpose, including providing individual legal advice.
Required Certifications
The Common Forms require each senior/key person to certify that the information provided is current, accurate, and complete, and that the individual is not a party to a malign foreign talent recruitment program (MFTRP). Individuals who participate in MFTRPs are ineligible to serve as senior/key personnel on federal awards. More information about MFTRPs is available on the University’s research security website.
It is of utmost importance that researchers ensure the accuracy of their Common Form submissions. The Common Forms state that misrepresentations and/or omissions 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.