Biographical Sketch Common Form provides instructions for submission of a bio sketch by each individual identified as a covered individual or senior/key person on a federally funded research project.

The bio sketch is used to assess how qualified the individual, team, or organization is to conduct the proposed activities.

The SciENcv Biographical Sketch and Current and Pending (Other) Support documents require each individual to certify that the information provided is accurate, current, and complete, and that they are not a party to a malign foreign talent recruitment program.

Current and Pending (Other) Support Common Form is used to assess the capacity or any conflicts of commitment that may impact the ability of the individual to carry out the research effort as proposed. The information also helps assess any potential scientific and budgetary overlap/duplication with the project being proposed. 

The SciENcv Biographical Sketch and Current and Pending (Other) Support documents require each individual to certify that the information provided is accurate, current, and complete, and that they are not a party to a malign foreign talent recruitment program.

In addition to prohibiting participation in Malign Foreign Talent Recruitment Programs (FTRPs), the CHIPS Act requires that federally-funded researchers disclose participation in any FTRP, regardless of the country involved.

The Office of Science and Technology Policy defines an FTRP as follows:

“Effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation.”

There are multiple units within DOD, so different formats may be required depending on which unit a proposal is submitting to. DOD provides a resource page identifying suggested templates for many of their proposal documents. 

Recently, the Department of Defense (DOD) issued a document describing how it will evaluate “undue foreign influence” risk factors when reviewing proposals for fundamental research. Under DOD’s risk matrix, participation in an FTRP that meets one or more of the criteria in Part A of the CHIPS Act definition of “malign foreign talent recruitment program” (see Malign FTRP) requires mitigation and, if no mitigation is possible, rejection of the proposal.  DOD’s Risk Matrix is available here.

Other agencies may also consider participation in an FTRP to be a research security risk factor.  However, without further guidance from these agencies, it is unclear the extent to which participation in FTRPs could impact future funding decisions.

DOE issued Department of Energy’s Interim Conflict of Interest Policy Requirements for Financial Assistance in December 2021.  

Projects falling under this requirement must disclose significant financial interests no later than the time of application, submit an updated disclosure of significant financial interests at least annually, submit an updated disclosure of significant financial interests within thirty days of discovering or acquiring a new significant financial interest, and include a signed and dated certification statement. 

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DOE contracts require disclosure of investigators’ affiliations, if any, with “foreign government-sponsored talent recruitment programs” in certain countries. This requirement applies to subcontracts to the University that involve work by an investigator at a DOE or contractor facility.

Definition of “Foreign government-sponsored talent recruitment program” 

In general, such programs include any foreign-state-sponsored attempt to acquire U.S. scientific-funded research or technology through government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the U.S. These recruitment programs are often part of broader whole-of-government strategies to reduce costs associated with basic research while focusing investment on military development or dominance in emerging technology sectors.

Distinguishing features of a foreign government talent recruitment program covered by this Order include:

1. Compensation provided by the foreign state to the targeted individual in exchange for the individual transferring their knowledge and expertise to the foreign country. The compensation can take several forms, such as cash, research funding, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or other consideration.
2. Recruitment in this context refers to the foreign-state-sponsor’s active engagement in attracting the targeted individual to join the foreign-sponsored program and transfer their knowledge and expertise to the foreign state. The targeted individual may be employed and located in the U.S., or in the foreign state. Recruitment would not necessarily include any invitation for engagement extended by the foreign state, for example, an invitation to attend or present work at an international conference.
3. Many, but not all, programs aim to incentivize the targeted individual to physically relocate to the foreign state. Of particular concern are those programs that allow for continued employment at U.S. research facilities or receipt of DOE research funds while concurrently receiving compensation from the foreign state.

A copy of the DOE Order implementing this requirement can be reviewed here.  

The Center for Security and Emerging Technology (CSET) has created a tracker to catalog publicly available information about Chinese Talent Recruitment Programs. The Chinese Talent Program Tracker is a catalogue of Chinese Party-State-sponsored initiatives aimed at cultivating China’s domestic talent pool in support of China’s strategic civilian and military goals. To learn more, visit the CSET website.

EPA includes templates for various application forms on their Required Forms website. 

EPA required the authorized representative (AOR) to certify that each covered individual has been made aware of the certification requirements identified in the William M. Thornberry National Defense Authorization Act for Fiscal Year 2021, Section 223(a)(1) (page 84 of 1482).

Disclosure Requirement

Each covered individual listed on the application must –

• • Disclose the amount, type, and source of all current and pending research support received by, or expected to be received by, the individual as of the time of the disclosure:
  • Certify that the disclosure is current, accurate, and complete; and
  • Agree to update such disclosure at the request of the agency prior to the award of support and at any subsequent time the agency determines appropriate during the term of the award.

False representations 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.

The template provided here is required to gather signatures for certification.

NASA Grants Policy and Compliance has published Grant Notice 24-01 informing NASA grant and cooperative agreement recipients and applicants about upcoming changes to NASA’s grant policies effective October 1, 2024, which implement revisions to 2 CFR and National Security Presidential Memorandum-33.

NASA forms (and samples of forms) can be found on the Grants Policy and Compliance website.

While changes to policy are effective for grants being awarded on or after October 1, 2024, GPC recognizes that upcoming requirements around biosketch and current and pending (other) support (CPS) disclosures could change for proposers while there is an open Notice Of Funding Opportunity (NOFO). As such, if a proposal is submitted that does not comply with the changes, and has been selected for funding, the NASA Shared Services Center will request and collect the new required forms and certifications from entities post-application and pre-award.

NASA Pre-award and Post-award Disclosure Requirements

NASA now requires applicants and awardees to disclose:

“all ongoing and pending projects and proposals (regardless of salary support) in which they are performing or will perform any part of the work. Co-Is proposing to spend 10% or more of their time in any given year to the proposed effort shall provide a list of ongoing and pending projects and proposals (regardless of salary support) that require more than 10% of their time in any given year. …PIs and Co-PIs also shall list their current and pending support with Chinese universities and other similar institutions or a Chinese-owned company at the prime recipient level and at all subrecipient levels, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement.

NASA researchers are now required to disclose the following information within their Current & Pending documents (see Common Forms)

• Financial Support. This includes sponsored awards held at UU, held at another institution/entity, or held as an individual that support an investigator’s research efforts.
• In-kind contributions. This includes non-monetary resources that are uniquely available to key personnel such as office/laboratory space, equipment, supplies, employees, students.
• Chinese affiliations. This includes funded and unfunded support received from a Chinese entity whether such support is held at UU, held at another institution/entity, or held as an individual that support an investigator’s research efforts.

Per the NASA Grant and Cooperative Agreement Manual (GCAM), all senior/key personnel receiving funding from a NASA grant or cooperative agreement are required to comply with the disclosure requirements described below.

The table includes the following columns:

• Type of activity to be disclosed: This column describes the information that senior/key personnel shall disclose to NASA.
• Biographical Sketch; Current & Pending (Other) Support; and Facilities, Equipment, & Other Resources:
  • Activities with a check mark in “Biographical Sketch” or “Current & Pending (Other) Support” shall be disclosed in the relevant disclosure form. Activities with a check mark in “Facilities, Equipment & Other Resources” shall be disclosed in the Facilities, Equipment, & Other Resources section of the award proposal.
• Project Reports:
  • If an activity has a check mark in the “Project Reports” column, then changes to that activity must be reported post-award.
  • Senior/key personnel shall make new disclosures by submitting an updated current and pending support form as part of their annual performance reports, and the performance report itself shall indicate that updated disclosures are being provided.
• Post-award Information Term & Condition:
  • Activities with a check mark in this column are required to be disclosed if it is determined that a senior/key person failed to disclose the information at the time of proposal submission or in a performance report.
  • These disclosures shall be provided via email to the award recipient’s cognizant NASA Grant Officer and Technical Officer within 30 calendar days per NASA’s terms and conditions .
• Disclosure Not Required: Activities with a check mark in this column do not need to be disclosed to NASA.

NIH will begin using the common forms in January of 2025 and is expected to require the use of SciENcv as well by Spring 2025. Until the common forms are implemented at NIH, the currently approved forms for Biosketch and Other Support should be used.

It is recommended that anyone involved in the creation of these forms should familiarize themselves with the samples on the NSF website above before implementation.

National Science Foundation (NSF) will require using the new common forms and their disclosures in SciENcv starting May 20, 2024 when the newest PAPPG (NSF 24-1) goes into effect.

NSF is the steward for the sample forms and they can be found on their website along with a table entitled, NSPM-33 Implementation Guidance Pre- and Post-Award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support, which will provide guidance on how to fill out the forms.

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NSF policy now requires applicants and awardees to disclose “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. Current and pending support also includes in-kind contributions (such as office/laboratory space, equipment, supplies, employees, students). In-kind contributions not intended for use on the project/proposal being proposed also must be reported. Current and pending support information must be provided for this project, for ongoing projects, and for any proposals currently under consideration from whatever source, irrespective of whether such support is provided through the proposing organization or is provided directly to the individual.”

With this clarification, NSF researchers are now required to disclose within their Current & Pending document as follows;

• Financial Support. This includes sponsored awards held at UU, held at another institution/entity, or held as an individual that support an investigator’s research efforts. This also includes start-up packages from entities other than UU. Investigators do not need to disclose UU start-up packages or gifts.
• In-kind contributions. This includes non-monetary resources that are uniquely available to key personnel such as office/laboratory space, equipment, supplies, employees, students. The location of the disclosure of in-kind contributions within the proposal depends upon whether there is a time commitment associated and if the contribution is to be used for the proposal being submitted (see chart below). Such disclosures do not need to be replicated across proposal documents.

See the NSF Disclosure Table (May 2024)

NSF policy remains consistent regarding location and timing of such disclosures, and all current and pending support must be reported within the proposal.

Post-award Disclosure of Current Support and In-Kind Contribution Information

Effective October 5, 2020, the National Science Foundation (NSF) standard terms and conditions establishes a post-award disclosure requirement for undisclosed current support and in-kind contribution information.

Therefore, as of this date if the University discovers that a PI or Co-PI on an active NSF award failed to disclose current support or in-kind contributions within their proposal, OSP must submit a notice to NSF informing them of the undisclosed support or contribution within 30 days of identification of the oversight.

NSF will review the disclosure and, after possible consultation with OSP, determine the impact of the new information on the award and, where necessary, take appropriate action.

Researchers and research administrators are encouraged to review submitted current and pending documents to ensure that all required disclosures have been made.  In the event current support or in-kind contributions not previously disclosed to NSF are identified, please notify your assigned SPO as soon as possible.

Biographical Sketch

With the release of the PAPPG effective June 1, 2020, NSF researchers are now required to disclose within their Biographical Sketch as follows;

• Positions, Appointments, and Affiliations. All academic, professional, or institutional appointment held by investigators whether current or previously held must be disclosed including domestic or foreign, paid or unpaid, or full/part-time/voluntary. Titled academic, professional, or institutional appointments, including adjunct, visiting, or honorary must be disclosed.

These clarified requirements extend the scope of required reporting beyond that which is attributable to an investigator’s affiliation with the University. Investigators must complete and update their Biographical Sketch based on the totality of their positions, appointments, and affiliations, both within and outside of the University.

International Partnerships

Within each proposal, applicants are required to mark intended partnerships with international collaborators on the NSF Cover Page under three circumstances;

• International Activities: Each proposal that describes an international activity, defined as research, training, and/or education carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies, must list the country(ies) with which project participants will engage on the NSF Cover Page.
• Funding of an International Branch Campus of a U.S. Institution of Higher Education (IHE): Each application that proposes to fund an international branch campus of a U.S. university (e.g. Weill Qatar) must check the International Activities Country Name(s) box and enter the name of the applicable country(ies) on the NSF Cover Page.
• Funding of a Foreign Organization: Each application that proposes to fund a foreign organization, including through use of a subaward or consultant arrangement, must check the Funding of a Foreign Organization box and enter the name of the applicable country(ies) on the NSF Cover Page.

Before naming a foreign individual or organization as a collaborator, request a Restricted Party Screening.

USDA includes templates for various application forms on their Application Support Templates website.