Information about NIH Foreign Disclosure and Risk Management can be found on their website. There, you will find NIH guidance on disclosure requirements, foreign risk case studies, post-award monitoring and reporting requirements and more. The NIH notices detailing the requirements can be found below.

HELPFUL NIH RESOURCES

1. UC Other Support Questionnaire to Faculty
2. UC Other Support Checklist
3. UC RPPR
4. Collaborative Relationships and Foreign Components
5. NIH FAQ PAGE: BIOSKETCH
6. NIH FAQ PAGE: OTHER SUPPORT and FOREIGN COMPONENTS
7. UC NIH Biosketch Training Video
8. UC NIH Other Support Training Video

May 4, 2021: NIH Issues Announcement on the Implementation of Changes to the Biographical Sketch and Other Support Format Page

NIH has issued a follow-up notice to NOT-OD-21-073 on the upcoming changes to the biographical sketch and other support format pages. Per the new announcement NOT-OD-21-110, “NIH expects* applicants and recipients to use the updated biosketch and other support format for applications, Just-in-Time (JIT) Reports, and Research Performance Progress Reports (RPPRs) as of May 25, 2021. NIH will require* the use of the updated format pages for the previously mentioned submissions for anything on and after January 25, 2022.”
*emphasis added.

In addition, NIH states:

“Please note, applicants and recipients remain responsible for disclosing all research endeavors regardless of the version of the forms used. Therefore, if applicants and recipients choose not to use the updated format pages before they are required, applicants and recipients must still capture all the necessary information.”

As of this most recent Notice, NIH has not specified a limited lookback period for disclosures under Section B of the biographical sketch, “Positions, Scientific Appointments and Honors. As we have previously advised, for biographical sketches being submitted with NIH institutional training grants due May 25,if you are pressed for space, we encourage you to prioritize disclosure of Scientific Appointments held during the last three years, both domestic and foreign, including any affiliations with foreign entities or governments. A scientific appointment can include participation in study sections, membership in a scientific society, board membership, and some consulting appointments.

Allpositions, however, should be included. This includes employment history or any kind of institutional appointment, whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

April 5, 2021: NIH Upcoming Changes to the Biographical Sketch and Other Support Format Page Starting May 25, 2021

On March 12, 2021, the National Institutes of Health (NIH) announced the following information:

In an effort to support strong collaboration between Federal research agencies, NIH has made every effort to align the Biographical Sketch (Biosketch), Other Support format page and Application Form Instructions with the guidance issued by the Office of Science and Technology Policy Joint Committee on the Research Environment.

NIH has updated its application forms and instructions to support the need for applicants and recipients to provide full transparency and disclosure of all research activities, foreign and domestic.

SIGNIFICANT CHANGES TO OTHER SUPPORT:

Certification statement and signature block added for Program Director/Principal Investigator and Other Senior/Key Personnel to certify the accuracy of the information submitted. Each PD/PI and senior/key personnel must electronically sign their respective Other Support form as a PDF prior to submission.

The updated forms and instructions and updated format pages will be required for use for applications and Research Performance Progress Reports (RPPR) submitted for due dates on or after May 25, 2021.

During the transition to the new Biosketch format, NIH will not withdraw applications that include the previous Biosketch format. Beginning with applications submitted on or after January 25, 2022, failure to follow the appropriate Biosketch format may cause NIH to withdraw your application from consideration.

Updated Biosketch resources, including FAQs and sample Biosketch format pages, are available on the NIH Biosketch Forms and Instructions page.

Updated Other Support resources, including FAQs and sample Other Support format pages, can be found on the NIH Other Support Forms and Instructions page.

For complete details, refer to NIH Notice NOT-OD-21-073.

Please share this with all faculty and staff who may need this information.

If you have any questions, please contact the Conflict of Interest Office.

Research Security policy, guidance, training and other information can be found on the National Science Foundation (NSF) Research Security Webpage.

On this page, NSF details the agency research security goals, describes the SECURE Center and SECURE Analytics and how both will assist institutions and researchers in compliance to research security regulations, outlines the benefits of international collaboration and the listing of the relevant NSF policies and actions related to research security. Additionally, NSF describes the TRUST framework. This framework was developed to assess grant proposals for potential risk and hopes to identify and mitigates risks as early as possible in the award process. Lastly, NSF provides information on foreign interference and risk mitigation and why it is important to disclose and be transparent about collaborations, affiliations, and conflicts of interests/commitments.

Completing Grant Applications

The information below is intended to guide users to complete the DOD Current & Pending Support, Biosketches and Facilities, Equipment and Other Resources, beginning October 1, 2020.

Note that in addition to the traditional forms of support, some Institutional resources must also be disclosed.

Current & Pending Support, Biosketches and Facilities, Equipment and Other Resources

Current and Pending Support and Biosketches must be provided for all senior personnel and faculty associates. The term "senior personnel" includes:

(Co)Principal Investigator(s) - the individual(s) designated by the grantee and approved by DOD who will be responsible for the project's scientific or technical direction. If more than one, the first one listed will have primary responsibility for the project and the submission of reports.

Faculty Associate (faculty member) - an individual other than the Principal Investigator(s) considered by the performing institution to be a member of its faculty or who holds an appointment as a faculty member at another institution and who will participate in the project.

Current & Pending Support

On March 20, 2019, the Department of Defense issued a memorandum that established new current and pending support requirements for Notices of Funding Opportunities for research and research-related educational activities. These requirements were implemented for the following purposes:

1. To support the protection of intellectual property, controlled information, key personnel, and information about critical technologies relevant to national security; and
2. To limit undue influence, including through foreign talent programs, by countries aiming to exploit United States technology involving the Department of Defense research, science and technology, and innovation enterprise.

As of April 20, 2019, all key personnel must submit current and pending support documentation that includes the following:

• A list of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of the source.
• Title and objectives of the other research projects.
• The percentage per year to be devoted to the other projects.
• The total amount of support the individual receives in connection to each of the other research projects or will receive if other proposals are awarded.
• Name and address of the agencies and/or other parties supporting the other research projects.
• Period of performance for the other research projects.

This information is required for all key personnel, regardless of whether their efforts under the project are to be funded by the DOD.

Failure to submit this information may cause a proposal to be returned without further review. Additionally, the DOD has stated that it reserves the right to request further details from a proposer before deciding on funding the project.

Note that a particular program solicitation may include additional or differing requirements for current support documentation and should be reviewed closely.

DOD references:

DOD March 20, 2019 Memo

Biosketch

• Full disclosure of academic/professional affiliations, positions, and appointments, including domestic and foreign positions, is required.
• Refer to program solicitation instructions for further detail and/or additional requirements.
• Review the solicitation carefully for program-specific requirements.

Updating Information for Award

Any form –Current & Pending, Biosketch, Facilities

If the Proposal Update seeks information regarding the biosketch or current and pending support, ensure that any new or previously unreported required information is included.

Annual Technical Report

DOD awards follow different models for annual and final technical reports, and DOD policy does not explicitly address updating current and pending support information during the period of performance.

Nonetheless, all participants on the project (including those who were not paid) must be reported, and countries of foreign participants must be identified.

Refer to award terms and the referenced technical report instructions for further details.

Agency Communications:

DoD memo issued on March 20, 2019, outlines disclosure requirements for all key personnel listed on DoD-funded financial assistance agreements.

DoD memorandum for immediate prohibition on Procurement of Foreign-Made Unmanned Aircraft Systems

The Department of Energy Office of Research, Technology, and Economic Security continuously updates the DoE Research Security policies and regulations. Check back here for updates.

Limits on Participation in Certain Foreign Talent Recruitment Programs

On June 7, 2019, DOE issued Order No. 486.1, which requires those performing work on DOE contracts to disclose fully and, as necessary, terminate affiliations with foreign government-supported talent recruitment programs from countries deemed by DOE to be high risk (China, Russia, Iran, and North Korea). Talent recruitment programs are defined to include "foreign-state-sponsored attempt(s) to acquire US scientific-funded research or technology through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States.

In conjunction with this foreign talent program prohibition for DOE contractors, new quarterly reporting relating to senior or key personnel has been imposed.

Although this directive currently applies to DOE contracts, it is expected that the ban on participating in foreign talent recruitment programs may be extended to cooperative agreements and grants in the future.

Current & Pending Support and Biosketches

Current and Pending Support and Biosketches must be provided for all senior personnel and faculty associates. The term "senior personnel" includes:

(Co)Principal Investigator(s) - the individual(s) designated by the grantee and approved by DOE who will be responsible for the project's scientific or technical direction. If more than one, the first one listed will have primary responsibility for the project and the submission of reports.

Faculty Associate (faculty member) - an individual other than the Principal Investigator(s) considered by the performing institution to be a member of its faculty or who holds an appointment as a faculty member at another institution and who will participate in the project.

Current & Pending Support

Current and Pending support is intended to allow the identification of potential duplication, overcommitment, potential conflicts of interest or commitment, and all other sources of support.

The PI and each senior/key person at the prime applicant and any proposed subaward must provide 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;
• fulltime, part-time, or voluntary positions;
• 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 foreign government-sponsored talent recruitment programs must be identified in current and pending support.

The DOE Office of Science requires the use of the biosketch format approved by the National Science Foundation. This format can be generated using the Science Experts Network Curriculum Vitae (SciENcv), a platform maintained by the National Institutes of Health. A sample of the NSF-approved format is also available. Using a format accepted by multiple agencies helps reduce the administrative burden on researchers by promoting consistency.

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. 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.

Details of any obligations, contractual or otherwise, to any program, entity, or organization sponsored.

Review the solicitation carefully for program-specific requirements.

DOE references:

Office of Science, or p. 91 of the FY 2021 Solicitation

EERE – Energy Efficiency & Renewal Energy

ARPA-E

Biosketch

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.

The DOE Office of Science requires the use of the biosketch format approved by the National Science Foundation. This format can be generated using the Science Experts Network Curriculum Vitae (SciENcv), a platform maintained by the National Institutes of Health. A sample of the NSF-approved format is also available. Using a format accepted by multiple agencies helps reduce the administrative burden on researchers by promoting consistency.

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.

In addition, the biographical sketch must include information to permit DOE to identify individuals who are conflicted with or potentially biased (favorably or unfavorably) against the investigator. Include a section entitled "Identification of Potential Conflicts of Interest or Bias in Selection of Reviewers" that will not count in a page limit. Provide the following information in this section:

• Collaborators and Co-editors: List in alphabetical order all persons, including their current organizational affiliation, who are, or who have been, collaborators or co-authors with you on a research project, book or book article, report, abstract, or paper during the 48 months 92 preceding the submission of this application. For publications or collaborations with more than 10 authors or participants, only list those individuals in the core group with whom the PI interacted on a regular basis while the research was being done. Also, list any individuals who are currently, or have been, co-editors with you on a special issue of a journal, compendium, or conference proceedings during the 24 months preceding the submission of this application. If there are no collaborators or co-editors to report, state "None."
• Graduate and Postdoctoral Advisors and Advisees: List the names and current organizational affiliations of your graduate advisor(s) and principal postdoctoral sponsor(s). Also, list the names and current organizational affiliations of your graduate students and postdoctoral associates.

Personally Identifiable Information: Do not include sensitive and protected personally identifiable information including social security numbers, birthdates, citizenship, marital status, or home addresses. Do not include information that a merit reviewer should not make use of.

Review the solicitation carefully for program-specific requirements.

DOE references:

Office of Science, or p. 91 of the FY 2021 Solicitation

EERE – Energy Efficiency & Renewal Energy

ARPA-E

Agency Communications:

• DoE O 486.1A, Foreign Government Sponsored or Affiliated Activities
• DoE O 486.1A FAQs
• DoE Unclassified Foreign Visits and Assignments Program
• DoE directives for Foreign Government Sponsored or Affiliated Activities

Complying with DOE Policy when Updating Information for Award

Any form – Current & Pending, Biosketch, Facilities

If the Proposal Update seeks information regarding the biosketch or current and pending support, ensure that any new or previously unreported required information is included.

Research Performance Progress Report

DOD awards follow different models for annual and final technical reports, and DOD policy does not explicitly address updating current and pending support information during the period of performance.

Nonetheless, all participants on the project (including those who were not paid) must be reported, and countries of foreign participants must be identified.

Refer to award terms and the referenced technical report instructions for further details.

The information below is intended to guide users to complete the NASA Biosketches, Current & Pending Support, and other information.

Note that in addition to the traditional forms of support, some Institutional resources must also be disclosed.

Current & Pending Support, Biosketches and Facilities, Equipment and Other Resources

Current and Pending Support and Biosketches must be provided for all senior personnel and faculty associates. The term "senior personnel" includes:

(Co)Principal Investigator(s) - the individual(s) designated by the grantee and approved by NASA who will be responsible for the project's scientific or technical direction. If more than one, the first one listed will have primary responsibility for the project and the submission of reports.

Faculty Associate (faculty member) - an individual other than the Principal Investigator(s) considered by the performing institution to be a member of its faculty or who holds an appointment as a faculty member at another institution and who will participate in the project.

Current & Pending Support

PIs and Co-PIs must provide full disclosure of all ongoing and pending projects and proposals, both domestic and foreign, regardless of whether salary support is received and in which they are performing or will perform any part of the work. Co-Is proposing to spend 10% or more of their time on the proposed effort must disclose ongoing and pending projects and proposals that require greater than 10% of their time.

Current and pending support is not required for Co-Is at non-U.S. institutions and is usually not required for students (although it may be requested).

Please refer to the NASA Guidebook for Proposers Responding to a NASA Funding Announcement (May 2020) for further details regarding current and pending support.

Review the solicitation carefully for program-specific requirements.

Biosketch

The biographical sketch must include professional experiences and positions, along with a bibliography of publications, especially those relevant to the proposed investigation. A description of scientific, technical, and management performance on relevant prior research projects must also be included.

Please refer to the NASA Guidebook for Proposers Responding to a NASA Funding Announcement (May 2020) for further details regarding biosketch requirements.

Review the solicitation carefully for program-specific requirements.

Other – NASA China Certifications and Questionnaire

According to the Grant Information Circular 12-01 Class Deviation Implementing NASA Restrictions On Funding Activities With The People's Republic Of China (PRC) Effective April 25, 2011

"NASA is restricted by specific applications of Section 1340(a) of The Department of Defense and Full-Year Appropriations Act, Public Law 112-10 (NASA's 2011 continuing resolution), and Section 539 of the Consolidated and Further Continuing Appropriation Act of 2012, Public Law 112-55 (NASA's FY 2012 appropriation) from using funding appropriated in the Acts to enter into or fund any grant or cooperative agreement of any kind to participate, collaborate, or coordinate bilaterally in any way 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."

Updating Information for Award

Complying with NASA Policy when Updating Information for Award

If the Proposal Update seeks information regarding the biosketch or current and pending support, ensure that any new or previously unreported required information is included.

DARPA generally follows Department of Defense Policy regarding Research Security including following the DOD Risk Matrix. DARPA and DOD have developed two guidance resources for institutions and researchers:

1. DARPA Fundamental Research Risk-Based Security Reviews Policy and Process
2. Basic Research; Research Directorate; Academic Research Security webpage

The White House Office of Science and Technology Policy Has Released Guidelines for Research Security Programs at Covered Institutions

In July of 2024, The White House Office of Science and Technology Policy released guidelines for research security programs for covered institutions. These guidelines expand and formalize guidelines for to Federal Research Agencies for research security at certain universities and federally-funded researcher institutions.

This document, titled Guidelines for Research Security Programs at Covered Institutions, covers requirements of research agencies and calls out 4 specific areas of requirements: Cybersecurity, Foreign Travel Security, Research Security Training, and Export Control Training.

To initiate compliance to these requirements, UC has: initiated a process to track foreign travel to Foreign Countries of Concern (defined by the CHIPS and Science Act of 2022as Iran, Russia, North Korea, China), Export Control Training (already in place in CITI), compliance to forth-coming Cybersecurity requirements, and exploration into Research Security Training Options.

Many countries sponsor talent recruitment programs to attract researchers from across the globe. Many use legitimate mechanisms of recruitment including fellowships, student and scholar exchanges, and grants. However, some programs include restrictions or contracts that create conflicts of interest or conflicts of commitment or event encourage unethical or even criminal behaviors. These types of foreign talent recruitment programs are classified as Malign Foreign Talent Recruitment Programs. Participation in Malign Foreign Talent Recruitment Programs is prohibited by UC Policy as well as United States law per the CHIPS and Science Act of 2022.

Malign Foreign Talent Recruitment Programs (MFTRP) can be defined by programs sponsored by "Foreign Country of Concern" or an entity based in a "Foreign Country of Concern" (People's Republic of China, North Korea, The Russian Federation, The Islamic Republic of Iran), any institutions or programs on the lists created in the National Defense Authorization Act of 2019 or found on the document titled 2025 Department of Defense (DoD) Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions.

The White House Office of Science and Technology Policy has released Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs that outlines the guidelines for federal agencies on MFTRP and a standard definition.

Additionally, Malign Foreign Talent Recruitment Programs have some or all of the following provisions, contract terms. If the following types of compensation is offered: Cash, In-kind compensation, including research funding, Promise of future compensation, Things of non de minimus value, Honorific titles, Career advancement opportunities or other types of renumeration or consideration IN EXCHANGE FOR PERFORMING ONE OF MORE OF THE FOLLOWING ACTIVITIES:

• Unauthorized transfer of intellectual property, materials, data, or other nonpublic information.
• Recruitment of trainees or researchers to enroll in such program, position, or activity.
• Establishing a lab or forming a company in a foreign country in violation of terms and conditions of a federal research award.
• Accepting a faculty position or undertaking any other employment or appointment in violation of terms and conditions of a federal research award.
• Signing a contract or agreement which you are unable to terminate except in extraordinary circumstances.
• Committing a specified amount of time to work for the foreign institution.
• Engaging in work that overlaps or duplicates a federal research award.
• Applying for or receiving research funding from the foreign government that would be awarded to the foreign institution.
• Requirement to omit acknowledgement of the foreign institution, or any U.S. federal research sponsors.
• Requirement to not disclose participation in the program, position, or activity to the University of Cincinnati or the U.S. federal government.
• Having a conflict of interest or commitment contrary to a federal research award.

As of May 20^th, 2024, senior/key personnel cannot be a party to a malign foreign talent recruitment program (MFTRP). Individuals who are a party to a MFTRP are not eligible to receive NSF funding.

1. We strongly encourage you to take an 8-minute training video to learn about MFTRPs and to certify that you are not involved in an MFTRP.
2. The NSF is modifying the SciENcv to include an attestation statement that you are not a party to a MFTRP. The modification is scheduled to be released by May 20^th, 2024.
3. A new PI certification at proposal stage is being added to Kuali for purposes of attestation:

Yes/No Do you certify that you as PI (or Multi-PI) and your senior/key personnel are not a party to a malign foreign talent recruitment program (Section 10638(4) of CHIPS and Science Act)?

If you have been asked to participate in a Foreign Talent Recruitment Program, reach out to the Research Security Team or the Export Control Office for assistance.