From: The Office of Sponsored Programs and the Office of Export and Secure Research Compliance

Virginia Tech’s Foreign Influence Task Force continues to monitor developments from federal agencies regarding foreign interest disclosure requirements. Recently, both National Institutes of Health (NIH) and National Science Foundation (NSF) have published information on this topic, which can be found below:

National Institutes of Health

National Institutes of Health published Notices NOT-OD-21-073 and NOT-OD-21-110, which detail changes to the Biographical Sketch, Other Support Format Page requirements, and supporting documents that are or will be required for complete disclosure. 

Changes include:

  • Certification of Other Support requires principal investigator/other senior, key personnel signature

  • New Biosketch and Other Support Forms

  • NIH may request supporting documents (consulting/other employment contracts)

  • Immediate notification requirements in the event faculty enter consulting/other employment agreements during the performance of an NIH award

Aside from Immediate Notifications, Biosketch and Other Support filings are made using the Just In Time or Research Performance Progress Reports as appropriate.

Note: According to NIH correspondence, use of the updated forms after May 25, 2021 is encouraged, but not mandatory. After January 25, 2022, failure to follow the appropriate formats may cause NIH to withdraw applications. 

National Science Foundation

The National Science Foundation recently published a revised Proposal and Award Policies and Procedures Guide effective October 4, 2021. Below is information from the NSF Policy webpage, with NSF’s summary notes of NSF 22-1. The new guide will be effective for proposals submitted or due on or after October 4, 2021. 

Changes include:

  • A new section covering requests for reasonable and accessibility accommodations regarding the proposal process or requests for accessibility accommodations to access NSF's electronic systems, websites, and other digital content;

  • A table titled, NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support. This table identifies where pre- and post-award current and pending support disclosure information must be provided. Although the guide (NSF 22-1) becomes effective October 4, 2021, proposers and awardees may begin using this table immediately to assist with completing the relevant proposal and project report sections;

  • Increasing the page limit for the biographical sketch from two to three pages;

  • Updates to the current and pending support section of NSF proposals to require that information on objectives and overlap with other projects is provided to help NSF and reviewers assess overlap/duplication;

  • Adding planning proposals and Career-Life Balance supplemental funding requests as new proposal types; and

  • Updates to travel proposals will require that authorized organizational representative certify that prior to the proposer's participation in the meeting for which NSF travel support is being requested, the proposer will assure that the meeting organizer has a written policy or code-of-conduct addressing harassment.

Additional information or questions:

Researchers can find additional information on the process of how to disclose foreign interests, as each federal sponsor currently has different methods for disclosure, here: Foreign Influence in Federally Sponsored Research - Guidance.

For questions regarding what to disclose to Virginia Tech and/or their sponsors, email: 

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