Sponsored Projects | UC Berkeley

Overview

Federal agencies require principal investigators (PIs) and other key personnel to disclose their foreign sources of support and to disclose how those sources are being used to support the proposed and related research. UC Berkeley researchers who receive federal funding for research activities need to be aware of these requirements and how each federal agency interprets what is meant by foreign sources of support. Some of these requirements have been in place for some time and others are new or are being interpreted differently and/or more rigorously than in the past.

It is important for campus researchers to stay up-to-date on new federal requirements and any modifications as these become available. This webpage is designed for this purpose although it does not replace reviewing requirements on agency webpages or in specific agency solicitations (also known as notice of funding opportunities or NOFOs).

If you have any questions regarding specific proposal or award requirements, please contact your SPO Contract and Grant Officer.

Other/Current & Pending Support

The National Security Presidential Memo-33 (NSPM-33) Implementation Guidance issued in January 2022 addressed standardization of disclosure requirements by federal agencies, including clarity regarding who discloses what, relevant limitations and exclusions; disclosure process (e.g., updates, corrections, certification, and provision of supporting documentation); and expected degree of cross agency uniformity.

The National Science and Technology Council (NSTC) Research Security Subcommittee worked to develop consistent disclosure requirements for use by senior/key personnel, as well as to develop proposed common disclosure forms for the Biographical Sketch and Current and Pending (Other) Support sections of an application for Federal research and development (R&D) grants or cooperative agreements. The National Science Foundation (NSF) was designated as the steward for these forms, finalizing them in late 2023 to ensure cross-agency uniformity.

Common Disclosure Forms

Disclosure Requirements

NSF hosts a webpage that provides NSPM-33 implementation guidance for Pre- and post-award disclosures relating to the Biographical Sketch and Current and Pending (Other) Support. The page has been created to provide helpful reference information regarding pre-award and post-award disclosures. The webpage includes the types of activities to be reported, where such activities must be reported in the application, as well as when updates are required in the application and award lifecycle. A final section on the webpage identifies activities that are not required to be reported.

In accordance with Section 10631 of the CHIPS and Science Act, Covered Individuals are required to disclose if they are part of a foreign talent recruitment program, certify that they are not part of a malign foreign talent recruitment program and recertify annually. The Common Forms include this required certification. Information about foreign talent recruitment programs and malign foreign talent recruitment programs (MFTRP) may be found on the Berkeley Research Security Program webpage in the section labeled Research Security Disclosures. UC guidance also provides details and definitions about Covered Individuals, Foreign Talent Recruitment Program and Malign Foreign Talent Recruitment Program (MFTRP) at the UCOP Ethics, Compliance and Audit Services webpage on Foreign Talent Recruitment Programs.

National Institutes of Health

NIH issued NOT-OD-21-073, “Upcoming Changes to the Biographical Sketch and Other Support Format Page for Due Dates on or after May 25, 2021”, which adds the following requirements for RPPRs submissions on or after May 21, 2021 and for applications submitted on or after January 25, 2022, as part of the Just-in-Time process or in certain cases when current and pending information is included with the application. Changes include these requirements for Other Support:

Supporting documentation, which includes copies of contracts/agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. If the contracts/agreements are not in English, recipients must provide translated copies.
Immediate notification of undisclosed Other Support. When a recipient organization discovers that a PI or other Senior/Key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the recipient must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.

Use of the Common Forms for Biographical Sketch, Current and Pending (Other) Support and NIH Biographical Sketch Supplement is required for application due dates and all JIT, RPPR, and Prior Approval submissions on or after January 25, 2026. See NOT-OD-26-018 for additional details.

In addition to the requirement of generating the form from SciENcv, changes include:

Requirement that all Senior/Key Personnel enter their ORCID ID into SciENcv in the Persistent Identifier (PID) section of the Common Forms.
Each senior/key person will be required to certify they are not a party to a malign foreign talent recruitment program.

The National Institutes of Health issued Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components (NOT-OD-19-114) on July 10, 2019.

Among the key points are:

All pending support at the time of application submission and prior to award must be reported.
Applicants are responsible for promptly notifying NIH of any substantive changes to previously submitted pending support.
If other support is obtained after the initial NIH award period, the details must be disclosed in the annual research performance progress report.
Post-award, recipients must address any substantive changes by submitting a prior approval request to NIH.

NIH has published guidance on Protecting U.S. Biomedical Intellectual Innovation. Resources on the page include requirements for disclosure, examples of what to disclose to NIH about Senior/Key Personnel on applications and awards, and a link to FAQs on Other Support and Foreign Component. NIH also provides general guidance on Other Support.

See RAC: Other Support and Foreign Influences: NIH for additional guidance.

Note: These disclosure requirements are in addition to the PHS Conflict of Interest disclosure requirements.

National Science Foundation

As stated in the NSF PAPPG 24-1 and effective May, 20, 2024:

Current and pending (other) support information 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.

NSF Policy Office uses the NSPM-33 Implementation Guidance Pre- and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending (Other) Support to provide the community with helpful reference information regarding pre-award and post-award disclosure information in the biographical sketch and current and pending support proposal sections. The table identifies where these disclosures must be provided in proposals as well as in project reports.

Current and pending (other) support information must be provided through use of SciENcv (Science Experts Network Curriculum Vitae).

Consulting activities must be disclosed under the proposals and active projects section of the common 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.

Senior/key personnel are required to disclose contracts associated with participation in programs sponsored by foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs.

In addition to certifying the information provided is current, accurate and complete, each senior/key person will be required to certify they are not a party to a malign foreign talent recruitment program.

Note: These disclosure requirements are in addition to the NSF Conflict of Interest disclosure requirements.

National Aeronautics and Space Administration

NASA issued a new edition of the NASA Grant and Cooperative Agreement Manual (GCAM) in March 2025; the disclosure requirements outlined below continue to apply.

On October 1, 2024 the National Aeronautics and Space Administration (NASA) issued the revised edition of the NASA Grant and Cooperative Agreement Manual (GCAM). The update includes NASA’s implementation of disclosure requirements in National Security Presidential Memorandum 33 (NSPM-33) and section 10631 of the CHIPS and Science Act.

Effective October 1, 2024, NASA requires the use of Common Forms for biosketch and current and pending (other) support in proposal submissions for grants or cooperative agreements. For awards issued after October 1, if Common Forms were not previously provided, NASA will reach out prior to issuing the new award to request biosketch and current and pending (other) support in the Common Forms format. The biosketch form and current and pending form are available for download on NASA’s Grants Policy and Compliance website.

NASA has published a table of NASA Pre-award and Post-award Disclosure Requirements indicating what needs to be disclosed, where, and when.

U.S. Department of Defense

Army Research Lab (ARL): Broad Agency Announcements (BAAs) for ARL require applicants to submit a signed Privacy Act Statement for each individual submitting a biosketch and current and pending support information. ARL provides guidance at the webpage: DEVCOM ARL Implementation of Army Research Risk Assessment Protection Program (ARRP).

DARPA: Effective November 1, 2024, DARPA requires disclosures using Common Forms for current and pending (other) support as described in the DARPA Proposer Instructions and as of April 1, 2025 DARPA uses Digital Persistent Identifiers (DPIs) for persistent identifiers on the Common Forms. See specific Broad Agency Announcements (BAAs) for any additional disclosure requirements.

CDMRP: Guidance for disclosures are included in the General Application Instructions for the DOD Congressionally Directed Medical Research Programs (CDMRP) as well as specific requirements in Funding Opportunities.

Other Defense agencies provide specific disclosure requirements for current and pending (other) support for Principal Investigators and other Key Personnel in Broad Agency Announcements (BAAs) or Notices of Funding Opportunities.

On March 20, 2019, the Undersecretary of Defense announced new requirements for all new DOD Notices of Funding Opportunities (NFOs) pertaining to new research and research-related educational activities after April 19, 2019.

See the full March 20, 2019 memo for details.

Excerpt:

Proposers must submit the following information for all key personnel—not just the PI and Co-PI—whether or not the individuals' efforts under the project are to be funded by the DOD:

A list of all current projects the individual is working on.
Any future (pending) support the individual has applied to receive, regardless of the source.
Title and objectives of each of these research projects.
The percentage per year each of the key personnel will devote to the other projects.
The total amount of support the individual is receiving 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.

DOD indicates that failure to submit this information may cause the proposal to be returned without further review. DOD also reserves the right to request further details from a proposer before making a final determination on funding the effort.

U.S. Department of Energy

DOE memo FAL 2026-02 outlines DOE current and pending support and biographical sketch requirements. As of December 3, 2025, DOE requires the use of the Common Forms for both biosketch and current and pending (other) support for Assistance (grant and cooperative agreement) applications and requires covered individuals to include their Digital Persistent Identifier in Common Forms. DOE Program Offices will include these requirements in Funding Opportunity Announcements (FOAs) and in award terms and conditions. DOE Offices such as the Office of Science prohibit any person participating on a project in a Foreign Government-Sponsored Talent Recruitment Program of a Foreign Country of Risk. Currently the DOE Foreign Countries of Risk are the same as the Foreign Countries of Concern defined by NSPM-33. For other DOE Offices, review the Notice of Funding Opportunity (NOFO).

The U.S. Department of Energy issued a directive, DOE Order 486.1, on June 7, 2019 that prohibits DOE and contractor personnel from participating in talent recruitment programs operated by certain foreign countries. While this directive does not directly affect faculty who are unaffiliated with DOE or its National Labs, it illustrates a pervasive concern across the federal agencies. The Order does require individuals to report their participation in Foreign Government Talent Recruitment Programs (FGTRP) for Research and Development (R&D) work performed or partially performed on or at a DOE or National Nuclear Security Administration (NNSA) site or facility, including DOE or DOE/NNSA Contractor leased space (note, all LBNL facilities fit into these categories). If an agreement, such as an LBNL IUT or subcontract from another DOE Lab is received, faculty and their research teams performing R&D work at a DOE facility are required to complete an FGTRP Certification form.

In September 2020, DOE revised the directive and issued DOE Order 486.1A to expand the restrictions on Foreign Government Sponsored or Affiliated Activities. In addition to prohibiting DOE and contractor personnel from participating in talent recruitment programs operated by a Foreign Country of Risk, it restricts other Foreign Government Sponsored or Affiliated Activities of a Foreign Country of Risk. This change does not affect faculty who are unaffiliated with DOE or its National Labs. DOE issued an FAQ that clarifies that, of the restrictions contained in the Order, only the prohibition on participation in Foreign Government Talent Recruitment Programs of Foreign Countries of Risk applies to university research projects when university staff come onto a DOE site to perform R&D work. The following are currently considered Foreign Countries of Risk (subject to change): Russia, Iran, China, North Korea, and Belarus.

Note: These disclosure requirements are in addition to the DOE Conflict of Interest disclosure requirements.

Federal Disclosure Related to Sponsored Projects