National Science Foundation (NSF): Disclosure Requirements

Over the last several years, the federal government and federal funding agencies have raised concerns regarding research security and undue foreign influence on federally funded research. As a result, many federal funding agencies, including the National Science Foundation (NSF), have revised what information they require from investigators to appropriately assess available resources and other sources of support. As part of this effort, NSF included updated requirements in the annual release of the Proposal & Award Policies & Procedures Guide (PAPPG). This clarifying guidance from NSF outlines requirements that differ from what was previously understood to be required of applicants and awardees. A summary of these current NSF requirements follows.

Disclosing Current & Pending Support

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.”

Disclosure Requirements within Current and Pending Documents are as follows:

• Financial Support. This includes sponsored awards held at Notre Dame, held at another institution/entity, or held as an individual that supports an investigator’s research efforts. This also includes start-up packages from entities other than Notre Dame. Investigators do not need to disclose Notre Dame 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, and visiting scholars. 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 matrix linked below).

NSF policy remains consistent regarding the 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 establish a post-award disclosure requirement for undisclosed current support and in-kind contribution information. Therefore, as of this date, if Notre Dame discovers that a PI or Co-PI on an active NSF award failed to disclose current support or in-kind contributions within their proposal, NDRAC must submit a notice to NSF informing them of the undisclosed support or contribution within 30 days of identification of the oversight by Notre Dame. NSF will review the disclosure and, after possible consultation with NDRAC, 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 Notre Dame Research Administrator as soon as possible.

Biographical Sketch

Researchers are required to disclose within their Biographical Sketch as follows;

• Positions, Appointments, and Affiliations. Any and all academic, professional, or institutional appointments and positions - paid or unpaid, full-time, part-time, or voluntary
• Professional Preparation. Education and training

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 the use of a sub-award 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.

For questions regarding NSF's current and pending support, biographical sketches, and foreign partnerships, please contact your pre-award program manager.

NSF Disclosure Requirements Matrix - Updated January 2024 NSF Disclosure FAQs