NSF Compliance

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

At the proposal stage, all Senior Personnel must submit Current and Pending Support and Biosketches. The term "Senior Personnel" includes:

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

Current & Pending Support

NSF uses the information submitted in the Current and Pending Support section to assess the individual researcher's capacity to carry out the project as proposed and help assess any potential overlap or duplication with the project being proposed.

NSF requires information on all current and pending support for ongoing projects and proposals. Detailed information about the content is available in the Proposal and Award Policies and Procedures Guide (PAPPG 24-1), Chapter II.C.2.h (page 65).

The proposed project and all other projects or activities requiring a portion of the PI/senior personnel's time must be included, even if they receive no salary support from the project(s).

REMINDER - Report funds and research support for the investigator to Caltech, another organization, or to the investigator directly.

NEW - Consulting

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.
• Report consulting that exceeds Caltech's policy of one day per week or thirteen (13) days per quarter.

Reminder: Consulting activities must be reported through the Caltech Disclosure of Financial Interests and Commitments system regardless of whether external consulting supports research endeavors.

NEW - Copies of Contracts - Consistent with NSPM-33, 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. Further, if an individual receives direct or indirect support that is funded by a foreign government-sponsored talent recruitment program, even where the support is provided through an intermediary and does not require membership in the foreign government- sponsored talent recruitment program, that support must be disclosed. Senior/key personnel must also report other foreign government-sponsored or affiliated activities. In accordance with 42 U.S.C. § 19232, individuals are prohibited from being a party in a malign foreign talent recruitment program.

NEW - Malign Foreign Talent Recruitment Program" (MFTRP). Investigators funded by a MFTRP are ineligible for NSF funding. An MFTRP means:

A. Any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual—

(i) engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;

(ii) being required to recruit trainees or researchers to enroll in such program, position, or activity;

(iii) establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;

(iv) being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;

(v) through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award, or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award;

(vi) being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient;

(vii) being required to omit acknowledgment of the recipient organization with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award;

(viii) being required to not disclose to the Federal research agency or employing organization, the participation of such individual in such program, position, or activity; or

(ix) having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award. And

(B) A program that is sponsored by— (i) a foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern; (ii) an academic institution on the list developed under § 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. § 2358 note; Public Law 115–232); or (iii) a foreign talent recruitment program on the list developed under § 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. § 2358 note; Public Law 115–232 ).

The following are not considered malign foreign talent recruitment programs unless such activities are funded, organized, or managed by an academic institution or a foreign talent recruitment program on the lists developed under paragraphs (8) and (9) of section 1286(c) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115–232):

(i) making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law;

(ii) participation in international conferences or other inter- national exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law; and

(iii) advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student, at such student's request.

NEW - Certification of Current & Pending (Other) Support, and the Biographical Sketch

Each senior/key person is required to complete the following certifications regarding the information provided in their Current and Pending (Other) Support:

I certify that the information provided is current, accurate, and complete. This includes, but is not limited to, information related to current, pending, and other support (both foreign and domestic) as defined in 42 U.S.C. § 6605.

I also certify that, at the time of submission, I am not a party in a malign foreign talent recruitment program.

Misrepresentations and/or omissions 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.

Institutional Financial Resources

Internal Awards (e.g., Caltech Innovation Initiative)

Internal awards are included in Current and Pending Support if the award is in direct support of a research project. Specifically, the awards are used for a project that has (1) scope of work; (2) budget; (3) effort commitment by the PI; (4) period of performance.

Gifts made to Caltech

Caltech and the federal government define a gift as something given without expectation of anything in return. If an item or service meets the definition of a gift, it is not reported as Current and Pending Support. If a gift was given to Caltech for use on a specific research activity, the funds must be disclosed as Current and Pending Support. Also, an item or service given with the expectation of an associated time commitment is not a gift and is instead an In-Kind contribution and must be reported to NSF.

Start-up funds

Caltech start-up packages provided to the PI from Caltech are NOT included in Current and Pending Support. Start-up packages from institutions other than Caltech must be reported in Current and Pending Support.

REVISED - Reporting "In-Kind" Support

An in-kind contribution is a non-cash contribution provided by an external entity that directly supports the individuals' research and development efforts. An in-kind contribution may include but is not limited to: real property; laboratory space; equipment; data or data sets; supplies; other expendable property; goods and services; employee or student resources.

Report all in-kind contributions with an estimated dollar value of $5,000 or more and that requried a commitment of the individual's time.. Note that "conditional" gifts may also be considered In-Kind support.

If an In-Kind contribution is not used on the project/proposal being proposed to NSF and has no associated time commitment, it need not be reported.

If an In-Kind contribution is not intended for use on the project/proposal being proposed to NSF but has an associated time commitment, the information must be included as part of the Current and Pending Support section of the proposal.

If an In-Kind contribution is intended for use on the project/proposal being proposed to NSF and either has an associated time commitment or not, the information must be included as part of the Facilities, Equipment and Other Resources section of the proposal and need not be replicated in the individual's current and pending Support submission.

If an In-Kind contribution is not used on the project/proposal being proposed to NSF and has no associated time commitment, it need not be reported.

Other Sources of Support

NSF requires reporting of all consulting appointments or other outside activities that fall outside the individual's appointment (e.g., that involve performing research for another organization).

Report travel reimbursements paid by an outside organization when the travel is to perform research and where the research activity involves a time commitment. Note: Only report travel reimbursed to you by a third-party entity. Do not report travel reimbursed from Caltech funds or sponsored awards to Caltech.

Report start-up companies based on intellectual property licensed from entities other than Caltech.

Note that, per NSF: "It is important to note that NSF is not asking for how much time is budgeted for a particular individual(s), but rather how much time the individual(s) is/are planning to spend to complete the scope of work on the proposed project and/or award. If the individual(s) will be spending time on the proposed project or award, then that time must be reported."

Note: Concurrent submission of a proposal to other organizations will not prejudice its review by NSF if disclosed. However, Caltech may not accept federal research funding for the same project also funded by other sources. Contact OSR to discuss how to withdraw duplicate proposals.

If the project (or any part of the project) now being submitted has been funded previously by a source other than NSF, information must be provided regarding the last period of funding.

For all funded projects, report the total award amount for the entire award period covered (including indirect costs) and the number of person-months (or partial person-months) per year to be devoted to the project by the individual.

Include the following Current & Pending Support information:

All planned, pending and current project support and in-kind support that is either provided directly to the individual or to the individual through their organization in support of that individual's research endeavors, from whatever source, including, but not limited to:

• Contracts or Cooperative Agreements for Research – All such sponsored agreements for research or educational activities that take place at Caltech or elsewhere must be included as Current and Pending Support, including internal funding as described above.
• Consulting activities not permitted by an individual's appointment, or where an exception has been granted. Examples include consulting activities that involve performing research for other entities, or where consulting time exceeds one day a week or thirteen (13) days per quarter, per Caltech policy.
  Reminder: Consulting Agreements - Consulting activities must be reported through the Caltech.
• Disclosure of Financial Interests and Commitments (DFIC) system (access.caltech.edu) regardless of whether external consulting supports research endeavors.
• Travel supported/paid by an external entity to perform research with an associated time commitment.
• Startup companies based on non-Caltech-licensed intellectual property.
• Fellowship Program - Included in Current and Pending Support, if the fellowship is granted to the Principal Investigator and/or key personnel.
• Postdoctoral fellowships paid directly to a researcher funded by a foundation or other organization should not be submitted as part of the PI or co-PIs Current & Pending Support submission.
• Foreign Talent Program¹ - Include in Current & Pending Support for the Principal Investigator and any senior personnel.
• Grants for Research - Included as Current & Pending Support regardless of whether or not the grants are based at Caltech. ***Also report any support for research paid directly to the investigator ***

^{1 Foreign Government Talent Recruitment Program. In general, such programs include any foreign-state-sponsored attempt to acquire U.S. 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. 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. See https://www.sciencemag.org/sites/default/files/January%20DOE%20memo.pdf for more information, including distinguishing features of a foreign government talent recruitment program as defined by the Department of Energy.}

Other Resources

Other Resources, not already included above, are included as Current and Pending Support if the resources are in direct support of the individual's research endeavors at Caltech or any institution or entity.

Projects and Activities - All Projects and Activities not already included above are included as Current and Pending Support if the project or activity supports an individual's research in any way at Caltech or any institution or entity.

NSF references:

• NSF Chart on Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support (May 2024)
• Using SciENcv - FAQ (September 2023)
• NSF Current & Pending Support page, including links and FAQs on SciENcv and Fillable PDF FAQs.
• Prior versions of the NSF FAQs: February 2023, April 10, 2022, January 10, 2022, February 24, 2021, June 28, 2021, July 30, 2020

^{1 Foreign Government Talent Recruitment Program. In general, such programs include any foreign-state-sponsored attempt to acquire U.S. 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. 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. See https://www.sciencemag.org/sites/default/files/January%20DOE%20memo.pdf for more information, including distinguishing features of a foreign government talent recruitment program as defined by the Department of Energy.}

^{*NSF defines research as a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. Research is classified as either basic or applied according to the objectives of the sponsoring agency. https://www.nsf.gov/statistics/fedfunds/glossary/def.htm#research}

Facilities, Equipment & Other Resources

Include an aggregated description of the internal and external resources (both physical and personnel) that the organization and its collaborators will provide to the project, should it be funded. Such information must be provided in this section instead of other parts of the proposal (e.g., Budget Justification, Project Description).

Use a narrative description and do not include quantifiable financial information. Reviewers will evaluate the information during the merit review process, and the cognizant NSF Program Officer will review it for programmatic and technical sufficiency.

If an In-Kind contribution is intended for use on the project/proposal being proposed to NSF (whether or not it includes a time commitment), the information must be included as part of the Facilities, Equipment, and Other Resources section of the proposal and need not be replicated in the individual's Current and Pending Support submission.

NSF references:

• PAPPG II.C.2.i - Facilities, Equipment, and Other Resources
• NSF Chart on Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support (April 2022)

Other disclosures of international activities

Cover Sheet and Project Description -

• All research, training, and/or education which involves international counterparts, whether in-person or virtually
• All subawards, consulting agreements, or other forms of funding to foreign entities or individuals

NSF references:

• PAPPG II.C.2.a(i) - Cover Sheet - Other Information
• PAPPG II.C.2.d - Project Description

Collaborators and Other Affiliations -

NSF has a long-standing policy for PIs to report unfunded collaborators contributing to the proposed project as part of the Facilities, Equipment, and Other Resources, as described below.

The NSF proposal and award guide states –

- Any substantial collaboration with individuals not included in the budget should be described in the Facilities, Equipment and Other Resources section of the proposal (see Chapter II.D.2.g) and documented in a letter of collaboration from each collaborator. Such letters should be provided in the supplementary documentation section of Research.gov and follow the format instructions specified in Chapter II.D.2.i.

- Collaborative activities that are identified in the budget should follow the instructions in Chapter II.E.3.

Note: While collaborations not directly contributing to the project may not need to be listed in the proposal as "collaborator", the activity may be considered "in-kind support" if it includes a time commitment, for example, if a PI hosts a visiting researcher funded by an outside entity.

In addition, NSF requires a spreadsheet format for listing Collaborators and Other Affiliations, for purposes of identifying potential conflicts for proposal peer reviews.

- Collaborations and Other Affiliations (COA) information. NSF requests information in spreadsheet form, where the PIs include lists of co-authors and collaborators. NSF uses this information to avoid conflicts of interest in proposal review. From the NSF proposal instructions, related to Table 4 -COA template Table 4: List names as last name, first name, middle initial, and provide organizational affiliations, if known, for the following: Co-authors on any book, article, report, abstract or paper with collaboration in the last 48 months (publication date may be later); and Collaborators on projects, such as funded grants, graduate research or others in the last 48 months.

NSF references:

PAPPG II.C.1.e - Collaborators and Other Affiliations