Guidance on Current and Pending (Other) Support

The U.S. Government, including the federal agencies that fund much of NBER’s research, has expressed serious concerns regarding inappropriate influence by foreign entities, government, or individuals on U.S. institutions and researchers. Several federal agencies have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding. We hope to mitigate these concerns by informing our investigators of institutional and federal disclosure requirements and best practices. The federal funding agencies, particularly NSF and NIH, have long-standing grant submission requirements for reporting "Other Support" or “Current and Pending Support” and submitting Financial Conflict of Interest certifications. 

On August 20, 2018, Dr. Francis Collins, Director, National Institutes of Health, issued a letter that described several concerns , including grantee failures to disclose substantial resource contributions from other organizations, such as foreign governments and foreign institutions of higher education, in grant applications and progress reports. "Other Support" includes all sources of research funding. The NSF followed up with a Dear Colleague Letter issued July 11, 2019 on Research Protection. 

To ensure compliance with federal funding application requirements, it is important to follow the instructions published by the sponsors. For your convenience, we summarize the NIH and NSF guidance here. 

The CHIPS and Science Act of 2022 requires federal research agencies to each issue a specific policy on “malign foreign talent recruitment programs” (MFTRP) which must include provisions that, as part of a proposal for a research and development award from the agency each covered individual listed in such proposal certify that each such individual is not a party to a malign foreign talent recruitment. Upon award this becomes an annual certification requirement. The NSF policy and certification requirement is effective May 20, 2024, please see the NSF guidance page for details. Please review the definition of MFTRP and if you have any questions or concerns about programs you may be involved in please contact the Director of Research and Grants Management at alterra@nber.org. 

These standards for reporting “Other Support” apply to Financial Conflict of Interest Disclosure certifications as well as funding applications and progress reports. FCOI certifications are required at the time of grant proposal submission as well as annually while a grant award is active.  Disclosure of a new significant financial interest is also required within thirty days of acquiring it. You can find here the NBER Research Conflict of Interest Policy. 

With heightened federal scrutiny and increasing concerns about this issue, it is more important than ever that we ensure the submission of accurate and complete information about project support to federal sponsors. Please share this information with your colleagues, co-authors and research teams.  

Please remember that every disclosure to an external funding agency of an investigator’s active and pending sources of support for research and other sponsored activities must be true, complete, and accurate to the best of the investigator’s knowledge. This requirement applies regardless of the source of support or the official recipient of the source of support. False, fictitious, or fraudulent statements or claims (including intentional omissions) may result in criminal, civil, administrative or NBER penalties. 

If you have questions about the policies or requirements for reporting Other Support or submitting FCOI certifications, please contact your NBER grant administrator or Alterra Milone, Director of Research and Grants Management, at alterra@nber.org.