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This is a message from OVCR Research Science and Security, Office of Sponsored Programs, and School of Medicine’s Sponsored Programs Office.

The Office of Science and Technology Policy (OSTP) recently released new requirements to all federal agencies governing Current and Pending (Other Support) and Biosketch documents (also known as Common Forms). The agencies were tasked with incorporating these new requirements into their processes and announcing agency-wide implementation dates.

Key Highlights of the New Federal Requirements:

  • New requirements apply to all senior/key personnel
  • Continues the heavy focus on international activities/affiliations
  • Standardizes the requirements for both Current and Pending (Other) Support and Biosketch documents across all agencies with minimal exceptions
  • Consulting activities now count towards “conflict of commitment” and have three new definitions that will need to be applied to determine if an activity should be disclosed
  • Prohibits senior/key personnel from participating in malign foreign talent programs
  • Better defines In-Kind resources
  • Both documents will require senior/key personnel certification

Training:

A pan-campus working group is currently developing training materials related to the new requirements, which will be available to all faculty and staff across campus. The training, once ready, will be hosted on the Office of Sponsored Programs website.

Agency Implementation Dates:

To date, only two federal agencies have released implementation dates, with two more acknowledging that they will incorporate the new requirements into their policies and procedures at some point in the future.  Details below.

  • National Science Foundation: NSF will implement the new requirements for all proposals submitted or due on, or after, May 20, 2024. SciENcv, a research profile system, will play an integral role.
  • National Institutes of Health: NIH will implement the new requirements in January 2025 using the standard templates released with the requirements.  They will then transition to SciENcv, to align with NSF, in May 2025.
  • National Aeronautics and Space Administration: NASA has announced they will incorporate the new requirements into their Grants Policy Manual but does not have an implementation date set yet.
  • Department of Energy: DOE has announced that they are currently negotiating with OSTP to implement the new requirements.  We believe this is because they want to make changes to the requirements in order to meet legislative/appropriation requirements.  They do not have an implementation date set yet.

As more information is received, and training materials becomes available, we will provide another update.  Additional information can also be found on the NSF website at https://www.nsf.gov/bfa/dias/policy/nstc_disclosure.jsp.

Should you have any immediate questions, please feel free to reach out to Brian Collier, Director of Research Science and Security at bcollier@email.unc.edu.

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