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Upcoming New Federal Proposal Requirements


The Office of Science and Technology Policy opens in a new window (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.

A pan-campus working group is currently developing training materials related to these 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 (OSP) website.

Key Highlights of the New Federal Requirements

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  • 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

 

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.

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  • National Science Foundation opens in a new window: NSF will implement the new requirements for all proposals submitted or due on, or after, May 20, 2024. SciENcv opens in a new window, a research profile system, will play an integral role.
  • National Institutes of Health opens in a new window: NIH will implement the new requirements in January 2025 using the standard templates released with the requirements. They will then transition to SciENcv opens in a new window, to align with NSF, in May 2025.
  • National Aeronautics and Space Administration opens in a new window: 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 opens in a new window: 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 yet have an implementation date.

 

As more information is received, and training materials become available, updates will be provided. Please reference this memo opens in a new window and the NSF guidance page opens in a new window for additional details.

Should you have any immediate questions, contact Brian Collier, Director of Research Science and Security at bcollier@email.unc.ede.

For all other general inquiries, please contact SponsoredPrograms@unc.edu.

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