NSF Guidance

May 20, 2024

Faculty Disclosure Guidance for NSF submissions

Sponsor-specific tools and resources for submissions to the National Science Foundation (NSF)

NSF Proposals & Awards Policies & Procedures Guide (PAPPG)

Current version: NSF PAPPG (NSF 23-1) (NSF website) is effective for submissions due on or after January 30, 2023.  Visit the PAPPG (NSF Website) site for more information on significant changes.

New version:  NSF PAPPG (NSF 24-1) (NSF website) is effective for submissions due on or after May 20, 2024.  Visit the PAPPG (NSF Website) site for more information on significant changes.

Uniform Guidance and Prior Approvals

Refer to Federal Research Terms and Conditions (NSF Website).

Harvard Submission Process

Submissions of proposals and progress reports are due to your School’s submitting office according to their deadline policy for review and authorization.  Submission deadlines vary by the submitting office; for Harvard Chan SPA submit 7 business days before the sponsor’s due date; for OSP and HMS ORA submit 5 business days before the sponsor’s due date.  Please use the links listed below for more information on each submitting office’s deadline policies:

• For deadline submissions to OSP
• For deadline submissions to HMS ORA
• For deadline submissions to Harvard Chan SPA

Disclosure Guidelines for NSF submissions

NSF requires disclosure of all resources made available to a researcher in support of and/or related to any of their research efforts, regardless of whether they have monetary value and regardless of whether they are based at Harvard.  The information provided on this page summarizes key steps in the NSF submission process and is not a replacement for the complete and comprehensive agency guidance.  To ensure submissions are compliant, faculty should review the policy and guidance information accessible through the links at the top of the page.

The National Science Foundation (NSF) issued new requirements for Current and Pending Support reporting and Biographical Sketches (Biosketches), effective May 20, 2024.

Requirements – effective May 20, 2024

NSF Pre-award and Post-award Disclosures Summary Chart

This NSF Pre-award and Post-award Disclosures Summary Chart (NSF provided PDF) is a helpful reference outlining information regarding pre-award and post-award disclosure information in the Biographical Sketch and Current and Pending Support proposal sections. The table identifies where these disclosures must be provided in proposals as well as in project reports.

(i) Biographical Sketch(es) (at proposal stage)

Section A: Professional Preparation

List of the individual’s undergraduate and graduate education as well as postdoctoral and fellowship training. Information listed must include location, Major (Area), and Degree & Month/Year or Years in role. Undergraduate Institution(s), Location, Field of Study, Degree & Month/Year Graduate Institution(s), Location, Field of Study, Degree & Month/Year Postdoctoral Institution(s), Location, Field of Study, Inclusive Dates (years).

Appointments and Positions

Provide a list, in reverse chronological order by start date, of all the senior/key person’s academic, professional, or institutional appointments and positions, beginning with the current appointment (including the associated organization and location). Appointments and positions include any titled academic, professional, or institutional position, whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

Products

Each individual may list up to 5 products per product category. Products:  list up to 5 products most closely related to the proposed project. Significant Products: list up to 5 other significant products, whether or not related to the proposed project. Acceptable products must be citable and accessible including but not limited to publications, conference papers, presentations, and copyrights; website(s) or other Internet site(s); technologies or techniques; inventions, patents, patent applications, and/or licenses; and other products, such as data, databases, or datasets, physical collections, audio or video products, software, models, educational aids or curricula, instruments or equipment, research material, interventions (e.g., clinical or educational), or new business creation. Unacceptable products are unpublished documents not yet submitted for publication, invited lectures, and additional lists of products. Each product must include full citation information including (where applicable and practicable) names of all authors*, date of publication or release, title, title of enclosing work such as journal or book, volume, issue, pages, website and URL, or other Persistent Identifier. *Senior personnel who wish to include publications in the products section of the biographical sketch that include multiple authors may, at their discretion, choose to list one or more of the authors and then “et al.” in lieu of including the complete listing of authors’ names.

Certification

In accordance with Section 223(a)(1) of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (42 U.S.C. § 6605(a)(1)), each individual identified as a senior/key person is required to certify in SciENcv that the information provided in the Biographical Sketch documents are accurate, current, and complete.  Pursuant to Section 10632 (42 U.S.C. § 19232), each identified as senior/key person must certify prior to proposal submission that they are not a party to a malign foreign talent recruitment program and annually thereafter for the duration of the award. The statements provided in SciENcv are as follows: I certify that the information provided is current, accurate, and complete.  This includes but is not limited to information related to domestic and foreign appointments and positions.  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.

(ii) Current and Pending / Other Support

Instructions:

Current and pending (other) support information must be provided separately for each individual designated as a senior/key person through use of SciENcv (Science Experts Network Curriculum Vitae). SciENcv will produce an NSF-compliant PDF version of current and pending (other) support. Senior/key personnel must prepare, save, certify, and submit these documents as part of their proposal via Research.gov or Grants.gov.  Information must be provided for: The project(s) to be submitted, 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. Each Current and Pending (Other) Support entry should include: Total award amount for the entire award period covered (including indirect costs) Number of person-months per year to be devoted by the individual brief statement of the overall objectives of the project/proposal being proposed or in-kind contribution must be provided summary of the potential overlap between this proposal and any active or pending proposal or in-kind contribution. Additional details can be found on the NSF Current and Pending (Other) Support website (NSF Website), the NSF Current and Pending (Other) FAQs (Feb 2023), and within the PAPPG, Chapter, II.D.2.hii (NSF website). For assistance with SciENcv refer to the NIH instructional videos SciENcv Tutorial and Current & Pending Support for NSF

Prepare an Inventory of In-Kind Support and Other Resources

All Harvard individuals who are designated as Key Personnel on a NSF award/subaward are required to report all their research support to NSF via the Current and Pending (Other) Support form, which is required at Just in Time (JIT) and with each Research Performance Progress Report (RPPR) if their support has changed since the last submission. To provide a complete list of resources and support, all Key Personnel must take inventory of all resources provided or otherwise supported externally and available in support of their research.  This may include:  Supplies and Equipment, including high value material that is not broadly available.  Facilities, including any office/lab space or other facilities that are not Harvard owned or leased, and not otherwise made broadly available. *Note that institutional resources, including core facilities or shared equipment, should not be included as Current and Pending (Other) Support, but instead listed under Facilities and Other Resources within the proposal application.  Personnel, including postdoctoral researchers, students, and other lab personnel, paid from an external source or self-funded and working on the research of the reporting Key Person.  Other In-Kind Resources, including Research Collaboration Agreements (RCAs) or other agreements or commitments that may involve the performance of research or exchange of resources in support of your research endeavors. This includes Data Use Agreements (DUAs) and Material Transfer Agreements (MTAs) if the exchange covers high value data/materials that are not broadly available.  Outside Funding Support, including funding received directly or through another entity at which you have an affiliation (including the Harvard Affiliates). This includes external start-up packages.

Collect information from Harvard Systems

Harvard systems may contain information pertaining to potential sources of in-kind and other resources. Please note, the first two options are only available to individual Key Personnel; no one else has access to the OAIR report or the GMAS Other Support* and Activities report:  Download the GMAS report (which includes data from OAIR and Agreements Modules) through a direct link to your Other Support and Activities (Link to GMAS for automatic download of Excel report).   Export your current activities separately OAIR: Exporting Current Outside Activities from OAIR (Harvard provided PDF) and DUA Exporting Data Use Agreements from the DUA module (Harvard provided PDF)    *Note: “Other Support” is sometimes referred to as “Current and Pending Support” or “Current and Pending (Other) Support”.  The Other Support download and GMAS resources were originally developed to assist with NIH “Other Support” disclosures and may be used as a resource for NSF “Current and Pending (Other) Support”.

Certification

In accordance with Section 223(a)(1) of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (42 U.S.C. § 6605(a)(1)), each individual identified as a senior/key person is required to certify in SciENcv that the information provided in the Biographical Sketch and Current and Pending (Other) Support documents are accurate, current, and complete.  Pursuant to Section 10632 (42 U.S.C. § 19232), each identified as senior/key person must certify prior to proposal submission that they are not a party to a malign foreign talent recruitment program and annually thereafter for the duration of the award. The statements provided in SciENcv are as follows: I certify that the information provided is current, accurate, and complete.  This includes but is not limited to information related to domestic and foreign appointments and positions.  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.

Undisclosed Current and Pending (Other) Support

Immediately notify your Research Administrator of undisclosed Current and Pending (Other) Support (i.e., information that was missing from a proposal at JIT or a RPPR).

(iii) Collaborators & Other Affiliations (COA) Information

(see Proposal and Award Policies and Procedures Guide (PAPPG), Chapter, II.D.2.hiii (NSF website) for more details)

Information regarding collaborators and other affiliations (i.e., full names, organizational affiliations, and type of affiliations for each collaborator, advisor, co-author, and editor) must be separately provided for each individual identified as a senior/key person on the project. The COA information must be provided through use of the COA template. The information in the tables is not required to be sorted, alphabetically or otherwise. Refer to the FAQs on the NSF COA template page for additional information.

(iv) Synergistic Activities

Each individual identified as a senior/key person must provide a document of up to one-page that includes a list of up to 5 distinct examples that demonstrates the broader impact of the individual’s professional and scholarly activities that focus on the integration and transfer of knowledge as well as its creation. Senior/key personnel must prepare, save, and submit these documents as part of their proposal via Research.gov or Grants.gov.  Examples may include: Innovation in teaching and training; Contributions to the science of learning; Development and/or refinement of research tools; Computation methodologies and algorithms for problem-solving; Development of databases to support research and education; Broadening the participation of groups underrepresented in STEM; and Service to the scientific and engineering community outside of the individual’s immediate organization Synergistic activities must be specific and discrete.  Entries that include multiple components are not permitted.  Examples that are not permitted include: Committee member lists; Sub-bullets of honors and prizes; and Listing of organizations for which the individual as served as a reviewer.

Roles and Responsibilities Pertaining to NSF Grant Disclosure

Principal Investigators and Key Personnel

Principal Investigators and Key Personnel are expected to be forthright and transparent about relationships, resources, and activities.  Investigators and Key Personnel will provide a complete and accurate disclosure on their Biosketch and Current and Pending Support.  This includes:

1. Collecting their disclosure information from GMAS.
   • Follow the link below to go directly to the Other Support* download in GMAS: https://gmas.harvard.edu/gmas/othersupportdownload (Harvard provided link to automatic GMAS download of xls spreadsheet)
   • For assistance, refer to the Job Aid: GMAS Other Support and Activities Download (Harvard provided PDF)
2. Working with their Grant Manager to complete your submission

*Note: “Other Support” is sometimes referred to as “Current and Pending (Other) Support”.  The Other Support download and GMAS resources were originally developed to assist with NIH “Other Support” disclosures and may be used as a resource for “Current and Pending (Other) Support”.

Grant Managers

Grant Managers will assist PIs and Key Personnel in organizing, formatting, and completing their submission.  This may include:

1. Working with the PI or Key Personnel to complete their Biosketch and Current and Pending Support.
2. Formatting and reviewing for completeness and accuracy.

School or Central Reviewers

School or Central Reviewers will coordinate with Grant Managers and PIs or Key Personnel to ensure the accuracy and completeness of the submission.  This includes:

1. Reviewing Biosketch and Current and Pending Support for completeness and accuracy.
2. Submitting finalized Biosketch and Current and Pending Support to NSF.

Other Resources

Definitions

NIH and NSF Definition of Research:

A systematic study directed toward fuller scientific knowledge or understanding of the subject studied.

Harvard University Definition of Scientific Appointment:

Any academic or research appointment, including visiting, adjunct or temporary academic appointments, with a university, college, governmental or non-profit research institution and any fiduciary or executive level appointment with a for-profit entity engaged in commercial or research activities of a biomedical nature.

Harvard University Definition of Research:

Adheres to the Federal Policy for the Protection of Human Subjects (known as the “Common Rule” as defined in HHS regulation 45CFR46).  Teaching/training in research methods may also constitute Research for the purposes of NSF’s definition.

The Common Rule defines research as a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge. (45CFR46.102(l))

Harvard University Definition of Conducting Research:

To be a Project Director, Principal Investigator or to otherwise be responsible for the design, conduct or reporting of research regardless of title or position (e.g., an Investigator). This definition does not normally include service on scientific or clinical advisory boards or more general scientific consulting unless it is anticipated that the individual will make a direct and significant intellectual contribution to a specific research project for the entity.

Harvard University Definition of Research as Part of Consulting:

To be responsible for the design, conduct or reporting of Research regardless of title or position.  This does not normally include service on scientific or clinical advisory boards or more general scientific consulting, unless the Principal Investigator or Senior/Key Personnel is anticipated to make a direct and significant intellectual contribution to a specific Research project for the entity.  Such an activity may result in earning authorship on a publication describing or supporting a research activity, or any consulting activity that otherwise meets the definition of Research.

Harvard University Definition of Support:

Any resources (i.e., financial, in-kind, personnel, provision of high-value materials that are not freely available) made available to a Principal Investigator or Key Personnel for use by this individual to pursue their Research. This includes in-kind resources directly provided to the individual (e.g., office/laboratory space, equipment, supplies or employees or students funded by outside sources). This does not include institutional resources, such as core facilities or shared equipment, that are made broadly available.