DoD Guidance

September 5, 2024

Faculty Disclosure Guidance for DoD submissions

Sponsor-specific tools and resources for submissions to the Department of Defense (DoD)

Title 2 of the Code of Federal Regulations (2 CFR) Subtitle B, Chapter XI Department of Defense

The DoD implements guidance pertaining to federal awards through 2 CFR Subtitle B, Chapter XI, Part 1104 titled “Implementation of Governmentwide Guidance for Grants and Cooperative Agreements. See below for links to the pertinent sections of 2 CFR:

• Part 1104 Implementation of Governmentwide Guidance for Grants and Cooperative Agreements
• Section 1103.100 Applicability of 2 CFR part 200 to requirements for recipients in DoD Components’ terms and conditions
• Part 200: UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS

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

Disclosure Guidelines for DoD submissions

On March 19, 2019, the Department of Defense (DoD) Under Secretary of Defense for Acquisition and Sustainment issued a Memorandum titled “Actions for the Protection of Intellectual Property, controlled Information, Key Personnel and Critical Technologies“.  This memorandum, citing Section 1286 (pp 443-445) of the 2019 National Defense Authorization Act (NDAA) (U.S. Congress provided PDF), outlined disclosure requirements for research and research-related educational activities supported by DoD grants, cooperative agreements, and Technology Investment Agreements (TIAs).  Included among the requirements is the obligation for proposers to submit a list of all current projects and future support key personnel have or have applied to receive. 

Title 2 of the Code of Federal Regulations (2 CFR) Section (§) 200.206, as implemented by the DoD through 2 CFR § 1103.100, requires the DoD to only collect information in grant applications using information collection forms approved by the Office of Management and Budget (OMB); OMB has approved the use of Standard Form (SF) 424 Research and Related (R&R) OMB number 4040-001. DoD policy is to use this suite of forms for proposals submitted in response to DoD research funding opportunities.  DoD components use the “Senior/Key Person Profile (Expanded)” to collect the required information as well as the Current and Pending Support efforts.  

Please note, the DoD provides funding through a variety of agencies with agency-specific requirements and submission policies; carefully read the specific program announcement, the preparation instructions may deviate and will supersede the guidance provided here.

For more information about DoD funding opportunities follow the links below:

Air Force Office of Scientific Research – AFOSR (DoD website), Congressionally Directed Medical Research Programs – CDMRP (DoD website), US Army Medical Research and Development Command – MRDC (DoD website), Defense Advanced Research Projects Agency – DARPA (DoD website), Defense Threat Reduction Agency – DTRA (DoD website), Office of Naval Research – ONR (DoD website), Special Operations Command – SOCOM (DoD website),

To search for additional DoD funding opportunities, use the websites below:

• Grants.gov
• eBRAP.org [Electronic Biomedical Research Application Portal]

DoD Risk Based Security Reviews

In accordance with National Security Presidential Memorandum– 33, the DoD Under Secretary of Defense for Research and Engineering signed out a Policy on June 8, 2023, that requires all fundamental research projects that are selected for award by the Department to go through a DoD review for potential conflicts of interest and conflicts of commitment arising from foreign influence.

• OUSD(R&E) Countering Unwanted Influence in Department Funded Research at Institutions of Higher Education, June 29, 2023
• DoD Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions (DoD PDF)
• U.S. Army Risk Matrix/Rubric (Army PDF, DEVCOM ARL Website)
• U.S. Army Research Risk Assessment Protection Program FAQs (Army PDF)
• DARPA Risk Based Security Reviews of Fundamental Research Process, December 21, 2023
• DARPA Fundamental Research Risk-Based Security Reviews Policy and Process, DARPA VPR Workshop, 26 August 2024

*Note: Many of the DoD organizations, such as DARPA, use arisk-based security review process which takes into consideration the entirety of the Covered Individual’s SF-424, current and pending support, and biographical sketch. These potential risk factors, along with any publicly available validation information, are then compared to the “DoD Risk Decision Matrix” to determine the level of mitigation that may be required to proceed, if possible.

Pre-Application

DoD Pre-Application

Biosketch

DOD Biographical Sketch (Biosketch)

Section A: Professional Preparation

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

Section B: Appointments and Positions

The list must include the following, whether or not remuneration is received and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).  List in reverse chronological order beginning with the current appointment: All positions, both domestic and foreign; All scientific appointments, both domestic and foreign; All affiliations with foreign entities or governments; All titled academic, professional, or institutional appointments; Any relevant academic and professional achievements and honors.

Section C: Products

Note: Review the solicitation and award terms carefully for program-specific requirements.  Agencies may elect to specify other types of products relevant to the mission of the agency. A list of products that demonstrate the individual’s qualifications to carry out the project as proposed.  Acceptable products must be citable and accessible including but not limited to: publications, conference papers, and presentations; website(s) or other Internet site(s); technologies or techniques; inventions, 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. Each product must include full citation information including: names of authors; product title; date of publication or release; website URL; other persistent identifier (if available); and other relevant citation information (e.g., in the case of publications, title of enclosing work such as journal or book, volume, issue, pages). If any of the items specified above is not applicable, indicate with N/A with the product entry.

DoD Current and Pending Support

Prepare an Inventory of In-Kind Support and Other Resources

All Harvard individuals who are designated as Key Personnel on a DoD award/subaward are required to report all their research support to DoD via the Current and Pending Support form.  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 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 DUAs and 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.  Gifts, that are provided with terms or conditions.

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) DUA Exporting Data Use Agreements from the DUA module (Harvard provided PDF)  Gifts may be listed on PI dashboard *Note: “Other Support” is sometimes referred to as “Current and Pending 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 all federal “Current and Pending Support”.

Certify with Electronic Signature

Each Current and Pending Support disclosure must be signed and dated and include the following certification statement: “I, PD/PI or other senior/key personnel, certify that the statements herein are true, complete and accurate to the best of my knowledge, agree to update such disclosure at the request of the agency prior to the award of support and at any subsequent time the agency determines appropriate during the term of the award and accept the obligation to comply with Section 223(a) of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021.  I also certify that, at the time of submission, I am not a party in a malign foreign talent recruitment program.  I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties.” If a fillable PDF format is used, the individual must include a signed, dated and certified statement using the language included above.

Undisclosed Other Support

Immediately notify your Research Administrator of any information that is missing and undisclosed in your Current and Pending Support.

Roles and Responsibilities Pertaining to DoD 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 Management

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 DOD.

School Contacts

Use the links below to contact your Research Administrator:

General Current and Pending and Biosketch

School	Main Contact	Email Address
FAS	RCP	rcp_outsideactivities@harvard.edu
GSE	Tiffany Blackman	tiffany_blackman@harvard.edu
HMS	Kelly Evans	Kelly_Evans@hms.harvard.edu
HSDM	Kelly Evans	Kelly_Evans@hms.harvard.edu
SPH	Melissa Francis	mjfrancis@hsph.harvard.edu
HKS	Carrie Kachoria	carrie_kachoria@hks.harvard.edu
SEAS	RCP	rcp_outsideactivities@harvard.edu
HLS	Jason Calieri	jacalieri@law.harvard.edu
Wyss	Katrin Duevel	katrin.duevel@wyss.harvard.edu
Other Schools	Contact your OSP Rep with Questions

Definitions

DoD and NSF Definition of Research:

DoD: A systematic study directed toward greater knowledge or understanding of the fundamental aspects of phenomena and of observable facts without specific applications towards processes or products in mind.

NSF: 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 NIH’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.