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COVID-19: Information from SPA/OSP/CGA

Current and Pending / Other Support Requirements by Sponsor

Current and Pending Support, also known as Other Support, is a form typically used by federal sponsors to request information for the PI(s) and Key Personnel’s current and pending research projects. Most federal agencies require Current & Pending Support documents to be submitted with the proposal or just before an award is issued, and if awarded, they may require any changes to be disclosed in progress reports. If applicable to your proposal/award, please remember to include ALL support including grants, and contracts from all non-U.S. and domestic sources, including MSU project support. The format of this requirement varies by sponsor. It is the responsibility of the Investigator/Key Person to make sure that all research projects and affiliations are disclosed and that the document is completed in its entirety.

Recently the Federal Government has been placing additional scrutiny on foreign influence and the impact to federal research.  This has resulted in some federal agencies providing additional guidance on what needs to be included in Current and Pending/Other Support documents.  Below are updates listed by agency.  This information will be updated as we learn of new requirements from federal agencies. If you have any questions related to Current and Pending Support being reported at the proposal or just-in-time stage, please contact your OSP Proposal Team.  For questions on how to report changes to Current and Pending Support at the award stage, please contact the CGA Awards Group.

National Institutes of Health (NIH)

UPDATE: NIH will require the new Other Support format for applications, Just-in-Time submissions, and Research Performance Progress Reports with due dates on or after January 25, 2022.  Although NIH extended the required date for use, they expect applicants and recipients to begin using the new format as of May 25, 2021.  For additional information see notice NOT-OD-21-110.

Definition of “Other Support”

With the release of their revised Grant Policy Statement in October of 2019, NIH revised their definition of Other Support.  The revised definition, “…includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.”

Who Must Report

  • At the Just-in-Time Stage (JIT) all individuals included in the grant application as senior/key personnel must submit Other Support information, except:
    • Other Significant Contributors
    • Program Directors, training faculty and others involved in the oversight of training grants
  • For Research Performance Progress Reports (RPPR) all senior/key personnel who have had a change in active Other Support must submit Other Support information, except:
    • Other Significant Contributors
    • Consultants
    • Program Directors, training faculty and others involved in the oversight of training grants

When to Report

  • At the Just-in-Time Stage – information gathered after proposal submission and prior to award.  
  • In the RPPR - changes to active Other Support should be submitted in the RPPR.
  • As soon as MSU becomes aware that Other Support information was not disclosed at the JIT or RPPR stage, the University must submit the updated information to the Grants Management Specialist named in the award.

What to Report

The following must be included on the Other Support form:

  • All ongoing projects/awards and proposals currently under consideration (listed in that order).
    • This includes proposals and awards that the individual participated with, that were not routed through MSU’s research administration system
    • When submitting Other Support information at the JIT stage, the related application should not be included. Conversely, when submitting Other Support information at the RPPR stage, the related NIH award should be included.
    • Internal MSU proposals / awards should be included.
  • Consulting activities that involve conducting research, regardless of whether or not remuneration is received.
  • Research conducted during the summer semester for faculty members with an Academic Year appointment, regardless of whether or not remuneration is received.
  • Participation in a foreign “talents” or similar program.
  • Financial support for laboratory personnel, travel, living expenses, etc.
  • High-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).
  • Start-up packages and all other research-related support from entities other than MSU, even if the research will be carried out at another institution.
  • Collaborations with other researchers outside of the applicant institution that directly benefit the individuals research endeavors.
  • In-kind contributions that are not intended for use on the project/proposal that the Other Support form is related to.  Examples include: office/lab space, equipment, supplies, or staff/students supported by an outside source.

The following may be excluded from Other Support:

  • Activities that are not research-related
  • Resources from the applicant institution, such as core facilities or shared equipment.  These should be listed under Facilities and Other Resources.
  • In-kind contributions for the project being proposed.  These should be listed under Facilities and Other Resources.
  • In-kind completed support from the last three years does not need to be included.
  • Start- up packages from Michigan State University.  
  • Consulting or professional service arrangements that do not involve conducting research.
  • Gifts – resources provided where there is no expectation of anything in return (would need to be reported if includes time, services, progress reports, etc.)
  • Training grants involving the reporting investigator as mentor or project director
  • Prizes given to the investigator 

Supporting Documentation—In addition to submitting the Other Support form, NIH is now requiring supporting documentation including, “…copies of contracts specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support.”  NIH has indicated that supporting documentation is not required to be included with Other Support until the revised January 25, 2022 date.  However, if requested by NIH staff, the information may still need to be sent to NIH prior to the required date.

  • All supporting documentation must be translated to English prior to submission to NIH.  It is the PI/departments responsibility to provide the translated documentation to the Office of Sponsored Programs (OSP) or Contract and Grant Administration (CGA) prior to submission.
    • NIH will accept machine-read translations (e.g. Google Translate)

What to include as supporting documentation:

  • Appointment letters or employment agreements with non-domestic entities.
  • If you are included on grants/contracts that are received by the non-domestic entity you have an appointment with, these grants/contracts need to be provided.
  • Agreements from non-domestic entities for resources such as, lab space, access to personnel, equipment, or any in-kind resources.

What to exclude as supporting documentation:

  • Sponsored project awards to MSU from non-domestic entities. This does not include non-domestic employment or appointment agreements. 
  • Supporting documentation does not need to be provided for completed support.

How to Report

  • This Other Support Format must be used for applications and RPPRs submitted for due dates on or after January 25, 2022.
  • NIH is anticipating that a template will be available in SciENcv beginning in FY 2022.
  • NIH has provided instructions for completing the new Other Support format as well as a new and renewal applications sample.  Highlights of key changes include:
    • NIH’s new template separates Project/Proposal support from In-Kind contributions.  Support should be grouped together based on their “Status” and reported in the order of Active, Pending or Completed during the past three years, (from top to bottom). Completed support does not need to be reported for In-kind contributions.
    • Primary Place of Performance has been added
    • Provide the Total Award Amount (including Indirect Costs)
    • Person Months must be provided per budget period for the project
      Year (YYYY) Person Months (##.##)
      1. [enter year 1]  
      2. [enter year 2]  
      3. [enter year 3]  
      4. [enter year 4]  
      5. [enter year 5]  
  • Signature spot for the PD/PI or other senior/key personnel to certify the form

    I, PD/PI or other key/senior personnel, certify that the statements herein are true, complete and accurate to the best of my knowledge, and accept the obligation to comply with Public Health Services terms and conditions if a grant is awarded as the result of this application. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties.

     
    *Signature:____________________________
    Date:____________________________

Submitting Other Support information at the Just-in-Time stage:

  1. Typically, the Office of Sponsored Programs (OSP) receives notice of the JIT request, and will contact the PI and Research Administrator (RA) to inform them of who in OSP will assist with review and submission. 
  2. OSP will provide a list of key personnel that need to provide Other Support.
  3. PI/RA will collect up-to-date Other Support information (using the NIH format and following NIH guidelines) from all Senior/Key Personnel included in the application. 
    • Each key person must electronically sign their respective Other Support form and send it to the lead PI/RA in a format that shows their original electronic signature.  The version with the original electronic signature must be retained by the department/college, to be made available upon request.  
      • OSP suggests that MSU key personnel provide a draft Other Support form for review prior to signing.  OSP will compare information on the form with data that is in KR, which may require updates to the form.
      • Record retention – For unfunded proposals, the original electronic signature must be kept for 18 months after the date the proposal was submitted.  For awarded proposals, the original electronic signature must be kept through the retention period for the award.
    • PI/RA will convert all Other Support forms to a flattened PDF file and upload into eRA Commons. 
    • PI/RA will also upload Supporting Documentation that is required to be submitted with Other Support.  Copies must be provided (in English) as part of the PDF, following the Other Support format page.
  4. PI/RA notifies OSP that JIT materials are ready for final review and submission.
  5. OSP will review based on the criteria provided in the Roles and Responsibilities chart, submit JIT, and send confirmation to the PI and/or RA.

Roles & Responsibilities for the MSU Other Support Process

Legend:

  • L = Lead Contact
  • S = Secondary Contact
Step OSP PI RA Key Person Task
  L        Email NIH Just-in-Time (JIT) notice to PI and Research Administrator (RA)
  L   S    Provide list of Senior Key Personnel that need to submit Other Support information
    L S L  Each Senior Key Person must update their Other Support form to include all required disclosures (see NIH instructions)
    S L    Send draft versions of Other Support forms to OSP for review (MSU Senior Key Persons only)
  L   S    Compare Other Support form with the information in MSU’s Research Administration System (for MSU Senior Key Persons only)
    L   L  Each Senior Key Person must electronically sign their Other Support form
    L L    Collect and save the original electronically signed Other Support form for all Senior Key Personnel
    L L    Convert all electronically signed Other Support forms to a flattened PDF file and attach to the JIT request in eRA Commons
    S L    Collect Supporting Documentation for all Senior Key Personnel, verify/convert to a flattened PDF file and attach to the JIT request in eRA Commons
    L   L  Transcribe any Supporting Documentation to English prior to submitting to NIH
  L        Review final JIT information and submit to NIH
  L        Send copy of the submitted JIT request to PI and RA

Additional Resources

National Science Foundation (NSF)

UPDATE 6/16/21:  NSF has created a disclosure table entitled, NSF Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Current and Pending Support, to help determine where disclosures should be provided.  The link includes archived versions of the disclosure table; please make sure you are viewing the current version.

Visit our new resource for guidance on how to fill out the new Current & Pending Fillable Forms. Please contact your OSP representative if you have any questions. Click here for summary information regarding NSF’s Current & Pending FAQs.

NSF revised their definition of current and pending (C&P) support in their upcoming 2020 Proposal and Award Policies and Procedures Guide (PAPPG)*.  The 2020 PAPPG was effective for proposals submitted or due, and awards made, on or after October 5, 2020.  The revised definition states that current and pending support includes, “…all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value.”  NSF also added that C&P support includes all in-kind contributions, not just those related to the project being proposed. 

  • In-kind contributions for the project being proposed to NSF should be included in the Facilities, Equipment and Other Resources section of the proposal and do not need to be included in the C&P form.  This includes in-kind contributions with and without an associated time commitment.
  • In-kind contributions that are not intended for use on the project being proposed to NSF only need to be reported if there is an associated time commitment.  This should be reported on the current and pending support form.
The table below shows NSF In-Kind Contribution reporting guidance for different scenarios.
NSF In-Kind Contribution Reporting Rules In-Kind WILL NOT Be Used on the Project In-Kind WILL Be Used on the Project
PI has a specific level of Committed Effort Disclose In-Kind on the C&P form Describe the In-Kind on the Facilities, Equipment, and Other Section of the proposal
PI has NO commitment of Effort Do not disclose on the C&P form Describe the In-Kind on the Facilities, Equipment, and Other Section of the proposal

Below are examples NSF provided for in-kind contributions.  If the time commitment or dollar amount is unknown, reasonable estimates should be provided. 

  • Office/Laboratory space
  • Equipment
  • Supplies
  • Employees
  • Students

Current and pending support includes the proposal being submitted, ongoing projects, and any proposal currently under consideration, from all sources, regardless of whether the support is provided through the proposing organization or is provided directly to the individual.  NSF has clarified that start-up packages provided to the individual from the proposing organization do not have to be reported.  Gifts also do not need to be reported (see NSF's FAQs for their definition of a gift).

NSF requires the Current and Pending Support form to be completed in an NSF approved format. Two options are available:

  • PDF fillable Current and Pending Support form
  • SciENcv will produce an NSF-compliant Current and Pending Support form

Additional information can be found on the NSF-Approved Formats for Current and Pending Support web page.

Department of Defense (DOD)

UPDATE September, 2021: DARPA issued a "Senior/Key Personnel Foreign Influence Risk Rubric" outlining the risk-based measures the agency is using to assess potential undue foreign influence, conflicts of interest or conflicts of commitment.  The risk assessment and rubric are included in all BAA's for grants and cooperative agreements.  DARPA will perform the assessment once an application has been identified for funding. Please visit DARPA's FAQ's on their Countering Foreign Influence Program for more information.

DOD requires full disclosure of current and pending support from domestic and non-domestic sources.

The Department of Defense issued a memo in March 2019 clarifying that all key personnel must disclose current and pending support in grant applications related to research and research-related educational activities.

Proposers shall submit the below information for all key personnel, whether or not the individuals' efforts under the project are to be funded by the DOD:

  • A list of all current projects the individual is working on, in addition to any future support the individual has applied to receive, regardless of the source.
  • Title and objectives of the other research projects.
  • The percentage per year to be devoted to the other projects.
  • The total amount of support the individual is receiving in connection to each of the other research projects or will receive if other proposals are awarded.
  • Name and address of the agencies and/or other parties supporting the other research projects.
  • Period of performance for the other research projects.

This information shall be included in the Senior Key Person Profile form included in the Notice of Funding Opportunity (NFO) and will not be included in the overall proposal page limits. Failure to submit this information may cause the proposal to be returned without further review.

Please note that DOD proposals for other types of awards may have different requirements; please check the program solicitation and direct any questions to your OSP Proposal Team.

Department of Energy (DOE)

On June 1, 2022 the Department of Energy released a Financial Assistance Letter (FAL), No. FAL 2022-04, to DOE and National Nuclear Security Administration (NNSA) Contracting and Grants Officers.  The FAL provided information and guidance on what should be included in Funding Opportunity Announcements (FOA) and Financial Assistance Agreements related to Current and Pending Support disclosures.  Effective immediately, DOE FOAs and newly issued Financial Assistance Agreements will include the following requirements for Current and Pending Support:

Who Must Report

  • All Senior/key personnel.  DOE defines Senior/key personnel as:
    • “An individual who contributes in a substantive, meaningful way to the scientific development or execution of a Research, Development and Demonstration (RD&D) project proposed to be carried out with a DOE award.”
    • DOE clarifies that typically these individuals have a doctoral or other professional degree, although individuals with other levels of education/experience may be considered Senior/key if their involvement meets the above DOE definition.
  • Other covered individuals.  At the award negotiation stage or during the performance of an award, DOE may designate project personnel as Senior/key and require their Current and Pending Support form.  This could include consultants, postdocs, graduate students, etc.

When to Report

  • Proposal stage: Follow the instructions provided in the Funding Opportunity Announcement for your proposal submission.  DOE instructed Contracting and Grants Officers to begin including these requirements in new FOA’s, as of June 1, 2022.
  • Award stage:
    • Adding new Senior/key personnel - If there are changes or additions to Senior/key personnel for the project, the new person must submit a Current and Pending Support form within 30 days of joining the project team, or on a timeline provided by the program office.
    • Changes to previously submitted Current and Pending Support – Changes to a previously submitted Current and Pending Support form must be submitted within 30 days of the change, or on a timeline provided by the program office.

Note: Typically not applicable to financial assistance agreements that exclusively fund conferences, workshops, and other technical meetings.

What to Report

The Current and Pending Support form must include:

  • “…all resources made available, or expected to be made available, to an individual in support of the individual’s RD&D efforts…”  This is regardless of:
    • Whether the source of support is domestic or non-domestic
    • Whether the resource is made available through MSU or directly to the individual
    • Whether the resource has monetary value
Examples include:
  • All proposals and ongoing projects/awards.  May also include past support, if so, the requirement to include past support as well as the timeframe, will be included in the Funding Opportunity Announcement. 
  • Research gifts (with or without terms and conditions)
  • Professional appointments, regardless of whether the appointment is:
    • Full-time, part-time or voluntary
    • Faculty, visiting, adjunct or honorary
  • Involvement in foreign government-sponsored talent recruitment programs
  • Consulting activities that involve conducting research
  • Research conducted during the summer semester for faculty members with an Academic Year appointment
  • “…in-kind contributions requiring a commitment of time and directly supporting the individual’s RD&D efforts.”  Examples include:
    • Provision of office or lab space
    • Access to equipment or supplies
    • Access to employee or student labor

How to Report

DOE uses NSF’s Current and Pending Support format, which can be completed through SciENcv, or the PDF template.  For each activity included on the Current and Pending Support form, include the following items:

  • Sponsor of the activity or source of funding
  • Award # or other identifying #
  • Title of award or activity
    • If the title of the activity isn’t descriptive, include a brief description of the research being performed.  The description should help identify overlaps or synergies with the proposed research.
  • Total cost of the proposal, award or activity, including direct costs, indirect costs and cost share.
  • Total project period (start and end date of the activity)
  • Person-months effort (per year) being dedicated to the award or activity
  • Use the overlap field to identify overlap, duplication of effort, or synergistic efforts with other awards or activities.

New – the Current and Pending Support form must be signed and dated, and include the following certification statement:

I, [Full Name and Title], certify to the best of my knowledge and belief that the information contained in this Current and Pending Support Disclosure Statement is true, complete, and accurate. I understand that any false, fictitious, or fraudulent information, misrepresentations, half-truths, or omissions of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (18 U.S.C. §§ 1001 and 287, and 31 U.S.C. 3729-3733 and 3801-3812). I further understand and agree that (1) the statements and representations made herein are material to DOE’s funding decision, and (2) I have a responsibility to update the disclosures during the period of performance of the award should circumstances change which impact the responses provided above.

The above certification statement is currently not included on the PDF template, nor is there a designated signature/date field.  This must be added to the PDF template, or if using SciENcv, it must be attached. 

Note: Details of any obligations to a program, entity or organization sponsored by a non-domestic government must be provided to DOE upon their request.  This may include providing supporting documents (with certified translation to English) of any identified source of support.

National Aeronautics and Space Administration (NASA)

NASA requires full disclosure of current and pending support from domestic and non-domestic sources

The following requirements are from the NASA Guidebook for Proposers Responding to a NASA Notice of Funding Opportunity, revised May 2020.

3.16 Current and Pending Support

PIs and Co-PIs must provide all ongoing and pending projects and proposals (regardless of salary support) in which they are performing or will perform any part of the work. Co-Is proposing to spend 10% or more of their time to the proposed effort must provide a list of ongoing and pending projects and proposals (regardless of salary support) that require a significant share (more than 10%) of their time. Proposals do not need to include the current proposal on the list of pending proposals unless submitted to another funding opportunity (NASA or another sponsor).

For those investigators for whom it is required (see above), the proposal shall provide following information for each current and pending project:

  • Title of funded project or proposal title;
  • Name of PI on award or proposal;
  • Program name (if appropriate) and sponsoring agency or organization, including a point of contact with their telephone number and email address;
  • Performance period;
  • Total amount received by that investigator (including indirect costs) or the amount per year if uniform (e.g., $50 k/year); and
  • Time commitment by the investigator for each year of the period of performance.

The proposing PI must notify the NASA Program Officer identified for the FA immediately of any successful proposals that are awarded for substantially the same research as proposed to NASA, any time after the proposal due date and until the announcement of NASA’s selections.

Current and pending support is not required for Co-Is at non-U.S. institutions. Current and pending support is usually not required for students. It may be requested, depending on the specifics of the Notice of Funding Opportunity (NOFO).

Please note that NASA proposals for other types of awards may have different requirements; please check the program solicitation and direct any questions to your OSP Proposal Team.

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