Federal Sponsor Reporting Requirements

The United States Federal Government has reiterated its commitment to promoting and protecting U.S. research and innovation from the risk of misappropriation, undue influence and theft by foreign governments.

Certain mandatory disclosures and reports are both an institutional and an investigator responsibility. In addition to federal sponsor requirements, both NSPM33 and the Chips and Science Act require investigator disclosures.

NSPM33, Chips + Science Act, and Other Background Information

Various federal funding agencies including the National Institutes of Health (NIH), the National Science Foundation (NSF), the Department of Energy (DOE), the Department of Defense (DoD), and the National Aeronautical and Space Agency (NASA) have issued notices and directives stating their commitment to safeguarding U.S. knowledge and intellectual property and reminding the U.S. research community of their disclosure obligations in regards to foreign entities and federally funded activities, including sponsored research. Beginning in 2019, these federal agencies individually began implementing changes in their reporting a disclosure rules, to address malign foreign influence.

In 2022, the Federal government issue both a National Security Presidential Memorandum (NSPM-33) and the Chips + Science Act. Both included broad requirements pertaining to Research Security. Among other areas, these regulations require expanded disclosure to federal agencies, prohibitions on participation in Malign Foreign Talent recruitment Programs (MFTRP), and prohibitions on engaging with certain entities in restricted or high-risk countries.

The Office of Science and Technology Policy (OSTP) issued further guidelines on February 14, 2024 regarding Foreign Talent Recruitment Programs, specifically prohibiting participation in a Malign Foreign Talent recruitment Program (MFTRP). The White House issued its Final Rule on July 09, 2024 fully implementing National Security Presidential Memorandum-33 (NSPM-33) in order to protect federally funded research against foreign government interference.

NSPM-33 requires funding agencies to implement rules for recipients to protect research security; provisions include:

Researcher disclosure requirements
Use of digital persistent identifiers (DPIs)
Appropriate consequences for disclosure violations
Sharing of information about violators, as consistent with applicable laws
Standards for research security programs
Harmonized definitions of key terms (note these may differ from State of Florida and/or FIU definitions)

The CHIPS and Science Act (2022) includes several research security provisions, including:

Prohibition of malign foreign government talent recruitment programs
Requirement to establish a Research Security and Integrity Information Sharing and Analysis Organization (RSI-ISAO)
Research security training requirement for all covered personnel
Inclusion of research security training as part of Responsible and Ethical Conduct of Research

Research security training may be included for certain researchers as a part of their required Responsible and Ethical Conduct of Research training.

University researchers are also reminded of their obligation to complete the University Outside Activities Report at least annually as set forth in the Conflict of Interest in Research policy # 2370.005

It is essential for PIs and other research personnel (as applicable), to accurately and comprehensively disclose all required data fields in their agency disclosures.

Elements of research proposals such as the Biosketch, Current & Pending (Other) Support, and Facilities and Equipment (Other Resources) are critical in supporting applications and enabling agencies to make funding decisions. The information contained in these components of the proposal become part of the award and must be kept up to date through the period of the award.

Federal agencies have begun to harmonize certain Research Security and reporting requirements, but some vary by agency. It is critical to understand the DIFFERENCES between agency requirements to ensure that these obligations are fully met.

Federal Agency-Specific Disclosure Requirements

Who Is Considered Key or Senior Personnel?

“Key” or “senior” personnel are Individuals who contribute significantly to the development or to the scientific or programmatic execution of a research or other sponsored project.
Key/senior personnel include but are not limited to:

principal investigators (PIs)
co-principal investigators (Co-PIs)

In addition to proving information about their ability to conduct the project, these personnel are required to disclose their sources of research funding to ensure transparency in identifying potential conflicts of interest or commitment. The information also helps the agency identify potential duplicate funding. Refer to each agency’s guidance to determine which project personnel are considered “key/ senior personnel”

Reducing Administrative Burden

To reduce administrative burden for researchers, all agencies are expected to adopt a common format for required reporting.

Biosketch– The National Science Foundation, the National Institutes of Health, the Intelligence Advanced Research Projects Activity, and the Department of Energy have partnered to use SciENcv: Science Experts Network Curriculum Vitae as the approved format for use in preparation of the biographical sketch section of proposals.
Current & Pending (Other) Support– NSF has adopted SciENcv to produce an NSF-compliant PDF versions of current and pending (other) support. (See https://www.nsf.gov/bfa/dias/policy/nsfapprovedformats/cps.pdf) Senior/key personnel must prepare, save, certify, and submit these documents as part of their proposal via Research.gov or Grants.gov.

In addition to disclosure requirements, the federal government has issued additional research-security related requirements that apply to research participants and programs.

Pursuant to NSPM-33 and agency requirements, research personnel are prohibited from participating in a Malign Foreign Talent Recruitment Programs [LD9.1]while performing federally funded research.
Most agencies now require mandatory Research Security training for at least Principal Investigators and Key Personnel. Some agencies/awards require training for ALL personnel.
Visiting Scholars, business visitors, and consultants engaged in research are a valuable part of FIU’s research enterprise. To avoid non-compliance and potentially negative impacts on the individual, the research program, and the university, these individuals’ efforts may also need to be evaluated through internal FIU processes and/or reported to federal and other sponsors. Learn more at our Special Considerations for Research-Engaged Visitors and Consultants & Visiting Scholars page

Relevant University Policies

Additional Resources and Documents

Need Assistance?

Questions? Please contact ORED at research@fiu.edu, Proposal Services at preaward@fiu.edu, and/or FIU Office of Compliance and Integrity at compliance@fiu.edu.

NSPM33, Chips + Science Act, and Other Background Information

NSPM-33 requires funding agencies to implement rules for recipients to protect research security; provisions include:

Researcher disclosure requirements
Use of digital persistent identifiers (DPIs)
Appropriate consequences for disclosure violations
Sharing of information about violators, as consistent with applicable laws
Standards for research security programs
Harmonized definitions of key terms (note these may differ from State of Florida and/or FIU definitions)

The CHIPS and Science Act (2022) includes several research security provisions, including:

Prohibition of malign foreign government talent recruitment programs
Requirement to establish a Research Security and Integrity Information Sharing and Analysis Organization (RSI-ISAO)
Research security training requirement for all covered personnel
Inclusion of research security training as part of Responsible and Ethical Conduct of Research

It is essential for PIs and other research personnel (as applicable), to accurately and comprehensively disclose all required data fields in their agency disclosures.

Biographical
Sketch
(Biosketch)

Learn more

Current &
Pending
(Other Support)

Learn more

Facilities &
Equipment
(Other Resources)

Learn more

Federal Agency-Specific Disclosure Requirements

Who Is Considered Key or Senior Personnel?

“Key” or “senior” personnel are Individuals who contribute significantly to the development or to the scientific or programmatic execution of a research or other sponsored project.

Key/senior personnel include but are not limited to:

principal investigators (PIs)
co-principal investigators (Co-PIs)

Reducing Administrative Burden

To reduce administrative burden for researchers, all agencies are expected to adopt a common format for required reporting.

Biosketch– The National Science Foundation, the National Institutes of Health, the Intelligence Advanced Research Projects Activity, and the Department of Energy have partnered to use SciENcv: Science Experts Network Curriculum Vitae as the approved format for use in preparation of the biographical sketch section of proposals.
Current & Pending (Other) Support– NSF has adopted SciENcv to produce an NSF-compliant PDF versions of current and pending (other) support. (See https://www.nsf.gov/bfa/dias/policy/nsfapprovedformats/cps.pdf) Senior/key personnel must prepare, save, certify, and submit these documents as part of their proposal via Research.gov or Grants.gov.

In addition to disclosure requirements, the federal government has issued additional research-security related requirements that apply to research participants and programs.

Pursuant to NSPM-33 and agency requirements, research personnel are prohibited from participating in a Malign Foreign Talent Recruitment Programs [LD9.1]while performing federally funded research.
Most agencies now require mandatory Research Security training for at least Principal Investigators and Key Personnel. Some agencies/awards require training for ALL personnel.
Visiting Scholars, business visitors, and consultants engaged in research are a valuable part of FIU’s research enterprise. To avoid non-compliance and potentially negative impacts on the individual, the research program, and the university, these individuals’ efforts may also need to be evaluated through internal FIU processes and/or reported to federal and other sponsors. Learn more at our Special Considerations for Research-Engaged Visitors and Consultants & Visiting Scholars page

Relevant University Policies