January 10, 2022

Dear Faculty: 

Earlier last week, the Whitehouse Office of Science and Technology Policy (OSTP) released implementation guidance to inform federal funding agencies’ implementation of the National Security Presidential Memo – 33 (NSPM-33), which was originally released in January 2021. As a reminder, NSPM-33 established national security policy for federally-supported research and development, and included requirements for transparency and disclosures related to research activities. It was under the auspices of this framework that NIH and NSF issued revised guidance for Other Support and Biosketch submissions. OSTP’s January 2022 report further refines the guidance provided to federal agencies regarding their implementation of NSPM-33. Some reminders relevant to the January 2022 report are provided below.  

Disclosure requirements are substantially expanded (table 2a and 2b in the OSTP guidance) 

Federal funding agencies are requesting information to understand a researcher’s complete research portfolio and all of their affiliations. NIH and NSF have already shared new instructions for the biosketch and other support or current and pending documents that comply with these requirements. NSF began using these new instructions and forms in October 2021. NIH will require use of the new forms and instructions by January 25, 2022. 

Federal funding agencies are conducting consistency checks 

It is essential that these disclosures are complete. Some federal funding agencies have started (and others will soon begin) conducting “consistency checks” using third-party and publicly available information to identify affiliations and sources of support. 

Consequences for violation of disclosure requirements (page 11 in the OSTP guidance) 

Violation of disclosure requirements may lead to criminal, civil, and/or administrative consequences as may be deemed appropriate based upon the particular facts of the violation. Administrative actions include, but are not limited to: 

• Rejection of an R&D award application
• Preserving an R&D award, but requiring or otherwise ensuring that individual(s) do not perform work under the award; 
• Ineligibility for participation in U.S. Government review panels and other activities; 
• Suspension or termination of Federal employment 
• Suspension or termination of an R&D award
• Suspension or denial of Title IV funds by the Department of Education; and 
• Placement of the individual or research organization in the System for Award Management or Federal Awardee Performance and Integrity Information System to alert other agencies. 

Resources for researchers 

The Office of Sponsored Programs created a webinar that details the changes to the NIH biosketch and other support documentation: 

Full Link Here: https://web.microsoftstream.com/video/f3d8f04f-5c5a-4a5e-a3f2-692936bc8c1d

Researchers may contact their local RAS unit to discuss their individual situation when preparing their biosketch, other support, or current and pending support documents. 

If you would like to request a presentation or Q&A session for your department or academic unit about these disclosure requirements, contact Holly Sommers HSOMME2@emory.edu. 

Thank you, 

Deborah Watkins Bruner, RN, Ph.D., FAA

Senior Vice President for Research