Federal Agency Guidance Regarding Disclosures of Other Support (Current and Pending Support)

UW-Madison Approach

Page Updated: August 14th, 2019

Note that this guidance is subject to change and will be revised as sponsors release new information.

This document contains guidance for completing Other/Current and Pending Support documents. Many federal agencies are revising their instructions regarding Other Support. They request similar, though not uniform, information and provide somewhat ambiguous instructions. Given these factors, we offer below some clarifying statements to standardize and set expectations on what to include in Other/Current and Pending Support documents submitted by UW-Madison.

  • It is the investigator’s responsibility to ensure the accuracy of Other/Current and Pending Support documents, in accord with the application guidelines or the sponsor’s instructions.
  • Any activity conducted within the scope of an Investigator’s UW-Madison appointment that provides funding or requires a quantifiable commitment of time must be reported.
    • Commitments are regular obligations of time (part of an investigator’s regular activities), not short-term obligations, such as attending a meeting and making a presentation.
    • If an investigator has a quantifiable commitment for an activity but is receiving no salary support from the activity (salary is cost shared by the University), that activity must be reported.
    • Typically, activities that provide funding or have a quantifiable commitment of time are Federal or Non-Federal sponsored projects (fund 144 or 133).
    • Awards resulting from internally-funded competitions, such as WARF funds, should be included only if there is measurable effort.
  • All collaborations and affiliations that provide funding or require a commitment of time must be reported, whether foreign or domestic.
  • For NIH Other Support documents, an Investigator’s VA-funded activities should be included. More guidance is included in the NIH section.

As appropriate, please:

  • Include the proposal being submitted as a pending proposal.
  • Address potential overlap or over-commitments. As this is a primary concern of Federal agencies, please be clear in your explanations.
  • List projects with no-cost extensions.
  • Update information as much as possible, e.g., remove outdated proposals or expired awards, unless specifically requested by sponsor, such as DoD.

What follows are examples of Federal sponsor-specific guidance on what they request in their Other Support documents. As sponsor guidance may change, RSP recommends that the investigator/department pay close attention to the sponsor’s instructions in the request for proposal, policy guide, etc. on how to prepare these documents. Each sponsor may request slightly different information or require that it be provided following their own format. RSP’s Current and Pending Support tool offers a method to prepare the information for some of the University’s largest sponsors.

Investigators and departments should be prepared to respond to a sponsor’s questions about the information provided in Other Support.

National Institutes of Health (NIH) Other Support

On July 10, 2019, the NIH Office of the Director issued Notice Number: NOT-OD-19-114 “Reminders of NIH Polices on Others Support and on Policies related to Financial Conflicts of Interest and Foreign Components”. This Notice changes some of the guidance NIH has provided in the past. This Notice is accompanied by FAQs. As NIH issues more anticipated clarifications on the Notice referenced above, RSP will update this guidance.

This Notice and associated FAQs indicate that ALL resources and other support be included, such as internal projects (i.e., WARF funds) and in-kind resources (e.g., space, equipment, supplies, employees). NIH instructs investigators to err on the side of diclosure and report. Please also read the section below, "Information from Recent Discussions with NIH."

RSP recognizes this updated guidance from NIH does not align with the designated reporting formats. RSP is engaged with national organizations such as Council on Governmental Relations (COGR) that are working with NIH to clarify and streamline this reporting requirement. We know NIH is developing new forms, but the timeline is not set.

From the NIH Grants Policy Statement, Revised October 2018:

Other support includes all financial resources, whether Federal, non-Federal, commercial or institutional, available in direct support of an individual's research endeavors, including but not limited to research grants, cooperative agreements, contracts, and/or institutional awards. Training awards, prizes or gifts are not included. Other support is requested for all individuals designated in an application as senior/key personnel-those devoting measurable effort to a project. Information on Other Support is not specifically requested for Program Directors, training faculty, and other individuals involved in the oversight of training grants since applicable information is collected in other sections of a training grant application. It is also not requested for individuals categorized as Other Significant Contributors.

IC scientific program and grants management staff will review this information before award to ensure the following:

  • Sufficient levels of effort are committed to the project.
  • There is no scientific, budgetary, or commitment overlap.
    • Scientific overlap occurs when (1) substantially the same research is proposed in more than one application or is submitted to two or more funding sources for review and funding consideration or (2) a specific research objective and the research design for accomplishing the objective are the same or closely related in two or more applications or awards, regardless of the funding source.
    • Budgetary overlap occurs when duplicate or equivalent budgetary items (e.g., equipment, salaries) are requested in an application but already are provided by another source.
    • Commitment overlap occurs when an individual's time commitment exceeds 100 percent (i.e., 12 person months), whether or not salary support is requested in the application.
    • Overlap, whether scientific, budgetary, or commitment of an individual's effort greater than 100 percent, is not permitted. Any overlap will be resolved by the IC with the applicant and the PD/PI at the time of award.
  • Only funds necessary to the approved project are included in the award.

Source: https://grants.nih.gov/grants/policy/nihgps/HTML5/section_2/2.5.1_just-in-time_procedures.htm

Information from Recent Discussions with NIH:

In addition to the excerpt from the GPS shown above, recent conversations with NIH suggest the University should use its best judgement about reporting activities in Other Support. NIH is working on updating the Other Support template to better accommodate the information being requested, which includes all resources made available to support all of an individual’s research endeavors (not just the project being considered for funding). The following information – all subject to change at a later date – reflects our current understanding of the intent of the Notice:

  • Participation in a foreign talent program needs to be disclosed.
  • Start-up funds provided by UW-Madison are not subject to disclosure in Other Support.
  • Consulting activities, which were part of the July 6, 2019 version of the FAQs, have been subsequently excluded from reporting requirements in Other Support.
  • Gifts, training grants, and prizes are still excluded from Other Support. Care must be taken to ensure that funds are appropriately categorized. See Gift Funds Policy.
  • Awards resulting from internally-funded competitions, such as WARF funds, should be included only if there is measurable effort.
  • Non-monetary support provided for the benefit of an investigator’s research endeavors needs to be reported. This would include resources and facilities that are uniquely available to the researcher, but would not include facilities, services, or resources available for shared use and not specific to the individual investigator. Those facilities, services and resources would typically be reported under the Facilities and Other Resources section of the application.
  • Individuals with a 9-month appointment must report any time spent conducting research under a foreign award over the summer. See the NIH FAQ on this topic.
  • All resources provided by a foreign organization, whether monetary or not, should be disclosed.
NIH Other Support for VA Supported Investigators

From Special Instructions for Individuals with Multiple Research Appointments (e.g., dual university/Department of Veterans Affairs appointments):

When an individual holds multiple appointments involving support for research activities, information from each appointment must be included separately in the Other Support documentation. The support from each funding source should be clearly and separately delineated so that the separate appointments can be considered independently when determining any potential overlap.

List each appointment separately and include enough information on the type of appointment; (e.g., full time academic or 6/8 VA) so that an assessment of an individual’s commitment can be made. Within each appointment, include appropriate sources of research support providing the standard detailed information cited above.

Note that when an individual has multiple appointments (UW & VA) it is possible that the combined effort can result in excess of 12 calendar months (not from any one institution, but a combination of multiple appointments). In all cases, an individual’s combined total professional effort must meet a test of reasonableness.

Source: https://www.research.va.gov/services/shared_docs/Other-Support-JIT.pdf

National Science Foundation (NSF) Current and Pending Support
The National Science Foundation released a draft Proposal and Award Policies and Procedures Guide (PAPPG) on May 29, 2019. Comments on the draft PAPPG are being considered by NSF and will impact new Current and Pending Support guidance. The timeframe for finalizing and implementing the new guidance is to be determined. Until then, the PAPPG cited below is in effect.

From NSF Proposal and Award Policies and Procedures Guide, February 25, 2019:

h. Current and Pending Support

This section of the proposal calls for required information on all current and pending support for ongoing projects and proposals, including this project, and any subsequent funding in the case of continuing grants. All current project support from whatever source (e.g., Federal, State, local, foreign, public or private foundations, industrial or other commercial organizations, or internal funds allocated toward specific projects) must be listed. The proposed project and all other projects or activities requiring a portion of time of the PI and any other senior personnel must be included, even if they receive no salary support from the project(s). The total award amount for the entire award period covered (including indirect costs) must be shown as well as the number of person-months per year to be devoted to the project, regardless of source of support. Similar information must be provided for all proposals already submitted or submitted concurrently to other possible sponsors, including NSF. Concurrent submission of a proposal to other organizations will not prejudice its review by NSF. The Biological Sciences Directorate exception to this policy is delineated in Chapter II.D.2.

If the project now being submitted has been funded previously by a source other than NSF, the information requested in the paragraph above must be furnished for the last period of funding.

A separate current and pending support pdf file, or other approved NSF template, must be uploaded in FastLane for each individual designated as senior personnel.

Source: https://www.nsf.gov/pubs/policydocs/pappg19_1/pappg_2.jsp#IIC2h

Department of Energy (DoE) Current and Pending Support
The Department of Energy has released a memo limiting participation in foreign talent recruitment programs. Guidance for how this limitation will apply to recipients of contracts, grants, and cooperative agreements is under development.

From FY 2019 Continuation of Solicitation for the Office of Science Financial Assistance Program, posted December 31, 2018:

APPENDIX 2: CURRENT AND PENDING SUPPORT

Provide a list of all current and pending support (both Federal and non-Federal) for the Project Director/Principal Investigator(s) (PD/PI) and senior/key persons, including subawardees, for ongoing projects and pending applications. List all sponsored activities or awards requiring a measurable commitment of effort, whether paid or unpaid.

For every activity, list the following items:

  • The sponsor of the activity or the source of funding
  • The award or other identifying number
  • The title of the award or activity
  • The total cost or value of the award or activity, including direct and indirect costs. For pending proposals, provide the total amount of requested funding.
  • The person-months of effort per year being dedicated to the award or activity

Provide the Current and Pending Support as an appendix to your project narrative. Concurrent submission of an application to other organizations for simultaneous consideration will not prejudice its review.

  • Do not attach a separate file.

Source: https://science.energy.gov/~/media/grants/pdf/foas/2019/SC_FOA_0001968.pdf

Department of Defense (DoD) Previous/Current/Pending Support
The Department of Defense has indicated that information provided in Previous/Current/Pending Support will be used to support protection of intellectual property, national security, and to limit undue influence. See Memorandum.

From General Application Instructions, Version 20170516, Department of Defense, Defense Health Program, Congressionally Directed Medical Research Programs:

  • PI Prevoius/Current/Pending Support: This file must be titled "Support_LastName.pdf," where "LastName" is the last name of the PI.
    • For all previous (award period of performance ending within the past 5 years), current, and pending research support, include the title, time commitments, supporting agency, name and address of the funding agency’s procuring Contracting/Grants Officer, performance period, level of funding, brief description of the project’s goals, and list of the specific aims. If applicable, identify where the proposed project overlaps with other existing and pending research projects. Clearly state if there is no overlap.
    • If there is no previous, current, or pending support, enter “None.” An updated previous, current, and pending support document will be required if an award is recommended for funding.

Source: https://cdmrp.army.mil/funding/pa/fy17-arp-gai.pdf

USDA National Institute of Food and Agriculture (NIFA) Current & Pending Support

From USDA NIFA Current & Pending Support template:

Instructions:

Who completes this template: Each project director/principal investigator (PD/PI) and other senior personnel specified in the Request for Applications (RFA). For Agriculture and Food Research Initiative (AFRI) applications, completion of this is only required for PDs/PIs and CoPDs/CoPIs.

How this template is completed:

  • Record information for active and pending projects, including this proposal.
  • All current efforts to which PD/PI(s) and other senior personnel have committed a portion of their time must be listed, whether or not salary for the person involved is included in the budgets of the various projects. For AFRI applications, list only projects for which salary is requested.
  • Provide analogous information for all proposed work which is being considered by, or which will be submitted in the near future to, other possible sponsors, including other USDA programs.
  • For concurrent projects, the percent of time committed must not exceed 100%.

Note: Concurrent submission of a proposal to other organizations will not prejudice its review by NIFA.

Source: https://nifa.usda.gov/sites/default/files/resource/current_pending_0.doc

National Aeronautics and Space Administration (NASA) Current and Pending Support

From NASA GUIDEBOOK FOR PROPOSERS RESPONDING TO A NASA FUNDING ANNOUNCEMENT, Revised as of March 2018:

3.16 Current and Pending Support (not required for contract proposals)

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 ongoing and pending project and proposals (regardless of salary support) that require a significant share (more than 10%) of their time. Proposals need not include the current proposal on the list of pending proposals unless it was also submitted to another FA or funding opportunity (whether at NASA or another sponsor).

For those investigators for whom it is required (see above), the proposal shall provide the 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 time that NASA’s selections are announced.

Current and pending support is not required for students or Co-Is at non-U.S. institutions.

Source: https://www.hq.nasa.gov/office/procurement/nraguidebook/