NIH updates

New data requirements for foreign subawards effective January 1, 2024

• The National Institutes of Health (NIH) issued Notice NOT-OD-23-182 and NOT-OD-23-133, updating requirements for consortium/subaward agreements to ensure that pass-through entities and auditors have access to a foreign subrecipient’s data and records at an agreed upon frequency, but no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. By access to, it is understood that such access may be entirely electronic.

Key actions to comply with new requirements

• OSP will add new certification language to each new outgoing subaward when the subrecipient is a foreign entity and will modify existing foreign subawards.
• OSP will work with potential subrecipients, at the application stage, to submit language in their letters of support indicating their awareness of these requirements and the subrecipient’s willingness to abide by all requirements should an award be issued.
• PIs should coordinate with their foreign subrecipients for when and how this information is delivered.
• PIs should review this information to confirm that the performance outcomes that are reported in the progress reports are accurate, complete, and properly reflect programmatic goals as part of subrecipient monitoring.
• This information should be retained by the PI for at least three years following the end of the award.
• NIH will not support any agreement that does not meet these new requirements.
• NIH reserves the right to request copies of the written agreement and relevant supporting documentation as needed, as part of its oversight responsibilities.

NSF Updates

NSF PAPPG (NSF 24-1): Effective for proposals submitted or due on or after May 20, 2024

Highlights of changes

Foreign organization eligibility – justification must include

• Why support from in-country resources are not feasible;
• Why the foreign organization/individual can carry out the activity more effectively;
• What unique expertise, organizational capability, facilities, data resources, and/or

Access to a geographic location brings to the project; AND

• What significant science and engineering education, training, or research

Opportunities the foreign organization/individual offers to the U.S.

Malign Foreign Talent Recruitment Programs (MFTRP)

• Any individual who is a current party to a MFTRP is ineligible to serve as a senior/key person on an NSF proposal or award.
• This requirement applies to any proposal submitted or due on or after May 20, 2024
• Definition of MRTRP is contain in the PAPPG Introduction, Section D.
• Each senior/key person must certify prior to proposal submission that they are not a party to a MTFRP (Biographical Sketch and Current and Pending (Other) Support).
• Each PI and co-PI on any NSF award must certify annually thereafter.
• A new term and condition will be added implementing this requirement post-award.
• Organizations must certify upon proposal submission that all senior/key personnel have been made aware of and complied with the requirement that they are not a party to a MFTRP

Post-award Foreign Financial Disclosure Report (FFDR) requirements (applies to each IHE that receives an award or funding amendment on an existing award made on or after May 20, 2024)

• Each IHE must submit an institutional report annually – negative reports are required
• Reporting includes any gift or contract with a cumulative value of $50K or more from a country of concern
• Reports must be submitted by July 31 each calendar year in Research.gov
• IHEs must maintain copies of relevant records
• NSF may request copies of contracts, agreements, or documentation of financial transactions associated with disclosures.
• Organizations other than IHEs are not required to submit annual FFDR reports
• A new term and condition will be added implementing this requirement post-award.

Mentoring plan requirement expanded to include graduate students

• Funding for graduate students and/or postdoctoral scholars must include a mentoring plan not to exceed one page.
• There are not separate plans for graduate students and postdoctoral scholars.
• A single plan must be included for all graduate students or postdoctoral researchers supported by the project regardless of whether they reside at the submitting organization, any subrecipient organization, or at any organization.
• Participating in a simultaneously submitted collaborative proposal.

Biographical Sketch

• Required for each individual identified as a senior/key person.
• Used to assess how well qualified the individual, team, or organization is to conduct the proposed activities.
• Individuals are required to disclose contracts associated with participation in programs sponsored by foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs.
• Must certify that they are not a party to a MFTRP.
• Page limitation has been removed from the biographical sketch (still up to 10 products can be cited).
• Must be created in SciENcv.

Synergistic Activities

• Removed as an element of the biographical sketch.
• It must be included as a separate upload for each senior/key person in Research.gov.
• May be up to one page that includes a list of up to five distinct examples that demonstrate the broader impact of the individual’s professional and scholarly activities that focus on the integration and transfer of knowledge as well as its creation.

Current and Pending (Other) Support

• Required for each individual identified as a senior/key person.
• Used to assess the capacity or any conflicts of commitment that may impact the ability of the individual to carry out the research effort as proposed.
• Information helps assess any potential scientific and budgetary overlap/duplication with the project being proposed.
• Must certify that they are not a party to a MFTRP.
• Must be created in SciENcv.

Impacts on Tribal Nation

• Proposals that may impact the resources or interests of a federally recognized American Indian or Alaska Native Tribal Nation (Tribal Nation) will not be awarded by NSF without the prior written approval from the designated official(s) from the relevant tribe(s).
• For these purposes, references to “resources or interests of a Tribal Nation” are limited to resources and interests connected to Tribal Nation lands or those aspects of Tribal life that are within the domain of a Tribal Nation, (including, but not limited to, Tribal languages and subsistence rights on Tribal Nation lands) as opposed to individual Tribal Nation members.
• New Proposal Preparation Instructions:
• New checkbox on the Cover Sheet to indicate if there are “Potential Impacts on Tribal Nations”.
• Proposers seeking funding for such proposals must provide at least one of the following at time of proposal submission:

(i) A copy of the written request to the Tribal Nation for the activities that require review and approval;

(ii) Prior to award, a written confirmation from the Tribal Nation(s) that review and approval is not required; or

(iii) A document providing the requisite approval.

Post-award additions

Post-award addition of postdoctoral researchers or graduate students

• If the original proposal already included a mentoring plan, no further documentation is necessary; if it did not include a mentoring plan, the recipient must provide one to the NSF Program Officer.
• PI must report on mentoring in annual and final annual reports
• A new term and condition will be added implementing this requirement post-award.

Post-award addition of a safe and inclusive working environment

• If the original proposal already included Plan for Safe and Inclusive Working Environments, no further documentation is necessary; if it did not include such a plan, one must be developed and maintained in the organization’s records.
• A new term and condition will be added implementing this requirement post-award.

Scientific Integrity – new definition

• Scientific integrity is the adherence to professional practices, ethical behavior, and the principles of honesty and objectivity when conducting, managing, using the results of, and communicating about science and scientific activities. Inclusivity, transparency, and protection from inappropriate influence are hallmarks of scientific integrity.
• An updated NSF Scientific Integrity Policy is publicly available on the NSF website: https://new.nsf.gov/policies/scientific-integrity

Notice to the Research Community with guidelines for safeguarding the integrity of the development and evaluation of proposals in the merit review process (December 2023).

• Use of Generative AI by Reviewers
• NSF reviewers are prohibited from uploading content from proposals, review information and related records to non-approved AI tools.
• Use of Generative AI in Proposal Preparation
• Proposers are encouraged to indicate in the project description the extent to which, if any, generative AI technology was used to develop their proposal.