Federal Funding Agency Requirements
In 2019, federal funding agencies began expressing serious concern that foreign entities were exerting inappropriate influence on U.S. research. Since that time, federal sponsors have implemented a variety of requirements which are designed to improve transparency into researchers foreign affiliations and engagements. Researchers who receive federal funding for research activities need to be aware of these requirements and how each federal agency defines foreign sources of support.
Primarily, federal funding agencies have increased disclosure requirements in the following areas:
Biographical Sketch Or “Biosketch”
A biographical sketch is required for each person identified as senior or key personnel and other significant contributors. The Biosketch must be up-to-date. The Biosketch must include:
- Education and Training
- Appointments and Positions whether or not remuneration is received, and, whether full-time, part-time, or voluntary
- Information to demonstrate how well qualified the individuals are to conduct the proposed project
- A list of products, e.g., publications, inventions, and other research products that demonstrate the individual’s qualifications relevant to the project as proposed.
Many federal funding agencies use a Common Form (SciENcv: Science Experts Network Curriculum Vitae) for Biosketch submissions in an effort to reduce administrative burden.
A Biosketch may be required at the time a proposal is submitted (pre-award) or at various times after the award is received (post-award). Biosketches are required:
- In competing applications;
- In progress reports when new senior/key personnel or other significant contributors are identified; and
- To support prior approval requests for changes in senior/key personnel status and changes of recipient organization.
Please refer to the Office of Sponsored Project’s webpage on Biosketch preparation and submission for more information and agency-specific information on completing the Biosketch.
Current & Pending/Other Support (“Other Support”)
Prior to 2019,“Other Support” to ensure that principal investigators were not over-extending their effort beyond a reasonable level. Now, in addition to evaluating effort, Federal agencies utilize “Other Support” reporting to identify and evaluate researcher affiliations, engagements, and collaborations with foreign individuals and entities. Sources of Other Support, particularly involving a Country of Concern, may indicate potential undue foreign influence which requires further evaluation and/or mitigation.
In general, Other Support 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. This includes resources and/or financial support from all foreign and domestic entities, consulting activities, and in-kind contributions of equipment, space, supplies, or personnel.
TAKE NOTE: Other Support includes resources and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and participation of student and visiting researchers supported by other sources of funding.
In-kind Current & Pending Support and In-kind Other Support include contributions requiring a commitment of time and directly supporting the individual's research and development efforts but not intended for use on the proposed/awarded project. These may include:
- the provision of office or laboratory space, equipment, supplies, or employees
- postdoctoral scholars, students, or visiting scholars who are supported by an external entity, whose research activities
- travel supported/paid by an external entity to perform research activities with an associated time commitment
- faculty or researcher startup packages from other than the proposing organization
- startup company based on non-organization-licensed IP
Please refer to the GW Office of Sponsored Projects webpage for additional information regarding Current & Pending/Other Support.
Foreign Component
In general, a Foreign Component occurs when any significant element or segment of the project occurs outside the United States, either by the grantee or by a researcher employed by a foreign institution, whether or not grant funds are expended.
Inclusion of a Foreign Component may expose project intellectual property to foreign parties, in advance of reporting such IP to the U.S. agency. Foreign Components are scrutinized carefully by federal agencies, particularly if they occur in a Country of Concern.
If a proposed or existing research project includes/ may include a Foreign Component in a Country of Concern (currently Iran, Cuba, North Korea, Russia, China, and/or Venezuela) please contact the Research Security office for assistance with evaluating compliance concerns related to this activity.
Research Security Training
Pursuant to NSPM-33, federal agencies are rolling out Research Security training requirements for principal investigators, key personnel, and in some cases, all individuals participating in the project. View information on each agency’s training requirements.
Agency-Specific Guidance
Review the tabs below for agency-specific guidance on the areas outlined above.
- National Institutes of Health (NIH)
BioSketch
The National Institutes of Health (NIH) and National Science Foundation (NSF) 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. The Intelligence Advanced Research Projects Activity has adopted this common form.
Other Support
Per NIH policy, Other Support information is required for:
- All individuals designated in an application as senior/key personnel, except
- Program Directors, training faculty, and other individuals involved in the oversight of training grants
- Individuals categorized as Other Significant Contributors
- All senior/key personnel, excluding consultants, in progress reports when there has been a change in active other support, except Program Directors, training faculty, and other individuals involved in the oversight of training grants
At this time, NIH has not yet adopted the Common Forms for the Biographical Sketch and Current and Pending (Other Support), which include the certification of non-participation in MFTRPs. Please refer to the GW Office of Sponsored Projects (OSP) webpage for the additional information regarding NIH Other Support and to access the relevant forms.
Supporting documentation for all foreign activities and resources that are reported in Other Support must be made available to NIH. If the contracts/agreements are not in English, recipients must provide translated copies.
Immediate notification of undisclosed Other Support is mandatory. If you become aware of activities or interests that should have been reported as Other Support, please notify the Office of Sponsored Projects (OSP) immediately. Pursuant to NIH rules, GW MUST immediately submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.
Foreign Component
***As of May 1, 2025, NIH will no longer accept prior approval requests to add a new foreign component or subaward to an ongoing project. Please contact the Office of Sponsored Projects with any questions about adding a Foreign Component.
Research Security Training
Effective October 1, 2025, recipients must implement trainings, in addition to maintaining a written and enforced policy, on requirements for the disclosure of other support to ensure Senior/Key Personnel fully understand their responsibility to disclose all resources made available to the 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.
- All individuals designated in an application as senior/key personnel, except
- National Science Foundation (NSF)
BioSketch
The National Science Foundation and the National Institutes of Health 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. The Intelligence Advanced Research Projects Activity has adopted this common form.
Current and Pending Support
Reporting is required for all PIs and Senior/Key Personnel on all proposals submitted after May 20, 2024. Only the SciENcv form is accepted for the preparation of the Current and Pending Support information.
PIs and co-PIs on active NSF awards must also indicate if there has been a “change in active other support” since submission of the proposal, or the last reporting period in their annual and final project report. If there has been a change, the individual must submit a revised Current and Pending Support document prepared in SciENcv as part of their project report. (See PAPPG 24-1 Chapter IX.C.2)
Please refer to the GW Office of Sponsored Projects webpage for the additional information regarding NSF Other Support.
International Activity (Foreign Component)
In accordance with the NSF Proposal and Award Policies and Procedures Guide (PAPPG II.E.8i), investigators must report research, training, and/or education activities carried out in cooperation with international counterparts either overseas or in the U.S. using virtual technologies. This includes travel to attend international conferences.
Research Security Training
According to NSF Important Notice No. 149: Updates to NSF Research Security Policies, starting on October 10, 2025, each individual identified as a senior/key person of a Federal Award must certify that they have completed the requisite research security training within 12 months prior to proposal submission.
- Department of Defense (DoD)
BioSketch
The Department of Defense has not issued comprehensive Biosketch requirements. Please refer to the individual Notice of Funding Opportunity for specific proposal requirements, and refer to the OSP Biosketch webpage for additional information.
Other Support/Foreign Component
According to the “2025 Department of Defense Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions”, all key personnel must report:
- 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
Please refer to the GW Office of Sponsored Projects webpage for the additional information regarding DoD Other Support.
Research Security Training
DoD agencies may require research security training on a project-by-project basis. If training is required, please contact the Research Security office at rsec
gw [dot] edu for assistance.- Department of Energy (DoE)
Biosketch
A biosketch is required for each principal investigator and key personnel. DoE strongly recommends that applicants use the SciENcv: Science Experts Network Curriculum Vitae format.
Other Support/Current and Pending Support
In general, principal investigator(s) (PD/PI) and senior/key persons must provide a list of all current and pending support for ongoing projects and pending applications. Specific DoE agencies, such as ARPA-E, may require more extensive reporting for all individuals participating in a research project. DoE requires the use of the Common Form for Current and Pending (Other) Support, which must be generated by the Science Experts Network Curriculum Vita (SciENcv).
Please refer to the GW Office of Sponsored Projects webpage for the additional information regarding DoE Other Support and to access the relevant sketch forms.
Foreign National Participation
According to DoE 0 142.3B (Chg 1), foreign nationals participating in DoE contracts may be required to file for DoE approval as required in the Contractor Requirement Document (CRD). In many cases, individuals who are citizens of a Country of Concern must receive DoE approval prior to participating in a DoE project.
Research Security Training
Effective May 1, 2025, DOE is mandating that Covered Individuals included on research and development (R&D) projects and/or applications must complete research security training. "Covered Individuals" include the PI, PD, Co-PI, Co-PD, or other individuals "who contribute in a substantive, meaningful way to the development or execution of the scope of work".
PIs/PDs are expected to certify that all Covered Individuals who will participate and/or have participated in the project have completed the training. PI/PD certification is completed via Current and Pending Support disclosure.
- National Aeronautics and Space Administration (NASA)
Biosketch
Per the NASA Grant and Cooperative Manual, NASA requires use of a NASA-specific form for principal investigator and key personnel biosketch submissions.
Other Support
NASA requires reporting from PIs, Co-PIs, and other individuals contributing in a substantive, meaningful way to the scientific development or execution of a research and development project report.
Please refer to the GW Office of Sponsored Projects webpage for the NASA Submission Checklist.
Foreign Component
Per 2 CFR § 1800.3(c), NASA does not normally fund foreign research proposals from foreign organizations, nor research efforts by individuals at foreign organizations as part of U.S. research proposals. This includes subawards from U.S. organizations to investigators at foreign organizations and travel by individuals at foreign organizations to conduct research, fieldwork, and present at conferences.
Research Security Training
NASA may require research security training on a project-by-project basis. If training is required, please contact the Research Security office at rsec
gw [dot] edu (rsec[at]gw[dot]edu) for assistance.*NASA does not allow NASA funds to be used to “develop, design, plan, promulgate, implement, or execute a bilateral policy, program, order, or contract of any kind to participate, collaborate, or coordinate, bilaterally in any way with China or any Chinese-owned company unless such activities are specifically authorized [by law.]”
- United States Department of Agriculture (USDA)
Biosketch
Individual USDA sub-agencies have separate USDA biosketch forms and requirements. Please refer to the agency announcement and/or individual sub-agency website for additional information on biosketch requirements.
Other Support
Since July 8, 2025, U.S. Department of Agriculture (USDA) requires that all recipients entering into an arrangement with USDA related to R&D or S&T must complete a Common Form for Current and Pending (Other) Support and a Common Form for Biographical Sketch (OMB Control Number 3145-0279) and must agree to update such forms at any subsequent time the Department deems appropriate during the term of the award.
Foreign Component
Recipients entering into an arrangement with USDA related to R&D or S&T must certify that they are not contracting, entering into arrangement with, or otherwise providing material or non-material benefit through the provision of funded or unfunded work to any foreign person or entity or any U.S. citizen or entity subject to foreign ownership, control, or influence by a country of concern or other foreign adversary unless appealed to and approved by the Secretary of Agriculture.
Research Security Training
Research security training is required for principal investigators and key personnel. GW must certify that training has been completed not more than one year prior to the date of project application and must re-certify annually for the duration of the award.