Forms, Policies & Procedures

Direct Charging Procedure

1. SCOPE OF PROCEDURE
   This procedure outlines University of Delaware (“UD” or “University”) requirements for allocating direct costs to sponsored projects, and applies to all University departments, units, faculty, staff and students involved in externally sponsored research.
2. DEFINITIONS
   1. Direct Costs – Costs which can be identified specifically with a particular sponsored project and which can be directly assigned to such activities, relatively easily and with a high degree of accuracy.
   2. Facilities & Administrative (F&A) Costs – Costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives.
   3. Cost Principles – Fundamental conditions for ensuring costs are permissible on a sponsored project, including:
      1. Allowability or Allowable – Costs must be permissible under the terms and conditions of the award, including the authorized budget and applicable regulations
      2. Allocability or Allocable – Costs must provide a sole benefit to the sponsored project or provide proportionately assignable benefits to the sponsored project.
      3. Reasonableness or Reasonable – Both the nature of the goods or services acquired and the amount paid must reflect the action that a prudent person would have taken at the time the decision to incur the cost was made.
      4. Consistency – Application of costs must be given consistent treatment within established University policies and procedures; costs for the same purpose must be treated and classified the same way under like circumstances.
   4. Allocation – The process of assigning a cost, or a group of costs, to one or more sponsored projects and/or cost objectives.
   5. Principal Investigator (“PI”) – The individual designated in a grant or contract to be responsible for ensuring compliance with the academic, scientific, technical, financial and administrative aspects and for day-to-day management of the sponsored project (grant or contract).
   6. Sponsored Projects – Externally-funded activities in which a formal written agreement (i.e., a grant, contract, or cooperative agreement) is entered between the University and the sponsor.
3. PROCEDURE STATEMENT
   The purpose of this procedure is to ensure University compliance with applicable cost principles and federal regulations set forth for allocating direct costs per Office of Management and Budget (OMB) Circular A-21 and Uniform Guidance 2 CFR 200. Key guidance under this procedure includes:
   • Direct costs must meet conditions for allocability, allowability, reasonableness and consistency established under federal regulations.
   • A cost is allocable to a sponsored project if the goods or services involved are chargeable or assignable to that sponsored project in accordance with relative benefits received.
4. STANDARDS AND PROCEDURES
   1. Direct vs. F&A Cost Considerations
      1. Uniform Guidance establishes principles to help determine the applicability of costs to federal grants, contracts, and other agreements. It prescribes which costs are allowable for recovery from the government and, of the allowable costs, whether the educational institution should treat them as direct or facilities & administrative (F&A) costs
      2. Common examples of F&A costs include:
         1. Administrative/Clerical Staff
         2. General Office Supplies/Equipment
         3. Postage
         4. Communications (ex. Cells Phones, Telephones, Internet)
         5. Facilities Operations & Maintenance
      3. Costs that are normally considered F&A costs may be allowable as direct costs if they meet all the following criteria:
         1. An unlike circumstance exists in which a sponsored project requires resources beyond those normally expected for a typical research project;
         2. The cost can be associated with the specific sponsored project with a high degree of accuracy;
         3. The costs are not also recovered as indirect costs; and
         4. The awarding agency has explicitly approved the cost as a direct expense in the awarded budget or per written prior approval.
      4. If costs that are normally considered F&A costs are allocated as direct costs to a sponsored project, but do not meet approval criteria per section (3)(d) above, sufficient supporting justification is required to ensure the costs are allowable on the sponsored project. Otherwise, the costs will be deemed unallowable and must be removed from the sponsored project. An after-the-fact explanation attesting to the benefit to the award is insufficient justification to treat these expenses as direct costs on federal awards.
   2. Direct Cost Allocation Methodologies
      1. Direct costs may be allocated only if they advance the work of the sponsored project(s) in the same proportion as the cost.
      2. Direct cost allocations on sponsored projects should not be based on budget, funding or availability of funds, as these factors are not evidence of the allocability of a cost.
      3. Direct Cost Allocation Principles:
         1. If a cost benefits one sponsored project, it should be charged in its entirety to the sponsored project.
         2. If a cost benefits two or more sponsored projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the sponsored projects based on the proportional benefit.
         3. If a cost benefits two or more sponsored projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (d) of this section, the costs may be allocated or transferred to benefitted sponsored projects on any reasonable documented basis.
         4. Where the purchase of equipment or other capital asset is specifically authorized under a federal award, the costs are assignable to the federal award regardless of the use that may be made of the equipment or other capital asset involved when it is no longer needed for the purpose for which it was originally required.
      4. Examples of Cost Allocation Methodologies:

      GENERALLY ACCEPTABLE

      Allocation Basis

      Example

      Effort

      A research assistant spends 80% effort on Project A and 20% effort on Project B. The research assistant uses supplies totaling $3,000/month on the two projects. Usage is directly related to the amount of effort devoted to each project, therefore, $2,400 (80% of $3,000) is charged to Project A and $600 (20% of $3,000) is charged to Project B.

      FTEs

      There are 5 FTEs employed on Project A and 8.5 FTEs employed on project B.  These are the only two sponsored projects that are performed and managed in the lab, and the monthly supplies total $5,500.  Project A should be charged $2,037.04 (5/13.5 x $5,500) and Project B should be charged $3,462.96 (8.5/13.5 x $5,500). 

      Usage

      The monthly cost of supplies/expendables to maintain a lab computer system is $1,000. The computer system is used solely for projects A and B. The computer operating system keeps a log of users and their time on the system. A reasonable base to allocate the expense would be computer user hours. Project A assistants have 100 combined user hours a month and project B assistants have 80 combined user hours a month. The cost allocated to project A is $560 (100 user hrs. /180 total user hrs. x $1,000). The cost allocated to project B would be $440 (80 user hrs. /180 total user’s hrs. x $1,000).

      Number of Experiments

      A PI uses syringes to conduct experiments on two of his research grants. The syringes are only good for one experiment and then they must be thrown away. The PI keeps a log of how many experiments are performed on each project per week. Syringes are ordered every two weeks at $1.05 per syringe. The log indicates the following:

      • Project A: Week 1: 25 Experiments, Week 2: 39 Experiments
      • Project B: Week 1: 19 Experiments, Week 2: 16 Experiments

      The total cost of the syringes is $103.95 (99 experiments x $1.05/syringe). Project A should be charged $67.20 (64 experiments x $1.05/syringe) and Project B should be charged $36.75 (35 experiments x $1.05/syringe).

      Square Footage

      A student is paid a salary of $1,500 a month to clean glassware in two laboratories that are conducting similar research. In this example, the square footage of the laboratories could be used as a reasonable basis. Lab A is 1,600 square feet and Lab B is 1,200 square feet. Lab A is charged $855 (1,600-sq. ft/2,800 sq. ft x $1,500) and Lab B charged $645 (1,200-sq. ft/2,800 sq. ft x $1,500).

      Reasonable Determination without Undue Effort or Cost

      The lab has two ongoing sponsored projects and purchases a $3,000 apparatus to be used equally on both projects, so both Project A and Project B are each charged $1,500 (50%).  Since Uniform Guidance allows for proportions to be determined without undue effort or cost, the supporting justification explaining the reasonable determination is generally acceptable.

      Other Quantitative Rationale

      The PI provides a quantitative rationale that is both reasonable and adequately supported with documentation, whereby the total cost can be divided based on a percentage calculated using the quantitative rationale.

      GENERALLY QUESTIONALBE OR UNACCEPTABLE

      Allocation Basis

      Example

      Restocking

      Restocking materials and supplies is an acceptable practice only if the usage of materials and supplies is tracked or logged and included with the supporting documentation for the transaction. If the usage is not tracked or logged, it is infeasible to adequately support that restocking transactions are allocable to the sponsored project. If the usage is not included with the supporting documentation, there is insufficient support to determine that materials and supplies benefitted the sponsored project.

      Offset

      Costs were charged to Project A one month, and the next month costs were charged to Project B to offset what should have been split allocations each month between the two projects.

      Available Funding

      27% of costs were allocated to Project A to zero out the remaining available balance, and the remaining 73% of costs were allocated to Project B. An exception to this would be if the entire cost was allocable to the sponsored project, but a portion of the cost was allocated to non-sponsored project funding (ex., start-up funds).

      Unreasonable Determination without Undue Effort or Cost

      The lab has three ongoing sponsored projects and purchases a $3,000 apparatus to be used on each project, so Project A is charged $1,350 (45%), Project B is charged $450 (15%), and Project C is charged is charged $1,200 (40%). This is generally an unreasonable determination without additional documentation to support the specific percentages selected for the split allocation.

   3. PI/Department Responsibilities
      1. Determine the appropriate allocation methodology to use to allocate direct costs consistent with the benefits received to each sponsored program.
      2. Maintain documentation supporting allocations and review/update the methodologies as necessary.
      3. Review sponsored research projects on a regular basis (at least monthly) to ensure that all direct costs charged are correct and appropriate.
      4. Ensure that all personnel engaged in financial administration of federally-funded sponsored projects are familiar with the University direct charging procedures.
   4. Research Office Responsibilities
      1. Develop and implement direct charging procedures in accordance with the regulations outlined in Uniform Guidance 2 CFR 200, Subpart E – Cost Principles.
      2. Assist in the interpretation and implementation of the direct charging procedures.
      3. Periodically review justifications and/or supporting documentation provided for direct cost allocations to sponsored programs to ensure documented adherence to the direct charging procedures.

 

Record Retention Procedure

1. SCOPE OF PROCEDURE
   This procedure outlines record retention responsibilities of Principal Investigators (PIs), Department/College Administrators, Research Office Pre-Award and Post-Award Teams, and other responsible parties involved in the administration of sponsored programs.

   All University faculty and staff who are responsible for administering externally sponsored grants and contracts should be familiar with this procedure.

2. DEFINITIONS
   1. Sponsor or Sponsoring Agency – An external entity responsible for providing project funding if UD’s proposal is accepted and an official award agreement is subsequently executed.
   2. Record – Documentation pertinent to the programmatic and financial management of an externally-sponsored award.
   3. Record Retention Period – The required amount of time for which records must be maintained for a particular externally-sponsored award.
3. PROCEDURE STATEMENT
   The purpose of the Research Office Record Retention Procedure is to ensure record retention and destruction for sponsored programs is conducted in accordance with UD, federal, and sponsor requirements. This mitigates potential UD financial and compliance risk by:
   • Ensuring UD’s ability to provide adequate support documentation to internal parties and authorized external entities when appropriate, especially during audit activities.
   • Establishing a limited time period for record retention, thereby mitigating UD exposure to late audit requests or potential information breaches by unauthorized external entities.

   It is the procedure of the University of Delaware (UD) to retain and dispose of documentation associated with sponsored programs in accordance with applicable sponsor requirements, as well as federal regulations per Uniform Guidance including:

   • §200.333 Retention Requirements for Records
   • §200.334 Requests for Transfer of Records
   • §200.335 Methods for Collection, Transmission, and Storage of Information
   • §200.336 Access to Records
4. STANDARDS AND PROCEDURES
   1. PIs, Department/College Administrators, and Research Office employees are responsible for retaining award records for sponsored programs. This includes financial records, supporting documents, statistical records, and other UD records pertinent to the award. Records must be maintained for active awards and archived for expired awards based upon standards outlined in this procedure.
   2. UD is obligated to provide authorized external parties (such as sponsors or auditors) with access to award records and documentation for the purpose of audits, examinations, excerpts, and transcripts. This includes timely and reasonable access to UD personnel for the purpose of interview and discussion related to such documents. Inability of UD to provide necessary records to sponsors or other authorized parties upon request may result in adverse financial or compliance impacts, such as potential disallowance of unsupported project costs
   3. It is the preference of UD (and federal sponsors) that award records be maintained in electronic rather than paper formats when practicable. Copies of original records, either in paper or electronic format, may be substituted for original records, so long as they remain unaltered and readable.
   4. D. PIs, Department/College Administrators, and Research Office employees are responsible for maintaining primary support documentation for sponsored programs in local Shared Drives as well as other electronic systems. The table below outlines common award records and storage methods maintained under this procedure:

   STORAGE METHODS FOR AWARD DOCUMENTATION

   Document Type

   Storage Method

   Proposal Documentation
   submitted to the sponsor such as budgets, budget justifications, scope of work, subaward documents, abstracts, etc.

   • PeopleSoft Attachments
   • Cayuse
   • Webforms (Proposal Approvals)
   • Local Shared Drives
   • Sponsor Web-Based Portals (ex: Proposal Submissions)

   Official Award Notices
   and contractual documents issued to UD from the sponsor.

   • PeopleSoft Attachments
   • Local Shared Drives
   • Sponsor Web-Based Portals (ex: Grants Management)

   Programmatic Support Documents
   pertinent to the award administration including detailed budgets, institutional approvals, and important correspondence.

   • PeopleSoft Attachments
   • Local Shared Drives
   • Webforms (ex: Proposal Approvals, Budget Adjustments)

   Financial Reports and Invoices
   submitted to the sponsor to report expenditures and/or request payment.

   • PeopleSoft Attachments
   • Local Shared Drives
   • Sponsor Web-Based Portals (ex: Federal Financial Reports, Payment Management Systems)

   Financial Backup
   supporting award expenditures and reporting such as account reconciliations, receipts, cost transfer forms, and expense approvals.

   • PeopleSoft Attachments
   • Local Shared Drives
   • Webforms (ex: Automated Closeout Reports, Journal Vouchers, Cost Transfers, Purchase Orders)
   • Concur/Works (ex: Expense Approvals)
   • Effort Reporting System

   Technical Reports and Deliverables
   submitted to the sponsor to report research program outcomes.

   • Local Shared Drives
   • Sponsor Web-Based Portals (ex: Technical Reports)
   • Webforms (ex: Automated Closeout Reports)

   Compliance Protocols
   and approvals related to sponsored research programs (e.g. human and animal subjects).

   • IRBNet (ex: IRB/IACUC Protocols)
   • Local Shared Drives
   5. Records should be disposed of upon expiration of the required record retention period for an award in order to limit excess audit risk and potential information breaches to UD. Unless a longer duration is required by the sponsor, or per other exceptions outlined in the table below, it is UD’s procedure to retain records for four years after an award’s end date. Destruction of such records should follow UD protocols to ensure they are no longer needed for reference.

   EXCEPTIONS TO THE STANDARD FOUR-YEAR RECORD RETENTION PERIOD

   Exception Scenario

   Retention Period

   Exception Description

   Sponsor or Award Specific Retention Period

   Per Sponsor Requirements

   Retention requirements may vary depending on award guidelines, terms, and conditions set by the sponsor. These may be stricter than the standard four-year retention period and will be evaluated on a case by case basis. PIs and their Department/College Administrators should contact the Research Office with any questions regarding the specific record retention requirements applicable to their award.

   Litigation, Claim, or Audit

   Until Resolution

   If any litigation, claim, or audit is started before the expiration of the four-year period, the records shall be retained until all litigation, claims or audit findings involving the records have been resolved and final action has been taken.

   Written Notice for Extension

   Per Written Notice

   UD will comply with any official written notice by a Federal sponsor, cognizant agency for audit, oversight agency for audit, cognizant agency for indirect costs, or pass-through entity to extend the record retention period.

   Final Financial Report Submitted ≥1 Year After the Award End Date

   3 Years After Final Financial Report Submissions

   If under rare circumstances, the final financial report was submitted or revised ≥1 year past the award’s expiration date, the award will be retained for 3 years after the final financial report was submitted to the sponsor.

   Real Property and Equipment

   3 Years After Final Disposition

   Records for real property and equipment acquired with Federal funds must be retained for three years after final disposition.

   Records Transferred

   Not Applicable to UD

   When records are transferred to or maintained by a Federal sponsor or pass-through entity, the record retention requirement is not applicable to UD.

   Program Income Transactions

   3 Years After the Applicable Fiscal Year End Date

   In some cases, UD must report program income after the period of performance. When this requirement exists, the retention period for the records pertaining to the earning of the program income starts from the end of UD’s fiscal year in which the program income is earned..

   Facilities and Administrative Cost Rate Proposals

   3 Years After the Date of Proposal Submission, or 3 Years After the Applicable Fiscal Year End Date

   For facilities and administrative cost rate computations or proposals, cost allocation plans, and any similar accounting computations of the rate at which a particular group of costs is chargeable (such as computer usage chargeback rates or composite fringe benefit rates):

   • If submitted for negotiation, a three-year retention period for supporting records starts from the date of such submission.
   • If not submitted for negotiation, a three-year retention period starts from the end of the fiscal year covered.

 

UD Procedure/Guidance for Preparation of Other Support (Current and Pending Support)

BACKGROUND AND IMPORTANCE
The University of Delaware researchers should be transparent regarding their other research support, other research activities, and research collaborations when submitting grant proposals to external sponsors. Disclosure of such support, via forms commonly referred to as “Current and Pending” or “Other Support,” allows the identification of potential duplication of funding, assessment of the investigator’s capacity/available effort to complete proposed projects, the evaluation of potential conflicts of interest, and the overall protection of national security and economic interests.

While the format/form being provided to the sponsor may vary, if applicable to a proposal under development, PIs should include ALL support, including grants and contracts from all domestic and non-U.S. sources, including support internal to UD. Additional guidance is generally available in the specific funding opportunity announcement to which the proposal is responding and MUST be followed to avoid return without review or other negative consequences.

Federal agencies are increasingly placing additional scrutiny on potential foreign influence and its impact upon the U.S. research enterprise. Efforts at the federal level are currently underway to standardize disclosure requirements, and some agencies have provided additional guidance on completing disclosure documents. For additional assistance, please contact your departmental administrator.

GENERAL GUIDANCE
Below are some clarifying statements to standardize and set expectations on what to include in Other Support or Current and Pending Support documents submitted by the University of Delaware. Regardless of the sponsor, information provided in Other Support or Current and Pending Support documents must be current, accurate, and complete.

Tip	Notes
Any activity conducted within the scope of an Investigator’s UD appointment that provides funding or requires a 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 commitment for an activity but receives no salary support from the activity (salary is cost shared by the University), that activity must be reported. Even if a research project does not involve a quantifiable commitment of time, if the PI/senior key personnel are spending time on the project, the project should be included. Awards resulting from internally-funded competitions (UDRF,GUR, etc.) may need to be included as in-kind commitments since although there may not be salary in the budget, time will still be expended on the project.
Include all collaborations and affiliations that provide funding or require a commitment of time, whether foreign or domestic.
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.	Active awards must have associated effort
Update information as much as possible, e.g., remove outdated proposals or expired awards, unless specifically requested by sponsor.
For subawards to UD, include the total amount specific to the subaward requested or received by UD.
Include consulting agreements where the PI or senior/key personnel will be conducting research as part of the consulting activities.	If the agreement will result in a co-authored publication, it may be considered research. Consulting may be outside of the scope of an individual’s UD appointment, but may need to be included. See NIH FAQs  and the NSF Pre-award and Post-award Disclosures table.
In-kind contributions should be reported for NIH and NSF, per agency instructions.	See Sponsor specific instructions below
Do NOT include start-up funding from UD.
Do NOT include consulting agreements that involve non-research consulting activities.
Do NOT include NIH proposals or projects for which the individual is an Other Significant Contributor.
Do NOT include UD endowed professorships.
Do NOT include fee-for-service agreements.
Do NOT include training awards, prizes, or gifts.

FEDERAL AGENCY GUIDANCE
What follows are examples of Federal sponsor-specific guidance on what they request in their Other Support documents. This guidance is subject to change, so PIs and Departmental personnel are encouraged to consult sponsor instructions directly. 

National Institutes of Health (NIH)
NIH defines Other Support as “Includes all resources made available to researcher or senior key personnel 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. Other support does not include training awards, prizes, start-up support from the US based institution, or gifts. (note: Gifts are resources provided where there is no expectation of anything (e.g., time, services, specific research activities, money, etc.) in return)”.
Source: https://grants.nih.gov/grants/policy/nihgps/H,TML5/section_1/1.2_definition_of_terms.htm

WHO and WHEN
At Just-in-Time (JIT), all individuals included in the grant application as senior/key personnel MUST submit Other Support documents/information, except:

• Other Significant Contributors
• Program Directors, training faculty and others involved in the oversight of training grants

For Research Performance Progress Reports (RPPR) all senior/key personnel who have had a change in active Other Support MUST submit Other Support information, except:

• Other Significant Contributors
• Consultants
• Program Directors, training faculty and others involved in the oversight of training grants

HOW to disclose

• The Other Support Format MUST be used for applications and RPPRs. The Other Support form includes the REQUIRED certification by each PD/PI or other senior/key personnel that the statements it contains are “true, complete, and accurate.” Electronic signature is required for this certification; neither a typed name nor a scanned wet-ink signature is acceptable. DocuSign and Adobe Pro are acceptable alternatives.
• Supporting documentation, which includes copies of contracts/agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. If the contracts/agreements are not in English, recipients must provide translated copies.
• Immediate notification of undisclosed Other Support. When a recipient organization discovers that a PI or other Senior/Key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the recipient must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known. 

Additional Resources

• Other Support | Grants & Funding

National Science Foundation (NSF)
The National Science Foundation (NSF) expects that Senior/Key Personnel will list any activity that provides funding to their work and/or a commitment of time by the individual using the Current and Pending section of proposals. NSF also requires that PIs submit information about Collaborators and Other Affiliations (COA) for senior project personnel. This information is in addition to Current and Pending Support, and may include advisor/advisee relationships, coauthors, editorships, business or family relationships that are relevant to peer review.

WHO and WHEN

• At proposal, all Senior/Key Personnel listed on the proposal MUST submit Current & Pending Support, Biosketch, and Collaborators & Other Affiliations documents.
• If an Authorized Organizational Representative discovers that a disclosure should have been made at time of proposal submission, but was not, they have 30 days to submit a post-award request to NSF.
• When submitting annual and final project reports, PIs and Co-PIs MUST specify whether new active other support has been received. If yes, they MUST attach updated Current & Pending Support document(s).

HOW to disclose:

• NSF requires information on all current and pending support for ongoing projects and proposals. Detailed information about the content is available in the Proposal and Award Policies and Procedures Guide (PAPPG), Chapter II.D.2.h.ii.. 
• SciENcv: Science Experts Network Curriculum Vitae – SciENcv: Science Experts Network Curriculum Vitae is an NSF-approved format for use in preparation of the current and pending support section of an NSF proposal. SciENcv will produce NSF-compliant PDF versions of the current & pending support format.
• Record information for active and pending projects, including the subject proposal.

Additional Resources

• Proposal and Award Policies and Procedures Guide (PAPPG) 24-1 
• Documents Required for Senior Personnel 
• Pre- and Post-Award Disclosures Relating to the Biographical Sketch and Current & Pending Support.

United States Department of Agriculture (USDA)

WHO and WHEN:
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.

At proposal, by uploading an attachment (see Additional Resources below for the recommended template) to the R&R Senior/Key Person Profile (Expanded)

WHAT and HOW to disclose:

• Record information for active and pending projects, including the subject 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.
• Please check the program solicitation for specific requirements.

Additional Resources

• USDA National Institute of Food and Agriculture (NIFA) Current and Pending Support Form.doc
• USDA NIFA Grants Application Guide
• USDA NIFA Federal Assistance Policy Guide.pdf

National Aeronautics and Space Administration (NASA):
Current and pending (other) support information is used to assess the capacity of senior/key personnel to carry out proposed award activities and helps NASA assess any potential scientific and budgetary overlap or duplication, as well as conflicts of commitment, with the proposed project. Each senior/key person listed on a NASA grant or cooperative agreement proposal is required to submit current and pending support disclosures with their application.

WHO and WHEN

NASA designates as a senior/key person all Principal Investigators (PIs), all co-Principal Investigators (CoPIs), and co-Investigators (Co-Is) proposing to spend 10 percent or more of their time in any given year on a NASA-funded grant or cooperative agreement. Refer to Notice of Funding Opportunity (NOFO) if any other personnel categories are designated as Senior/Key Personnel. Proposals do not need to include the current proposal on the list of pending proposals unless it has been submitted in response to another funding opportunity (i.e., NASA or another sponsor).

At proposal, included in the submission packet.

WHAT and HOW

NASA has provided a table of Pre-Award and Post-Award Disclosure Requirements

• PIs and Co-PIs also shall list any current and pending support with China, including Chinese universities and other similar institutions or a Chinese-owned company at the prime recipient level and at all subrecipient levels, whether the bilateral involvement is funded or performed under a no-exchange of funds arrangement. (NASA Proposer’s Guide, 2.16)

Additional Resources

• NASA current-and-pending-support-cps-form.docx
• NASA Pre-Award and Post-Award Disclosure Requirements.
• NASA Grant and Cooperative Agreement Manual

Department of Energy (DOE)
Current and pending support is intended to allow the identification of potential duplication, overcommitment, potential conflicts of interest or commitment, and all other sources of support. All senior/key personnel at the recipient and subrecipient level must provide a list of all sponsored activities, awards, and appointments, whether paid or unpaid; provided as a gift with terms or conditions or provided as a gift without terms or conditions; full-time, part-time, or voluntary; faculty, visiting, adjunct, or honorary; cash or in-kind; foreign or domestic; governmental or private-sector; directly supporting the individual’s research or indirectly supporting the individual by supporting students, research staff, space, equipment, or other research expenses. All senior/key personnel involved in the project must disclose all other foreign or domestic government or non-profit support of the work to be done under the award. All involvement with foreign government-sponsored talent recruitment programs must be identified in current and pending support.

WHO:

All Senior/key personnel.  DOE defines Senior/key personnel as: “An individual who contributes in a substantive, meaningful way to the scientific development or execution of a Research, Development and Demonstration (RD&D) project proposed to be carried out with a DOE award.” DOE clarifies that typically these individuals have a doctoral or other professional degree, although individuals with other levels of education/experience may be considered Senior/key if their involvement meets the above DOE definition.

Other covered individuals.  At the award negotiation stage or during the performance of an award, DOE may designate project personnel as Senior/key and require their Current and Pending Support form.  This could include consultants, postdocs, graduate students, etc.

WHEN to disclose:

• Proposal stage: Follow the instructions provided in the Funding Opportunity Announcement for your proposal submission.
• Award stage:
  • Adding new Senior/key personnel – If there are changes or additions to Senior/key personnel for the project, the new person MUST submit a Current and Pending Support form within 30 days of joining the project team, or on a timeline provided by the program office.
  • Changes to previously submitted Current and Pending Support – Changes to a previously submitted Current and Pending Support form MUST be submitted within 30 days of the change, or on a timeline provided by the program office.

HOW to disclose:

• DOE uses NSF’s Current and Pending Support format, which can be completed through SciENcv, or the PDF template
• Please check the program solicitation for specific requirements.

Department of Defense (DOD)

Provide support information for the PI and all senior/key personnel, including other individuals who will contribute to the scientific development or execution of the proposed research project in a substantive, meaningful way, independent of whether they request salaries or compensation. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation. Include the total or estimated dollar amount for research, resource, or other project support.

WHO:

Required for all key personnel at the proposal stage.
Outside of DoD CDMRP solicitations, individual DoD funding opportunity announcements (FOAs)/solicitations have varied disclosure requirements. always review carefully and follow the disclosure guidance in the specific DoD solicitation to which you/your investigator is applying.

HOW to disclose:

This information shall be included in the Senior Key Person Profile form included in the Notice of Funding Opportunity (NOFO) and will not be included in the overall proposal page limits.

Please check the program solicitation. However, CDMRP general instructions can be found under IV.B.d. of the General Application Instructions 901.pdf