Federal Agency Guidance Regarding Disclosures of Other Support (Current and Pending Support) - UW-Madison Approach

Page Updated: May 14, 2021

This document contains guidance for completing Other/Current and Pending Support documents. 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. Please be sure to carefully read and follow the guidance provided by individual sponsors on how to prepare Other Support documents.

General Guidance

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.

Tip Additional Notes
Include any activity conducted within the scope of an Investigator’s UW-Madison 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 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).
  • Even if a research project does not involve a quantifiable commitment of time, if the PI/senior key personnel is spending time on the project, the project should be included.
  • Awards resulting from internally-funded competitions should be included. Examples include, WARF Fall Competition funds, SEED Research Program or Draper Technology funds, Research Service Grants, and Thompson Center awards to name a few.
Include all collaborations and affiliations that provide funding or require a commitment of time must be reported, whether foreign or domestic.
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Update information as much as possible, e.g., remove outdated proposals or expired awards, unless specifically requested by sponsor, such as NIH or DoD.
For subawards to UW-Madison, include the total amount specific to the subaward requested or received by UW-Madison.
Include clinical trials.
  • For federally-sponsored clinical trials, include the effort commitment listed in the award document.
  • For industry-sponsored clinical trials, group the clinical trials in one section. Include an aggregated effort amount for all industry-sponsored trials, as well as a general description for all trials. Each trial should then be listed individually with the sponsor, PI, dates, payments received to date, and a brief (one-sentence) description. See example
Include start-up funding provided by an organization other than UW-Madison.
Include consulting agreements where the PI or senior/key personnel will be conducting research as part of the consulting activities must be reported.
  • 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 UW-Madison appointment, but may need to be included.
  • See NIH FAQ and NSF FAQ #15.
In-kind contributions should be reported for NIH and NSF, per agency instructions.
  • NIH
    • If an in-kind contribution is not specific to the project being proposed but a resource available to the investigator, then it must be included as part of Other Support.
    • If an in-kind contribution is intended for use on the project being proposed, it should be included in the Facilities and Other Resources or Equipment section. If included in the Facilities section, it does not need to be replicated on Other Support.
    • For in-kind resources with no associated time commitment, researchers can list zero effort, but must provide the estimated dollar value of the in-kind resource. The effort and dollar value cannot both be zero.
    • Information on high-value materials (e.g., data, samples, etc.) received from collaborators must be included in the in-kind contribution section of Other Support, including the source, a summary of the in-kind contribution, and the estimated value. Only resources uniquely available to the researcher must be reported.
    • Institutional resources, such as core facilities or shared equipment that are made broadly available and will be used on the project being proposed, should not be included in Other Support, but rather listed under Facilities and Other Resources.
    • See NIH Other Support information.
  • NSF
    • If the in-kind contributions are not specific to the project/proposal but are available to the investigator and have an associated time commitment, the information must be included as part of the current and pending support section of the proposal.
    • In-kind contributions with no associated time commitment that are intended for use on the project/proposal to NSF must be included as part of the Facilities, Equipment, and Other Resources section. These contributions do not need to be replicated in the individual’s Current and Pending Support submission.
    • See NSF Current & Pending Support information.
  • UW-Madison definition of third party in-kind contributions:
    • Non-cash contributions from third parties external to the university. Instead of cash, the third party provides goods or services. This can include donated space, donated buildings or land, donated supplies, donated or loaned equipment, volunteer effort, or the paid effort of employees from an outside organization. (from UW-Madison Cost Sharing Guidelines)
For NIH Other Support documents, include an Investigator’s VA-funded activities.
Do NOT include start-up funding from UW-Madison.
Do NOT include consulting agreements that involve non-research consulting activities.
Do NOT include training awards, prizes, or gifts.
  • Gifts are resources provided where there is no expectation of anything in return. Care must be taken to ensure that funds are appropriately categorized. See Gift Funds Policy.
Do NOT include NIH proposals or projects for which the individual is an Other Significant Contributor.
Do NOT include UW-Madison endowed professorships.
Do NOT include UW-Madison retention packages.
Do NOT include fee-for-service agreements.
Do NOT include internal departmental funds, such as 101.

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 and will be revised as sponsors release new information. Because 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.

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 601, Department of Defense, Defense Health Program, Congressionally Directed Medical Research Programs:

PI Previous/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.

List all positions and scientific appointments, both domestic and foreign, held by senior/key personnel that are relevant to an application, including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).

Report all resources and other support for all individuals designated in an application as senior/key personnel–including for the PI and for other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation. Information must be provided about all current support for ongoing projects, irrespective of whether such support is provided through the applicant organization, through another domestic or foreign organization, or is directly provided to an individual who supports the senior/key personnel’s research efforts.

Report all current projects and activities that involve senior/key personnel, even if the support received is only in-kind (e.g., office/laboratory space, equipment, supplies, employees). All research resources including, but not limited to, foreign financial support, research or laboratory personnel, lab space, scientific materials, selection to a foreign “talents” or similar-type program, or other foreign or domestic support must be reported.

Provide the total award amount for the entire award period covered (including facilities and administrative costs), as well as the number of person-months (or partial person-months) per year to be devoted to the project by the senior/key personnel involved.

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/FY21-BCRP-GAI.pdf

Department of Energy (DoE) Current and Pending Support
The Department of Energy has released a memo limiting participation in foreign talent recruitment programs. DOE has released an order and FAQs to implement this memo.

From Continuation of Solicitation for the Office of Science Financial Assistance Program, posted 10/1/2020:

SECTION VIII.A.

10. How to Prepare Current and Pending Support

WARNING: These instructions have been significantly revised to require disclosure of a variety of potential conflicts of interest or commitment, including participation in foreign government-sponsored talent recruitment programs.

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. The PI and each senior/key person at the prime applicant and any proposed subaward 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 foreign government-sponsored talent recruitment programs must be identified in current and pending support. SC requires the use of the format approved by the National Science Foundation (NSF), which may be generated by the Science Experts Network Curriculum Vita (SciENcv), a cooperative venture maintained at https://www.ncbi.nlm.nih.gov/sciencv/, and is also available at https://www.nsf.gov/bfa/dias/policy/nsfapprovedformats/cps.pdf. The use of a format required by another agency is intended to reduce the administrative burden to researchers by promoting the use of common formats.

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. If the title of the award or activity is not descriptive, add a brief description of the research being performed that would identify any overlaps or synergies with the proposed research
  • 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 award period (start date –end date)
  • The person-months of effort per year being dedicated to the award or activity

Source: https://science.osti.gov/-/media/grants/pdf/foas/2021/DE-FOA-0002414.pdf

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

From NASA GUIDEBOOK FOR PROPOSERS RESPONDING TO A NASA FUNDING OPPORTUNITY, Revised as of May 2020, Effective as of June 23, 2020:

3.16 Current and Pending Support

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 a list of ongoing and pending projects and proposals (regardless of salary support) that require a significant share (more than 10%) of their time. Proposals do not need to include the current proposal on the list of pending proposals unless submitted to another funding opportunity (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 in the NOFO 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 announcement of NASA’s selections.

Current and pending support is not required for Co-Is at non-U.S. institutions. Current and pending support is usually not required for students. It may be requested, depending on the specifics of the NOFO. Proposers may request student funding in three different ways:

  • As a direct labor cost, the same as a key or other personnel.
  • As a scholarship or other student aid that must comply with the requirements in 2 CFR 200.466, Scholarships and student aid costs."
  • As a participant support cost as defined in 2 CFR 200.75.

Source: https://prod.nais.nasa.gov/pub/pub_library/srba/documents/2020_edition_Proposers_Guidebook.pdf

National Institutes of Health (NIH) Other Support RECENTLY UPDATED

NIH guidance and instructions on Other Support has evolved over the last few years. Major resources include the following:

From the NIH Grants Policy Statement, Revised October 2019:

Definition of Other Support: 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, gifts or start-up support from the US based institution.
Source: https://grants.nih.gov/grants/policy/nihgps/HTML5/section_1/1.2_definition_of_terms.htm

NIH has indicated that they review Other Support information to ensure that:

  • All resources, domestic or foreign, directly supporting the individual’s research endeavors have been reported
  • Sufficient levels of effort are committed to the project
  • There is no scientific, budgetary, or commitment overlap
  • Only funds necessary to the approved project are included in the award
  • Any foreign resources that meet the definition of a foreign component have received appropriate prior approval.

Source: https://grants.nih.gov/faqs#/other-support-and-foreign-components.htm?anchor=question56209

NIH Other Support Guidance

Other Support must be provided for all individuals identified in the application as the PI or senior/key personnel. More detailed information is available on the NIH Other Support webpage.

What to include in NIH Other Support:
  • Resources and financial support from all foreign and domestic entities that are available to the researcher in support of and/or related to their research endeavors. This includes all resources and support, whether provided through University of Wisconsin-Madison, another institution, or to the researcher directly.
  • In-kind contributions, e.g., laboratory/office space, equipment, supplies, or employees or students supported by an outside source
  • Financial support for laboratory personnel
    • For example, a student or postdoc funded by a foundation or their home university who is working on research in support of the PI or senior/key personnel’s research endeavors should be reported as an in-kind contribution on Other Support
  • Provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.)
  • Consulting agreements when PD/PI or other senior/key personnel will be conducting research as part of consulting activities
  • Start-up funds provided by sources outside UW-Madison
  • 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.
  • For a researcher working on a subproject for another UW-Madison PI, provide the project number and PD/PI name for overall project. Provide all other information, including total award amount and person months, for the subproject only.
  • For a researcher working on a subaward to UW-Madison where the NIH grant is awarded to another institution, provide the project number and PD/PI name for the prime award. Provide all other information, including total award amount and person months, for the subaward only.

Some specific examples of information that should be disclosed in NIH Other Support include, but are not limited to:

  • Other funding (e.g., salary, stipend, honoraria, etc.) paid to a University of Wisconsin-Madison researcher by an outside entity. This may include participation in a foreign talent program.
  • Financial support for laboratory personnel (e.g., students, postdocs, or scholars working in a researcher’s lab at University of Wisconsin-Madison and who are supported by a foreign entity either through salary, stipend, or receipt of living or travel expenses).
  • Provision of lab space at another institution, foreign or domestic.
  • Any agreement with a foreign university for which the University of Wisconsin-Madison faculty member directs non-UW students, postdocs, or other personnel affiliated with that university.
  • Any contractual agreement with a foreign institution or government agency.
  • Any non-University of Wisconsin-Madison agreement in which foreign funds or other resources are provided to the faculty for activities either at University of Wisconsin-Madison or at a foreign institution.
What not to include in NIH Other Support:
  • Training awards, prizes, or gifts. Care must be taken to ensure that funds are appropriately categorized. See Gift Funds Policy.
  • Start-up funds provided by UW-Madison
  • Non-research consulting activities
  • Facilities, services, or resources available for shared use and not specific to the individual investigator
NIH Other Support Requirements (effective for due dates on/after May 25, 2021) NEW!
  • The Other Support form must be signed by the PI or senior/key personnel. The signature may be a JPEG or may be achieved through a product such as DocuSign or Adobe Sign. A specific type of signature is not mandated. Once a signature has been obtained, print the document to PDF to make it into a flattened PDF.
  • Supporting documentation:
    • For foreign activities or resources, recipients must submit “copies of contracts, grants or any other agreement specific to senior/key personnel foreign appointments and/or employment with a foreign institution.” This may include:
      • Appointment letters or other documents (agreement) related to the terms and conditions of the appointment with foreign entities
      • Employment agreements with foreign entities
      • Grants and contracts received as a result of their appointment and/or employment with the foreign entity (received as an individual or through the foreign entities involved)
    • If the agreements are not in English, UW-Madison must provide translated copies. See additional information on translations.
    • All Supporting Documentation must be combined with the signed Other Support form and submitted as one Other Support PDF document.
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

NIH Frequently Asked Questions

What does NOT-OD-21-110 mean?
The notice indicates that the new Other Support format is expected to be used as of May 25, 2021, but it is not required until January 25, 2022. This means that NIH will not withdraw applications that do not follow the new format until January 25, 2022. NIH clarified that they will not require that supporting documentation be included with Other Support until January 25, 2022, but that institutions may be asked to provide this documentation to NIH prior to that date, if necessary.

Other Support documents must include disclosures of all domestic and foreign support available to a researcher, per NIH guidance. Although the new Other Support format is not required until January 25, 2022, RSP recommends that people begin using the format as soon as they are able on or after May 25, 2021. If the attestation is included, it should be signed by the PI/PD or senior/key personnel. RSP also recommends that departments begin collecting supporting documentation, in case NIH requests it.

National Science Foundation (NSF) Current and Pending Support
NOTE: The National Science Foundation released an updated Proposal and Award Policies and Procedures Guide (PAPPG) on January 24, 2020. The new PAPPG is effective on June 1, 2020. Beginning October 5, 2020 NSF will be requiring the use of an NSF-approved format to prepare Current and Pending Support, and the agency has made available a website on Current and Pending. The UW Libraries can support you if you have question on use of SciENcv to create your Current and Pending Support.

From NSF Proposal and Award Policies and Procedures Guide, January 24, 2020:

h. Current and Pending Support

Note: The requirement to use an NSF-approved format for preparation of current and pending support will go into effect for new proposals submitted or due on or after October 5, 2020. In the interim, proposers must continue to prepare this document in accordance with the guidance specified in the PAPPG (NSF 20-1). NSF, however, encourages the community to use the NSF-approved formats and provide valuable feedback as we enhance them for the October implementation.

Current and pending support information must be separately provided through use of an NSF-approved format, for each individual designated as senior personnel on the proposal. Current and pending support includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value. Current and pending support also includes in-kind contributions (such as office/laboratory space, equipment, supplies, employees, students26. In-kind contributions not intended for use on the project/proposal being proposed also must be reported27.

Current and pending support information must be provided for this project, for ongoing projects, and for any proposals currently under consideration from whatever source28, irrespective of whether such support is provided through the proposing organization or is provided directly to the individual.

The total award amount for the entire award period covered (including indirect costs) must be provided, as well as the number of person-months (or partial person-months) per year to be devoted to the project by the individual.

Concurrent submission of a proposal to other organizations will not prejudice its review by NSF, if disclosed.29 If the project (or any part of the project) now being submitted has been funded previously by a source other than NSF, information must be provided regarding the last period of funding.

Source: https://www.nsf.gov/pubs/policydocs/pappg20_1/pappg_2.jsp#IIC2h

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