CASRAI Dictionary

Tag: current and pending support

  • NSPM-33 disclosure: what US researchers must report in 2026

    National Security Presidential Memorandum 33 (NSPM-33), signed in January 2021, directed US federal research funding agencies to strengthen and harmonise disclosure requirements for federally funded researchers. Five years later the implementation has stabilised across NIH, NSF, DOE, DOD, NASA, USDA, and the other major science agencies, with the CHIPS and Science Act of 2022 having added enforcement teeth and the 2024 Research Security Programs Standard Requirement having added institutional-level obligations. This post is the practical 2026 compliance map for US-funded researchers.

    The shape of NSPM-33 in 2026

    NSPM-33’s core mandate is straightforward: a federally-funded researcher must disclose all support they receive (financial, in-kind, or in the form of positions, appointments, or affiliations) so that the funding agency can identify potential conflicts of commitment, undisclosed foreign components, or scientific overlap. The disclosure is made at proposal stage and updated throughout the project’s life.

    The five years of implementation have produced two important refinements. First, the common disclosure forms: NIH’s Other Support format, NSF’s Current and Pending (Other) Support, and parallel formats at other agencies have been substantially harmonised under the NSPM-33 implementation guidance. By 2026 a researcher can largely produce one structured disclosure record (typically in SciENcv format) and have it serve all federal agencies. Second, the structured-data submission: the agencies now require disclosure forms in machine-readable format with ORCID linkage, not as free-form PDFs.

    What must be disclosed

    The 2026 disclosure scope at the major agencies covers, at a minimum:

    • All ongoing and pending research support (federal, non-federal, and foreign).
    • All in-kind support of significance (laboratory space, equipment access, personnel time).
    • All positions and appointments (professorships, visiting positions, advisory roles, board memberships) regardless of whether they are paid.
    • All consulting arrangements above a defined threshold (typically a few thousand dollars per year, but agency-specific).
    • Foreign government talent recruitment programme participation (see below).
    • Patents and patent applications related to the funded research.
    • Sponsored or paid travel above defined thresholds.
    • For NIH specifically, all support for research effort regardless of how titled.

    The Current and Pending Support form (NSF terminology) and the Other Support form (NIH terminology) are the canonical artefacts. They are populated by the researcher at the proposal stage and re-verified at the just-in-time (JIT) request stage if the proposal is funded.

    The foreign-component question

    The single most consequential 2021-2024 enforcement focus was undisclosed foreign components. A foreign component is any significant scientific element of a project performed outside the United States by any source of funding, including foreign collaborator efforts even if not separately funded.

    NIH’s foreign-component disclosure rule existed before NSPM-33 but was inconsistently enforced. Post-NSPM-33 the enforcement has been substantial: dozens of researchers had grants terminated or returned, and several criminal cases proceeded for fabricated disclosures. The 2023-2024 cohort of cases clarified the threshold: an undisclosed foreign-funded position, a foreign-government talent-recruitment-programme membership, or a substantial unreported collaboration with a foreign laboratory are all material non-disclosures with grant-termination and criminal consequences.

    In 2026 the practical rule is conservative: if you have any affiliation, position, support, or significant collaboration outside the US that overlaps in time with your federal-funded project, disclose it. The cost of over-disclosure is filling in more forms; the cost of under-disclosure has become very high.

    Foreign Talent Recruitment Programmes

    The Foreign Talent Recruitment Programme (FTRP) category was sharpened by Section 10632 of the CHIPS and Science Act of 2022, which required agencies to prohibit federally-funded researchers from participating in malign FTRPs. The 2024 implementation guidance defined a malign FTRP as one that involves transfer of intellectual property, transfer of laboratory resources, or compensation contingent on outcomes that benefit a foreign government’s national interests, among several other criteria.

    The category is narrower than the original 2018-2021 “China Initiative” framing might have suggested. Participation in a non-malign FTRP (a competitive postdoctoral programme, an academic exchange visit, an honorary professorship) is not prohibited but must be disclosed. Participation in a malign FTRP is prohibited for federally-funded researchers and must be terminated as a condition of receiving federal funding.

    The institutional-side burden under the 2024 Research Security Programs Standard Requirement is substantial: institutions over a defined funding threshold must implement a research security programme with training, conflict-of-interest screening, foreign-collaboration approval, and ongoing monitoring. The standard requirement specifies the elements; institutions implement them with their own policies.

    The reporting workflow in practice

    The 2026 workflow for a federally-funded researcher at a US institution typically looks like:

    1. SciENcv profile. Maintain a current SciENcv profile with all positions, appointments, and support. SciENcv (Science Experts Network Curriculum Vitae) is the federal-government-supported tool and produces the structured-data formats accepted by NIH, NSF, and other agencies.
    2. Proposal-stage disclosure. Export the relevant disclosure form from SciENcv at proposal preparation. Verify with the institution’s sponsored-research office before submission.
    3. JIT update. For NIH, re-verify Other Support at JIT request. Any changes since proposal submission must be reported.
    4. Award updates. Any new support, position, or appointment acquired during the award must be reported to the agency. NIH’s threshold is “significant changes”; in practice, disclose anything that would have been on the original form.
    5. Annual progress reports. RPPR and other annual reporting captures updated Other Support and current-and-pending. Treat this as a real update, not a copy-paste.
    6. Final reports and closeout. Disclosure obligations continue through closeout.

    Institutional research security programmes

    The 2024 Research Security Programs Standard Requirement obligates institutions over the $50M annual federal-research threshold to operate a research security programme covering: cybersecurity training, foreign-collaboration approval workflow, conflict-of-interest and conflict-of-commitment training, export-control compliance, and ongoing monitoring of researchers’ disclosures against external data sources.

    The institutional layer matters because most disclosure failures are not fraud; they are inadvertent omission by researchers who did not realise an affiliation was disclosable. A well-functioning research security programme acts as a backstop, with regular reminders, training, and a pre-submission review that catches omissions before they become non-disclosures of consequence.

    The CASRAI funder-mandate guide covers the agency-specific disclosure requirements with current links; the research-security domain tracks the cross-agency policy harmonisation.

    What’s still uncertain

    Three areas remain in active interpretation in 2026. First, the treatment of dual-affiliated researchers: a researcher with a tenured position at a US institution and a part-time appointment at a non-US institution must disclose both, but the threshold for the non-US appointment counting as a foreign component is fuzzy in practice. Second, the scope of the conflict-of-commitment definition: an unpaid advisory role at a foreign institution may not count as support but does count as commitment; the agencies vary in how they treat this. Third, the retroactive application: disclosure failures discovered years after the funded work was completed have been treated with substantial inconsistency, with some cases pursued criminally and others handled administratively.

    For researchers, the safe path is conservative disclosure, current SciENcv maintenance, and proactive consultation with the institution’s sponsored-research office whenever an affiliation or support is ambiguous. The compliance cost of asking is low; the cost of under-disclosure that surfaces later is potentially career-ending.

    Related dictionary entries

    References

    NSTC Joint Committee on the Research Environment, Guidance for Implementing National Security Presidential Memorandum 33 (January 2022). NIH Office of Extramural Research, Notice of Information: Updates to Other Support (NOT-OD-22-150 and subsequent updates). CHIPS and Science Act of 2022, Section 10632 (Foreign Talent Recruitment Programs). OSTP, Research Security Programs Standard Requirement (July 2024). NSF, Proposal and Award Policies and Procedures Guide (current version).