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Compliance protocols MUST be approved and linked in SeRA to a SPO project record prior to award acceptance. 

See ORA's Award Acceptance Resources for additional information.

Department of Defense (DoD)

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Current and Pending Support Disclosures

Jump To DoD Congressionally Directed Medical Research Programs (CDMRP) Guidance

In their March 20, 2019 Memo, the DoD required that as of April 20, 2019, all key personnel must submit current and pending support documentation that includes the following:

  •  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. 

This information is required for all key personnel, regardless of whether their efforts under the project are to be funded by the DoD.
 
The DoD reserves the right to request further details from a proposer.

Additionally, the William M. (MAC) Thornberry National Defense Authorization Act for Fiscal Year 2021 advises on pages 84-86 (out of 1482):

SEC. 223. DISCLOSURE OF FUNDING SOURCES IN APPLICATIONS FOR FEDERAL RESEARCH AND DEVELOPMENT AWARDS.

(a) DISCLOSURE REQUIREMENT.— Each Federal research agency shall require, as part of any application for a research and development award from such agency—

  • (1) that each covered individual listed on the application—
    • (A) disclose the amount, type, and source of all current and pending research support received by, or expected to be received by, the individual as of the time of the disclosure;
    • (B) certify that the disclosure is current, accurate, and complete; and
    • (C) agree to update such disclosure at the request of the agency prior to the award of support and at any subsequent time the agency determines appropriate during the term of the award; and
  • (2) that any entity applying for such award certify that each covered individual who is employed by the entity and listed on the application has been made aware of the requirements under paragraph (1).

(b) CONSISTENCY.—The Director of the Office of Science and Technology Policy, acting through the National Science and Technology Council and in accordance with the authority provided under section 1746(a) of the National Defense Authorization Act for Fiscal Year 2020 (Public Law 116–92; 42 U.S.C. 6601 note) shall ensure that the requirements issued by Federal research agencies under subsection (a) are consistent.

(c) ENFORCEMENT.—

  • (1) REJECTION FOR VIOLATION OF LAW OR AGENCY TERMS.—A Federal research agency may reject an application for a research and development award if the current and pending research support disclosed by an individual under subsection (a) violates Federal law or agency terms and conditions.
     
  • (2) ENFORCEMENT FOR NONCOMPLIANCE.—Subject to paragraph (3), in the event that a covered individual listed on an entity’s application for a research and development award knowingly fails to disclose information under subsection (a), a Federal research agency may take one or more of the following actions:
    • (A) Reject the application.
    • (B) Suspend or terminate a research and development award made by that agency to the individual or entity.
    • (C) Temporarily or permanently discontinue any or all funding from that agency for the individual or entity.
    • (D) Temporarily or permanently suspend or debar the individual or entity in accordance with part 180 of title 2, Code of Federal Regulations, any successor regulation, or any other appropriate law or regulation, from receiving government funding.
    • (E) Refer the failure to disclose under subsection (a) to the Inspector General of the agency concerned for further investigation or to Federal law enforcement authorities to determine whether any criminal or civil laws were violated.
    • (F) Place the individual or entity in the Federal Awardee Performance and Integrity Information System for noncompliance to alert other agencies.
    • (G) Take such other actions against the individual or entity as are authorized under applicable law or regulations.
  • (3) SPECIAL RULE FOR ENFORCEMENT AGAINST ENTITIES.— An enforcement action described in paragraph (2) may be taken against an entity only in a case in which—
    • (A) the entity did not meet the requirements of subsection (a)(2);
    • (B) the entity knew that a covered individual failed to disclose information under subsection (a)(1) and the entity did not take steps to remedy such nondisclosure before the application was submitted; or
    • (C) the head of the Federal research agency concerned determines that—
      • (i) the entity is owned, controlled, or substantially influenced by a covered individual; and
      • (ii) such individual knowingly failed to disclose information under subsection (a)(1).
  • (4) NOTICE.—A Federal research agency that intends to take action under paragraph (1) or (2) shall, as practicable and in accordance with part 180 of title 2, Code of Federal Regulations, any successor regulation, or any other appropriate law or regulation, notify each individual or entity subject to such action about the specific reason for the action, and shall provide such individuals and entities with the opportunity to, and a process by which, to contest the proposed action.
  • (5) EVIDENTIARY STANDARDS.—A Federal research agency seeking suspension or debarment under paragraph (2)(D) shall abide by the procedures and evidentiary standards set forth in part 180 of title 2, Code of Federal Regulations, any successor regulation, or any other appropriate law or regulation.
    • (d) DEFINITIONS.—In this section:
      • (1) The term ‘‘covered individual’’ means an individual who—
        • (A) contributes in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award from a Federal research agency; and
        • (B) is designated as a covered individual by the Federal research agency concerned.
      • (2) The term ‘‘current and pending research support’’—
        • (A) means all resources made available, or expected to be made available, to an individual in support of the individual’s research and development efforts, regardless of—
          • (i) whether the source of the resource is foreign or domestic;
          • (ii) whether the resource is made available through the entity applying for a research and development award or directly to the individual; or
          • (iii) whether the resource has monetary value; and
        • (B) includes in-kind contributions requiring a commitment of time and directly supporting the individual’s research and development efforts, such as the provision of office or laboratory space, equipment, supplies, employees, or students.
      • (3) The term ‘‘entity’’ means an entity that has applied for or received a research and development award from a Federal research agency.
      • (4) The term ‘‘Federal research agency’’ means any Federal agency with an annual extramural research expenditure of over $100,000,000.
      • (5) The term ‘‘research and development award’’ means support provided to an individual or entity by a Federal research agency to carry out research and development activities, which may include support in the form of a grant, contract, cooperative agreement, or other such transaction. The term does not include a grant, contract, agreement or other transaction for the procurement of goods or services to meet the administrative needs of a Federal research agency.

Program solicitations may include additional or altered requirements.  Please review DoD solicitations carefully for additional guidance.

DoD Congressionally Directed Medical Research Programs (CDMRPs)

From the General Application Instructions (version 702) for DoD CDMRPs

PI and Key Personnel Previous/Current/Pending Support 

For all previous (award period of performance ending within the past 5 years), current, and pending (includes period of time awaiting funding status and/or period of time awaiting start date) 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, 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.

Note: Other support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of monetary value and/or where they are based. This includes resource and/or financial support from all foreign and domestic entities, including but not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (biologics, chemical, model systems, technology, etc.).

New Requirement: Certification Regarding Disclosure of Funding Sources. The proposing entity must comply with Section 223(a) of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021, which requires that the PI, Partnering PIs (if applicable), and all key personnel:

  • Certify that the current and pending support provided on the application is current,accurate, and complete;
  • Agree to update such disclosure at the request of the agency prior to the award of support and at any subsequent time the agency determines appropriate during the term of the award; and
  • Have been made aware of the requirements under Section 223(a)(1) of this Act.

False, fictitious, or fraudulent statements or claims may result in criminal, civil, or administrative penalties (U.S. Code, Title 18, Section 1001).


Need further assistance? Have questions and/or feedback? Please submit questions and/or feedback here, and a member of the ORA-RMG Disclosures Team will respond to you shortly.