NSPM-33 Implementation Guidance Disclosure Requirements Standardization Talking Points for Institutions

The document summarizes key considerations and themes regarding the implementation of standardized disclosure forms under NSPM-33, focusing on biographical sketches and current and pending (other) support (CPS) in federal research funding processes. The forms, released for public comment in August 2022, aim to harmonize and clarify researchers’ disclosure requirements across agencies, with the National Science Foundation collecting feedback. Institutions are encouraged to provide input on the necessity, utility, and administrative burden of the information required, the accuracy of burden estimates, and ways to enhance and automate the process. Critical concerns addressed include underestimation of actual time and resources needed to complete disclosures, lack of clarity in definitions and requirements—especially around in-kind contributions, consulting, and distinguishing among various appointment types—and the risk of reduced harmonization if agencies introduce unique, agency-specific requirements.

The Council on Governmental Relations (COGR) commends the progress toward uniformity but emphasizes areas needing further streamlining and clarification, such as reducing inconsistencies, clearly defining ambiguous terms, and adapting form formats to accommodate non-project-based activities. COGR highlights the varying processes and timelines for disclosures among agencies as a source of confusion and administrative inefficiency, advocating for standardized procedures and centralized guidance. The organization also urges transparent modification processes for these forms, minimal and clear certification requirements, and greater stakeholder involvement in any future changes. Overall, while the move toward standardized forms is viewed as positive, the document calls for ongoing collaboration among agencies and the research community to ensure practical, efficient, and clearly communicated disclosure expectations that minimize institutional burden and preserve compliance.