The letter, jointly submitted by COGR, AAU, and APLU, provides formal feedback to the National Science Foundation (NSF) on proposed revisions to the Common Disclosure Forms for biographical sketches and current and pending (other) support, used in research application submissions. The organizations commend the NSF and relevant agencies for their responsiveness to prior community input, especially regarding improved clarity, harmonized definitions, and revised reporting thresholds. The associations emphasize their support for transparency and research security while underscoring the continued need for clear, concise, and practical guidance to facilitate consistent compliance across institutions.
However, the letter identifies several "fatal flaws" in the current draft forms that, if unaddressed, may hinder effective reporting and introduce confusion or audit risk. The main concerns center on inconsistencies and ambiguities relating to in-kind contributions, the definition and disclosure criteria for malign foreign talent recruitment programs, consulting activity reporting, and the use of "devoted" versus "committed" person-months in effort reporting. Additional clarifications are requested regarding startup disclosures and the reporting timeframe for professional appointments. The groups advocate for standardized, transparent modification processes and the development of further FAQs and guidance to support institutional compliance and training. Overall, the organizations stress the importance of clarity and consistency to uphold research integrity without imposing undue burden, and they express appreciation for ongoing dialogue and opportunities to contribute to federal research policy development.
