The memorandum, submitted jointly by several leading higher education and research associations, responds to the National Science Foundation’s request for public comment regarding the development of common disclosure forms for Biographical Sketch and Current and Pending Support within federal research applications, as mandated by NSPM-33. The associations commend federal efforts to harmonize and clarify disclosure requirements across agencies, highlighting that establishing a community-informed, unified approach offers the potential to reduce the administrative burden on institutions and faculty, improving clarity and compliance.
The document offers three key recommendations to guide finalization and ongoing management of these common forms: first, it urges federal agencies to minimize individual variations in disclosure requirements to prevent confusion and excessive compliance demands; second, it calls for a transparent, uniform process and schedule for updating forms and disclosure elements, as well as clear expectations about the frequency and responsibility for updates; third, it emphasizes the importance of consistent, clearly defined terminology—such as “consulting,” “in-kind contributions,” and “key/senior personnel”—across agencies, with supporting examples and qualifiers to facilitate researcher compliance. The associations appreciate ongoing stakeholder engagement and urge the continuation of harmonization and transparency efforts to support the integrity and international collaboration of the U.S. research enterprise.
