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Other / Current & Pending Support

Northwestern Guidance

In recent years, Federal agencies have increased their focus on — and updated their requirements for — disclosing affiliations, financial support, and other resources available to university researchers who are applying for Federal funds due to increased attention to foreign influence and research security risks.

Federal sponsors focus on ensuring there is no budgetary, scientific, or commitment-related overlap by monitoring:

  • An investigator’s collaborations, especially those involving foreign partners
  • Total effort to confirm an investigator is not over-committed
  • Existing funding and resources for the project being proposed from alternate sources

The primary method of providing this information is through the submission of Other Support (also called Current and Pending Support) documents. These are typically included as part of an application or submitted just prior to an award. However, this information can also be conveyed through other documents such as the biographical sketch, facilities/other resources description, lists of collaborators and other affiliations, etc. Progress reports are also another important opportunity for disclosures.

This page provides an overview of some of the standard Other Support disclosure requirements. However, as these change frequently and can vary from sponsor to sponsor,  always check for the most current sponsor guidance.

What must be disclosed as Other Support?

Other Support is defined as ALL resources made available to an investigator in support of or related to their research endeavors, whether or not they have monetary value. This includes all active awards, pending proposals, and in-kind contributions.

Consistent with Federal agency expectations and requirements, Northwestern University requires investigators to disclose all resources, financial, and in-kind support provided by both domestic and foreign entities, other than those provided by Northwestern. These may include, but are not limited to:

  • Support for lab personnel, including visiting scholars
  • Contributions of lab space, equipment, or supplies, whether at Northwestern or elsewhere
  • Consulting fees or travel paid to perform research
  • Participation in foreign government sponsored talent recruitment programs

Other Support does not include training awards, prizes, or unrestricted gifts for which the sponsor has imposed no reporting requirements or other expectation of anything in return. It also excludes Northwestern-provided resources such as core facilities or start-up funding. Activities that are considered non-research may also be excluded. However, it may be appropriate to disclose some gifts, awards, or prizes, especially those from a foreign country, as there may be foreign influence and research security considerations. For awards, prizes, or unrestricted gifts from OFAC sanctioned countries and military end use countries, coordinate review with the Export Controls & International Compliance team to determine if they should be listed on your Other Support.

In addition, all activities that require a quantifiable commitment of time must be reported. Commitments are regular obligations of time — meaning they are part of an investigator’s regular activities — and may include but are not limited to:

  • Outside activities and collaborations such as consulting if related to research
  • Research activity occurring in the summer for faculty on academic year appointments, paid or unpaid
  • Effort that is provided as part of a cost-share commitment

Teaching does not need to be reported as a commitment. In addition, effort does not need to be disclosed if:

  • It is related to a short-term obligation, such as attending an advisory meeting or making a presentation at a conference
  • It is for faculty serving as a mentor for a fellowship
  • It is under an award resulting from an internally funded competition, unless measurable effort is required
  • Projects such as equipment, conference grants, or clinical trials may not have any measurable effort to disclose but should be evaluated on a case-by-case basis and included whenever needed to ensure transparency.

If you’re unsure about including something, we recommend erring on the side of disclosing it; it is better to be fully transparent rather than leave something out.

When and how is Other Support disclosed?

 

Some sponsors require the inclusion of Other Support documents with the initial proposal, whereas others may only request it if a project is recommended for funding. If the project is funded, these disclosures become an ongoing obligation throughout the project period. In some cases, a sponsor’s award terms may require updated disclosures whenever support may change.

In general, Other Support documentation is provided at proposal stage, as part of Just in Time updates, and through annual technical reports. See the agency-specific resources below for more information.

Failure to disclose Other Support accurately can result in: (1) Delayed or denied funding; (2) Potential civil and criminal enforcement actions against the researcher and institution; and (3) Reputational harm to researchers and institutions. Transparent disclosures are critical in protecting the integrity of Northwestern’s research and ensure both individual and institutional compliance with Federal regulations.

If at any point you believe there was an error or oversight in an Other Support submission, please contact Sponsored Research immediately, as we have an obligation to provide updates to the sponsor.

Who must disclose Other Support?

Who must disclose depends on the specific sponsor and solicitation. In most cases, disclosure of Other Support is limited to the Principal Investigator and others identified as senior/key personnel. However, some sponsors such as the Department of Energy may have an expanded definition of key personnel, which may also include graduate students and postdocs. Non-key personnel including Other Significant Contributors, consultants, or training faculty typically do not have to provide Other Support documents, unless otherwise indicated by the sponsor.

Where Northwestern serves as the lead proposer, it is also responsible for ensuring that the required disclosures are provided for all subrecipients.

Roles and Responsibilities

Sponsored Research, in its capacity as Authorized Organizational Representative, is charged with submitting Other Support documents to sponsors. However, the preparation and maintenance of Other Support documents is the responsibility of individual faculty members with assistance from their departmental research administrators.

Only the investigator has access to all the information that is needed for a full and complete disclosure, particularly as it relates to in-kind support or other resources provided that are not captured in Northwestern’s systems. Therefore, faculty must be actively involved in the preparation of their Other Support documents for each proposal submission or JIT and monitor them carefully throughout the life of an award to ensure they remain current and compliant. The investigator’s signature on each disclosure certifies that these disclosures are true, complete, and accurate to the best of their knowledge. Sponsors carefully monitor these responses, so faculty must remember that false, fictitious, or fraudulent statements or claims (including intentional omissions) may result in administrative, civil, or even criminal penalties for them as individuals and/or the University.

In addition to Other Support documents, “covered personnel” — PIs and senior or key personnel — are required to complete Research Security training which covers disclosures and proper use of funds.

Format and Signature

Some, but not all, Federal sponsors use what are called the “Common Forms” for biosketches and Other Support. NSF, for example, already uses SciENcv and NIH has also announced their intent to use this format beginning in January 2026. However, it is important to carefully review each solicitation to determine what is required. For example, some sponsors require only active and pending support, but others may require disclosure of previous sources of support for a certain period.

Most sponsors also require that documents are signed or certified. JPEG signatures are not considered compliant; investigators should use only DocuSign or Adobe-verified signatures with a digital ID. Note: using the signature functionality built into Adobe Acrobat Pro (“Fill & Sign”) is not an acceptable option. This methodology is not the same as digitally signing and certifying with Adobe and does not yield an Adobe-verified signature.

For subaward institutions, Northwestern will defer to the determinations made by those organizations regarding compliant signatures.

Effort Reporting

With support from their department research administration teams, investigators should monitor effort as it is entered into CERES as this provides the basis for all internal reporting and tracking.

At proposal stage

“Committed effort” is an initial estimate of the time a person will spend on a specific sponsored project. This is captured in the budget module of the CERES funding proposal record. It is typically conveyed in the form of person months, e.g. 10% of a 12-month appointment would result in 1.2 calendar months of committed effort.

Northwestern’s effort reporting policy requires that faculty commit some level of effort (>0%) for proposals on which they are listed as principal investigator (PI) or key personnel. There are a few exceptions, which include equipment and instrumentation grants, doctoral dissertation grants, student augmentation grants, and institutional/individual training grants (for faculty mentors). Projects such as industry clinical trials and conferences may also be exempt, depending on the school or unit’s specific policy.

At award stage

When preparing Just In Time documents, departments should clearly describe the impact of any budget revisions on the committed effort and ensure that when the award is set up, it reflects the final, sponsor-approved effort. [Note: sponsors including NIH who may unilaterally reduce an award will still consider the originally proposed effort as the approved effort.]

Post-Award

During the life of an award, the committed effort may change. Particularly with regards to effort reductions of key personnel, it is important to carefully review the Notice of Award and other policy guides to determine whether or not sponsor approval is needed. Not every incremental change is required to be captured in CERES; however, should multiple small changes exceed the sponsor’s allowed threshold, the department must route an Award Modification Request to capture the request to and approval of the sponsor.

Cognos Reports

Committed effort can be monitored using the GA401–Current Awards and GA401–Pending Proposals reports in Cognos. Note: if you identify errors in these reports, please alert the Specialist identified on the CERES award record for assistance. Sponsored Research does not recommend using shadow systems to manage effort; the data entered into CERES should provide the basis for all reviews and reports.

Certified Effort

The actual effort charged to an award is called the “certified effort”. It is important that this is accurately monitored to ensure any reductions are in alignment with sponsor policies. Under no circumstances can an individual be paid more than the equivalent of 12 person months during a given budget period. Since effort certification may be done by staff members who are not actively involved in award management, it is important to communicate all sponsor requirements to ensure compliance. Reference the ASRSP website for additional information about the effort reporting system and related policies.

Best Practices

As an investigator may update Other Support documents throughout the year, the following recommendations can help departments maintain accuracy and compliance of Other Support documents:

  1. Certain sponsors or projects may require a minimum level of effort which cannot be reduced under any circumstances. Northwestern’s systems will not flag this; it is the PI and department’s responsibility to read each solicitation and NOA carefully.
  2. If it appears that effort may exceed 12 CM in a single year, PIs must provide a detailed statement indicating how effort will be managed to avoid overcommitment. Departments should help review these statements to ensure the proposed reductions will not require prior approval by the sponsor.
  3. Be cautious if making minor incremental changes; even if they do not initially require sponsor approval, if the cumulative reduction would exceed the sponsor’s allowable threshold, an Award Modification Request is required.
  4. Other Support documents should always be current — within 30 days of the date they are to be submitted. The date should be clearly visible so that if revisions are needed, it is easy to determine which document prevails.
  5. All foreign talent recruitment programs must be disclosed. Investigators cannot participate in a Federal proposal or award if they are a member of a malign foreign talent recruitment program. Contact the ECIC team if you are unsure if proposed activity or activity may be considered “malign.”
  6. Maintain supporting documentation; sponsors may require copies of contracts/agreements specific to foreign appointments and/or employment with a foreign institution as part of Other Support.
  7. For NIH submissions, ensure that all effort is captured in the tables with the appropriate calendar year. (When effort spans two calendar years, NIH instructs that the table list the latter year.) Do the math to ensure there are not more than 12 calendar months active or proposed for any given year. NIH is very vigilant and will require clarification if they identify potential overcommitment.
  8. For NIH submissions, ensure that the overlap statement adequately addresses all three types of overlap: budgetary, scientific, and commitment.
  9. For projects in a no-cost extension, remember that effort reductions during that time do not generally require prior approval, but the investigator still must report some measurable effort.
  10. Be sure to remove outdated proposals or expired awards unless this is specifically requested by sponsor.

Northwestern Resources

Multiple offices are involved in ensuring compliance and can assist investigators in understanding the evolving Federal requirements:

Federal Agency Guidance

NIH

NSF

Department of Defense (DOD)

Instructions and forms are available in the specific solicitation and applicable version of the Application Instructions in eBRAP. Visit Funding Opportunities and Forms and click on the relevant funding opportunity.

Additional guidance:

Note: Based on their review of Other Support, the Department of Defense may determine that a Risk Mitigation Plan is required. Please consult with Export Control and International Compliance prior to responding. 

Department of Energy (DOE)

DOE generally requires the use of the format approved by the National Science Foundation (NSF), which may be generated via SciENcv.

Note: requirements may vary between DOE offices; be sure to check the program solicitation.

SciENcv

Science Experts Network Curriculum Vitae (SciENcv) supports the preparation of biosketches and Other Support documents for Federal proposals and reports. It is intended to reduce the administrative burden of creating and maintaining these forms, by integrating with information contained in eRA Commons, NCBI My Bibliography, Research.gov, and ORCID.

Use of SciENcv has been required by the National Science Foundation since 2023; the Department of Energy Office of Science also requires use of the NSF-approved biosketch format.

For NIH, a transition to SciENcv was originally scheduled for May 2025 but is now anticipated in early 2026. Northwestern proposers should continue to use the current NIH-specified forms until the implementation is confirmed.

Other agencies that currently use or plan to implement use of SciENcv shortly include USDA and the Department of Energy (for Other Support.)

Faculty may allow delegate access to SciENcv for research administrators to help view and manage their documents; however, only PIs can certify their information.

For additional information, see: https://libguides.galter.northwestern.edu/SciENcv