SUPPORTING STATEMENT – PART A
National Science Foundation
Common Disclosure Forms for the Biographical Sketch and Current and Pending (Other) Support
OMB Control No. 3145-NEW
Section 4(b) of National Security Presidential Memorandum-33 (NSPM-33) directs that “research funding agencies shall require the disclosure of information related to potential conflicts of interest and commitment from participants in the Federally funded R&D enterprise… The appropriate disclosure requirement varies depending on the individual’s role in the United States R&D enterprise.” Section 4(b)(vi) directs that “agencies should standardize forms for initial disclosures as well as annual updates, … and should provide clear instructions to accompany these forms and to minimize any associated administrative burden.”
These common disclosure forms are intended to clarify what is expected of senior personnel applying for R&D funding from Federal research funding agencies. Variations among Federal research funding agencies will be limited to cases: (a) where required by statute or regulation; (b) where more stringent protections are necessary for protection of R&D that is classified, export-controlled, or otherwise legally protected; or (c) for other compelling reasons consistent with individual agency authorities and as coordinated through the NSTC.
Agencies may develop agency- or program-specific data elements and instructions, if necessary, to meet programmatic requirements, although agencies will be instructed to minimize the degree to which they supplement the common forms. Modification and/or supplementation of these common disclosure forms will require clearance by OMB/OIRA under the Paperwork Reduction Act (PRA) process.
The NSTC Research Security Subcommittee has worked to develop harmonized disclosure requirements for use by senior/key persons, as well as to develop proposed common disclosure forms for the Biographical Sketch and Current and Pending (Other) Support sections of an application for Federal research and development (R&D) grants or cooperative agreements. The purpose of the Biographical Sketch is to assess how well qualified the individual, team, or organization is to conduct the proposed activities. The purpose of Current and Pending (Other) Support is to assess the capacity of the individual to carry out the research as proposed and to help identify any potential scientific and budgetary overlap/duplication, as well as overcommitment with the project being proposed. These common disclosure forms are intended to replace forms/formats currently used by agencies for these sections of applications, thereby increasing the consistency of disclosure forms and reducing administrative burden.
As stated in the NSPM-33 Implementation Guidance, “the goal of these common forms and accompanying instructions is to ensure that applying for awards from any Federal research funding agency will require disclosing the same information in the same manner, to increase clarity and reduce administrative burden on the research community. In some cases, research agencies may adapt the forms and instructions, where required by their legal authorities. Such common forms also will allow the research community to identify and point out where greater clarity may be needed.”
For purposes of NSF, these common disclosure forms must be used by senior/key persons to develop their biographical sketch and current and pending (other) support in SciENcv and included in the application submitted to the Foundation. The application must be submitted either through use of Research.gov (NSF’s main proposal submission vehicle), or Grants.gov, which has its own OMB clearance under 4040-0002. Other Federal research funding agencies may utilize different electronic systems for use in development of the application which will be cleared separately by OMB/OIRA under the PRA process.
Efforts to Identify Duplication
Given that these are Common Forms, there will be no duplication.
This collection will not have a significant impact on a substantial number of small businesses.
Not applicable.
This information collection will be conducted in a manner consistent with the general information guidelines.
As required by 5 CFR 1320.8(d), comments on the information collection activities were solicited through the publication of a 60-Day Notice in the Federal Register at 87 FR 53505. NSF received 100 discrete comments in response to the 60-day Notice. Commenters included individuals, professional societies, institutions of high education, and federal agencies. Responses to each of the comments submitted can be found in the attached Comment Table. Additionally, NSF and other U.S. Government representatives consulted with several stakeholders through meetings, conferences, and presentations to receive input. These stakeholders included university professional associations as well as faculty associations and bodies of the Nationals Academies of Science, Engineering, and Mathematics. The National Science and Technology Council’s Subcommittee on Research Security also held several virtual listening sessions to receive feedback.
Not applicable.
The information from these forms will be covered by NSF’s Privacy Act System of Records, in particular, NSF-50, “Principal Investigator/Proposal File and Associated Records.”
No sensitive questions are asked as part of this information collection. Senior/key persons are advised not to submit any personal information. This includes items such as: home address; home telephone, fax, or cell phone numbers; home e-mail address; driver’s license number; marital status; personal hobbies; and the like. Such personal information is not appropriate and is not relevant to the merits of the proposal.
As these will be common disclosure forms, the following burden table is applicable only to NSF. The Foundation expects an annual rate of 46,500 applications per year, with an estimate of two hours for each form per applicant. On average, there are four senior/key persons per application, and the following table lays out the burden estimate per proposal.
Form Name |
Number of Proposals (estimated) |
Number of respondents (estimated) |
Burden time (hours) |
Total |
Biographical Sketch |
46,500 |
4 |
2 |
372,000 |
Current and Pending (Other) Support |
46,500 |
4 |
2 |
372,000 |
Total burden hours |
|
|
|
744,000 |
Beyond the hourly burden, there are no respondent or record keeper costs estimated for this collection.
NSF Office of Budget, Finance, and Award Management
Policy Office Head 3 months x AD-5 = $46,800
1 Senior Policy Specialist 1 month x GS-14 = $12,100
1 Policy Analyst 20 hours x GS-13 = $1,500
NSF Office of the Director
Chief of Research Security, Strategy, and Policy 1 week x SES Pay Band C = $4,000
National Institutes of Health
Director, Office of Policy for Extramural Research Administration 2 months at SES Pay Band C = $32,000
Total Salaries: $96,400
Not applicable. This is a new request for common forms.
Not applicable.
B. Collections of Information Employing Statistical Methods
Not applicable.
Attachments:
Biographical sketch Common Form and associated instructions
Current and Pending (Other) Support Common Form and associated instructions
Comment Table
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | holly002 |
| File Modified | 0000-00-00 |
| File Created | 2023-08-18 |