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The NIH has intensified scrutiny of international research partnerships, particularly in regard to foreign talent recruitment programs, undisclosed financial support, and data/material sharing with foreign entities. To remain compliant:

• Disclose All Foreign Relationships: Ensure that all affiliations, in-kind contributions (e.g., data access, lab space), and financial relationships with foreign institutions or individuals are fully disclosed in your Other Support and Biosketch documents.
• Do Not Include Foreign Subcontractors on outgoing proposals: NIH will no longer issue awards to domestic or foreign entities that include subawards to foreign entities. NIH is implementing a new method for directly funding foreign collaborators, expected to be in place by September 30, 2025. See Guide Notice NOT-OD-25-104 for details.
• Avoid Informal or Unfunded Foreign Collaborations: These may be viewed with suspicion if not disclosed or if they involve technology transfer or publication agreements.
• Use MOUs and MTAs: Formalize collaborations with Memoranda of Understanding (MOUs) or Material Transfer Agreements (MTAs) vetted by the Office of Sponsored Programs to clearly define roles and responsibilities.
• Coordinate with the Office of Sponsored Programs and the Office of Compliance: Before initiating or continuing work with a foreign collaborator—especially in sensitive fields or with institutions in countries of concern—please consult the Office of Compliance for review.

As of August 15, 2025, the OSP Proposal Approval Form (PAF) replaces the OSP Internal Routing and Review (IRR) Form as the internal document that summarizes a sponsored project proposal, including period of performance, effort commitments of key personnel, budget, cost share, related certifications, and other pertinent information. The PAF is due on or before the proposal submission deadline. For a link to the PAF survey in Qualtrics, form instructions, and FAQs, see the Proposal Approval Form webpage.

Effective October 27, 2024, NSF implemented multifactor authentication (MFA) for Research.gov sign-in. While this step has increased the security of NSF’s IT systems, it has made the sign-in process more burdensome to users. With these new changes in place, the most direct way to sign-in to your Research.gov account is to select the option for “Sign In Using Organization Credentials,” using either Google Chrome or Microsoft Edge browsers. The option to sign-in to Research.gov using “Organization Credentials” will appear as the middle sign-in option on your screen. To sign-in, select “Syracuse University” from the drop-down list and then click “Sign In Using Organization Credentials.” For more guidance information, see NSF FAQs.

The National Science Foundation (NSF) has released a revised version of the Proposal & Award Policies & Procedures Guide (PAPPG), version 24-1, on January 22, 2024. Below are some of the most significant policy changes related to proposals submitted on or after May 20, 2024. For a complete list of the changes and for additional detail, please see the updated PAPPG (NSF 24-1). Please contact your OSP representative if you have any questions.

• Biographical Sketch – Biographical Sketch no longer has a page limitation, and implements the new Common Disclosure form, which also removes the Synergistic Activities section. The Biographical Sketch will continue to be created in SciENcv, which will produce a pdf compliant version that can be attached to the proposal in Research.gov.
• New Synergistic Activities Document – Synergistic Activities that used to be included as part of the Biographical Sketch has been moved to a separate document.  Each individual identified as senior/key personnel must include a one-page document with up to five examples that demonstrate the broader impact of the individual’s professional and scholarly activities that focus on the creation, integration, and transfer of knowledge. This document is submitted as part of the Senior/Key personnel documents in Research.gov. 
• Mentoring Plan – Mentoring Plan has been expanded, now requiring a plan for graduate students as well as postdoctoral researchers supported on a project.  The page limit for a Mentoring Plan is still one page.
• Current and Pending (Other) Support – implementing the new Common Disclosure form.  The Current and Pending Support form will continue to be created in SciENcv, which will produce a pdf compliant version that can be attached to the proposal in Research.gov.
• Foreign Organizations – updated guidance for justifying inclusion of a foreign organization (subaward) or foreign individual (consultant) in a proposal budget. The justification must be included in the project description section of the proposal and the box for “Funding of a Foreign Organization or Foreign Individual” must be checked on the Cover Sheet.
• Malign Foreign Talent Recruitment Programs – guidance provided for individuals who are a party to a Malign Foreign Talent Recruitment Program. Such individuals are not eligible to serve as a Senior/Key Person on NSF proposals and awards.  This new policy is part of NSF’s implementation of the National Security Presidential Memorandum-33 (NSPM-33). Additionally, as part of the proposal submission, Syracuse University must certify that all individuals identified as senior/key persons have been made aware of and have complied with their responsibility to certify that they are not party to a Malign Foreign Talent Recruitment Program. 
• Proposal Font, Spacing, and Margin Requirements – updated to allow for submission of proposal documents in landscape format.

• Projects Requiring Advanced Computing, Data, and Analysis Capabilities updated instructions – updated to say that many research projects require access to computational, data, analysis, and/or visualization resources to complete the work proposed. Typically, such resources will be noted in the proposal under Facilities, Equipment and Other Resources. For projects that require such resources at scales beyond what may be available locally, NSF supports an array of national resources. Proposals are reviewed for both their scientific and computational/data needs, as well as readiness to utilize the resources.
• Concept Outlines and Proposal Concept Tool (ProSPCT) – Concept Outlines are used for Planning, RAPID, EAGER and RAISE proposals.  Concept Outlines are typically submitted via email or through the ProSPCT tool.  Follow the submission guidelines included in the NSF funding opportunity.
• Tribal Nation Approval – proposals that may impact the resources of a Tribal Nation must seek and obtain approval from the Tribal Nation prior to award.

Beginning October 23, 2023, NSF will only accept applications with Biosketches and Current and Pending (Other) Support forms prepared using the SciENcv tool. Help guides are available to assist researchers with this mandatory transition to SciENcv.

It is National Science Foundation (“NSF”) policy to “foster safe and harassment-free environments wherever science is conducted.” (NSF 2023 PAPPG Guide II-E.9]. NSF’s new policy requirement states that there must be a plan for a safe and inclusive work environment created and on file at the proposal stage.  PIs are responsible for distributing the plan to each participant in advance of departure for an off-campus research activity. Off-campus or off-site research is defined by NSF for this requirement as “data/information/samples being collected off-campus or off-site, such as fieldwork or research activities on vessels and aircraft.”

Effective as of January 30, 2023, NSF grant applicants, including Syracuse University, are required to certify that we have a plan in place for a safe and inclusive work environment. The plan specifically addresses:

1. Abuse of any person, including but not limited to harassment, stalking, bullying or hazing or any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; and
2. Conduct that is unwelcome, offensive, indecent, obscene, or disorderly

The creation and distribution of the plan is the responsibility of the award PI. To ease the administrative burden, the Office of Sponsored Programs has created a Plan Template for your use.

• Page 1. of the template plan provides instructions for the PI,
• Page 2. of the plan outlines Syracuse University’s compliance with NSF’s requirement and provides links to all relevant University policies, and
• Page 3. of the plan is the project specific information PIs will prepare and share with OSP prior to proposal submission.

PIs are responsible for distributing a copy of the plan to all required participants (See Participants definition in the FAQ) in advance of departure for an off-campus research activity, as well as maintaining documentation of who received the plan. Unless specifically requested, applicants should not submit the plan to NSF for review.

For additional information and examples of the applicability of the new NSF policy, please see the FAQ, or contact your OSP Research Administrator.

New NIH Data Management and Sharing Policy Effective Jan. 25, 2023
The NIH has released new policy for data management and sharing that applies to all research, funded or conducted in whole or in part by NIH, that results in the generation of scientific data. The Syracuse University Libraries and Office of Research have developed Syracuse University guidance to aid researchers on adhering to the new policies. This guide will be updated over the next month with more resources.

The Office of Sponsored Programs has analyzed the University’s eligibility for the National Institutes for Health (NIH) Research Enhancement Awards (R15) and based on the University’s recent success with receiving consistent NIH funding, we are projected to be ineligible to submit proposals for the NIH R15 program in the next federal fiscal year, starting October 1, 2022. 

The NIH R15 Program includes the Academic Research Enhancement Award (AREA) for Undergraduate-Focused Institutions, and the Research Enhancement Award Program (REAP) for Health Professional Schools and Graduate Schools.

This eligibility determination is contingent on receipt of at least $6 million in select NIH funding for October 1, 2021 to September 30, 2022. For the past two fiscal years, we have exceeded $9 million in such funding and thus fully expect to exceed $6 million in the current fiscal year. The analysis of our eligibility has been conducted using NIH public resources and confirmed by NIH program officers.

FAQs for R15 Eligibility, based on NIH provided clarifications:

1. I’ve already submitted my R15 proposal. Will I be denied an award if it comes after October 1, 2022?
   • No, the eligibility is only for proposal submissions. Awards may come after this deadline.
2. Will this prevent no-cost extension of current R15 awards?
   • No, current awards will remain in effect and extensions are allowable.
3. Will this prevent renewals of current R15 awards?
   • Yes, the R15 eligibility will cover new and renewal applications. Renewals of current R15 awards will not be allowed.
4. Can we apply in September 2022 for an October 2022 deadline? The submission will come while we are still eligible although the deadline will come after our eligibility expires.
   • To the best of our knowledge and interpretation of NIH guidance, our understanding is that Syracuse University remains eligible to apply in September 2022 for an October 2022 deadline. PIs should verify this information with a Program Officer from the Institute or Center to which they are applying.

If you have further questions, please direct questions to Stuart Taub, Director, Office of Sponsored programs at staub@syr.edu.

Federal agency guidance on current and pending (C&P) support is changing:

• NSF – further updated their current and pending support requirements for proposals submitted on or due, and awards made, on or after October 4, 2021.
• NIH – changes impact applications, Just-in-Time submissions, and Research Performance Progress Reports with due dates on or after January 25, 2022.
• Other Federal Agencies – Specific requirements for other agencies may differ. Check the program solicitation for requirements.

Current and Pending Support, also known as Other Support, is a form typically used by federal sponsors to request information for the PI(s) and Key Personnel’s current and pending research projects. Most federal agencies require Current & Pending Support documents to be submitted:

• • with the proposal or
  • just before an award is issued, and
  • if awarded, they may require any changes to be disclosed in progress reports.

When required, please remember to include ALL support including grants, and contracts from all non-U.S. and domestic sources, including internal Syracuse University project support (e.g., CUSE Grants). The format of this requirement varies by sponsor. It is the responsibility of the Investigator/Key Personnel to make sure that all research projects and affiliations are fully disclosed and that the document is completed in its entirety.

Recently the Federal Government has been placing additional scrutiny on foreign influence and the impact to federal research.  Please see the Foreign Influence in University Research page on the Office of Research website for additional guidance applicable to Syracuse University researchers. These government concerns around foreign influence have resulted in some federal agencies providing additional guidance on what needs to be included in Current and Pending/Other Support documents.  Guidance for the specific agencies can be found on the Other Support/Current & Pending Support  page of the Office of Sponsored Programs website.  This information will be updated as we learn of new requirements from federal agencies. If you have any questions related to Current and Pending Support being reported at the proposal or just-in-time stage or to report changes to Current and Pending Support at the award stage, please contact your OSP Research Administrator.

Reminders of NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components:

The intent of this notice is to remind the extramural community about the need to report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-19-114.html