DOE's Disclosure Requirements for Current & Pending Support
Contract and Grant Lifecycle
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Overview of DOE's Current and Pending Disclosure Requirements
In January 2021, the White House issued the National Security Presidential Memorandum-33 (NSPM-33), which directed federal research agencies to require principal investigators (PIs) and other senior/key personnel to disclose appropriate information that “will enable reliable determinations of whether and where conflicts of interest and commitment exist.” Around the same time, Section 223 of the FY 2021 National Defense Authorization Act (NDAA), codified at 42 U.S.C. § 6605, was enacted, which requires all federal research agencies collect current and pending support disclosures as part of the application process.
To ensure consistent implementation of NSPM-33 and Section 223 of the FY 2021 NDAA, on January 4, 2022, the White House Office of Science and Technology Policy issued NSPM-33 implementation guidance, which addressed five key areas, including “Disclosure Requirements and Standardization.” Current and pending support is one piece of the larger category of disclosures.
Standardizing disclosure requirements is a central theme in the NSPM-33 implementation guidance, and federal research agencies are charged with developing model financial assistance application forms and instructions. While those efforts are underway, the Department of Energy (DOE) is taking this initial step to mandate all DOE and National Nuclear Security Administration (NSSA) offices incorporate consistent current and pending support disclosure requirements to harmonize the type of required information submitted to the Department as part of current and pending support disclosures.
OVERVIEW OF DOE'S CURRENT & PENDING DISCLOSURE REQUIREMENTS
The DOE issued Financial Assistance Listing (FAL) #2022-04 on June 1, 2022, directing program officers to implement new disclosure requirements for DOE and NSSA awards. Program officers will implement the provisions in new funding announcements effective immediately. The new provisions include a certification about the completeness and accuracy of current and pending support, disclosure of past support on an as-needed basis as required in new award announcements, and a reminder about the requirement to disclose participation in foreign talent recruitment programs. (Refer to FAL for specific requirements and definitions.)
FAL 2022-04 applies to all DOE and NNSA funding opportunity announcements (FOAs), financial assistance agreements (i.e., grants and cooperative agreements) resulting from those FOAs, and financial assistance agreements resulting from unsolicited proposals – that are: 1) issued on or after June 1, 2022; and 2) encompass research, development, and demonstration (RD&D) activities, or technical assistance to support RD&D activities. The current and pending support requirements may also be included in non-RD&D FOAs and awards issued on or after June 1, 2022 if determined necessary by one level above the Grants Officer. This FAL is not applicable to financial assistance agreements that exclusively fund conferences, workshops, and other technical meetings.
TWO OPTIONS FOR CREATING THE CURRENT & PENDING SUPPORT DOCUMENT
Current and Pending Support information may be provided in the format approved by the National Science Foundation (NSF) with the inclusion of the DOE certification. The use of a format required by another agency is intended to reduce the administrative burden to researchers by promoting the use of common formats. The two approved DOE formats for creating Current & Pending Support are:
- NSF SciENcv with accompanying DOE certification
- NSF-Fillable Current and Pending Support PDF (adapted with DOE certification)
DOE - Current and Pending Support using SciENcv
SciENcv - (Updated September 21, 2021) NSF partnered with the National Institutes of Health (NIH) to use SciENcv: Science Experts Network Curriculum Vitae as an NSF-approved format for use in preparation of the current and pending support section of an NSF proposal.
Department of Energy has now adopted the NSF-approved format for use in preparation of the current and pending support section of a DOE proposal. Adoption of a single, common researcher profile system for Federal grants reduces administrative burden for researchers. As such, SciENcv will produce DOE-compliant PDF versions of the current & pending support format; however, the requisite DOE Current & Pending Support Certification must also be completed (e.g., insert Name and Title, Sign, and Date).
Proposers must save these documents as a single-combined PDF and submit them as part of their proposal via CayuseProposal for submission to Grants.gov.
DOE - Current and Pending Support using Fillable PDF
The Department of Energy supports the use of NSF's fillable PDF for preparation of the current and pending support document; however, such PDF does not contain the additional certification required by the DOE. As such, UCR has taken the NSF-fillable pdf and inserted the requisite DOE certification. All PIs and other Senior/Key Personnel named in the application (and any proposed subaward level) must each complete a Current & Pending Support document. In the DOE certification section, please insert Name and Title, and include Signature and Date.
Note: Proposers should download and save the blank PDF document prior to adding content.
Both Mac and Windows users are recommended to open and fill in the blank PDF document using Adobe Acrobat Reader for an optimized experience.
The completed and saved PDF can then be uploaded via CayuseProposal for submission to Grants.gov.
Disclosure of Past Support
In addition to Current & Pending Support, DOE/NNSA program offices may also require disclosure of past support. This should be limited to a reasonable time period (e.g., previous five years), to be determined by the DOE/NNSA program office.
Disclosure of past support would prevent a scenario where a program office unknowingly funds RD&D that had already been supported, but where the prior award happened to conclude before submission of the application to the DOE Program Office. The requirement to disclose past support will be stated in the applicable funding opportunity announcement. Disclosure of past support may be unnecessary in basic and fundamental research that leads to publications and other forms of scholarly communication.