I hope you are enjoying your summer. Because we did not hold a July Research Administration Forum (RAF) and I will be on annual leave during the August RAF, I wanted to share some sponsor updates that may be of interest. I look forward to seeing you at the September RAF.
NASA
SciENcv Required for Common Forms Beginning September 1, 2026
NASA recently announced that Biographical Sketch and Current & Pending (Other) Support disclosures for grant and cooperative agreement proposals must be generated and certified in SciENcv for all submissions due on or after September 1, 2026.
- SciENcv-generated forms will be required beginning September 1, 2026; NASA will no longer accept forms prepared outside SciENcv after that date.
- The new forms include an individual certification confirming completion of the Research Security Training (RST) prior to proposal submission. More information on NASA’s RST is available here.
- During the transition period (June 25-August 31, 2026), investigators may use either:
- The fillable Word forms available on NASA’s Grant Operations Management (GOM) website, or
- SciENcv-generated forms.
If you work with NASA funded researchers, we recommend notifying them of the upcoming requirement and encouraging them to establish and review their SciENcv profiles before September 1 to avoid proposal submission delays.
NSF
Research Security Update: Prohibited Collaborations with Restricted Entities
NSF recently announced a forthcoming policy that will:
- Prohibit the use of NSF funds for research collaborations with entities appearing on specified U.S. government restricted-party lists, and
- Prohibit senior/key personnel on NSF awards from collaborating with, holding appointments at, or receiving research support from these restricted entities.
Senior/key personnel will be required to certify compliance at proposal submission. We expect NSF to issue a final policy guidance and implementation instructions prior to October 1, 2026.
NSF-funded researchers should expect continued scrutiny of research relationships. As NSF’s research security framework evolves, information disclosed in the Biographical Sketch, Current & Pending (Other) Support, and Collaborators and Other Affiliations (COA) Disclosure Table may be reviewed as part of broader research security, compliance, and risk assessment activities.
In the coming weeks, UCLA Export Control will provide instructions for accessing a tool that enables researchers and departments to search U.S. government restricted-party lists. This resource will help departments evaluate whether current or proposed collaborations, appointments, affiliations, or external research support could be affected by NSF’s forthcoming policy.
NIH
Foreign Components Remain an Area of Increased Scrutiny
NIH continues to emphasize the importance of identifying and properly disclosing foreign components. NIH defines a foreign component as the performance of any significant scientific element or segment of a project outside the United States, whether conducted by the recipient organization or by a researcher employed by a foreign organization, regardless of whether NIH funds are used.
Key points:
- Foreign components require NIH prior approval.
- NIH has recently emphasized that international collaborations resulting in co-authorship will likely constitute a foreign component.
- While some situations are straightforward, others may require case-by-case assessment, particularly when a collaborator’s contribution appears limited or peripheral.
When there is uncertainty about whether a planned activity constitutes a foreign component, investigators are encouraged to consult their NIH Program Officer as early as possible. If prior approval is needed, departments should work with OCGA to submit the request before the activity begins.
Delinquent Final Technical Reports: All Federal Sponsors
Federal sponsors continue to emphasize the timely submission of final technical reports and other closeout deliverables. Delinquent reports can have significant institutional consequences, including delayed award closeouts, reputational risk with sponsors and, in some cases, sponsors withholding funding.
Timely report submission is critical to:
- Maintaining compliance with sponsor requirements.
- Avoiding funding delays and administrative restrictions.
- Reducing the substantial follow-up effort required by central offices to obtain overdue reports.
We appreciate the important role you play in monitoring reporting requirements and helping investigators submit final technical reports by sponsor deadlines. Your partnership in this effort is greatly appreciated.
Please share this information and let me know if you have any questions.