Federal Agency Other Support Requirements

Researchers: As a term and condition of entering into an arrangement with USDA related to research and development (R&D) or science and technology (S&T), applicants must:

• complete a Common Form for Current and Pending (Other) Support and a Common Form for Biographical Sketch (0MB Control Number 3145-0279) and must agree to update such forms at any subsequent time the Department deems appropriate during the term of the award;
• certify that research security training has been completed not more than one year prior to the date of application and must recertify annually for the duration of the award;
• certify they are not party to a malign FTRP and must recertify annually for the duration of the award;
• certify that they are not contracting, entering into arrangement with, or otherwise providing material or non-material benefit through the provision of funded or unfunded work to any foreign person or entity or any U.S. citizen or entity subject to foreign ownership, control, or influence by a country of concern or other foreign adversary unless appealed to and approved by the Secretary of Agriculture;
• certify they are not party to utilizing forced labor, or partnering with universities who are party to utilizing forced labor;
• complete a disclosure (updated annually) of contracts associated with participation in programs sponsored by foreign governments, foreign instrumentalities, or foreign entities including FTRPs;
• complete a disclosure ( updated annually) of the amount, type, and source of all current and pending research support received by, or expected to be received by, the applicant at the time of the disclosure and certify that the disclosure is current, accurate, and complete;
• complete a disclosure (updated annually) of all academic, professional, or institutional appointments and positions whether or not renumeration is received and whether fulltime, part-time, or voluntary (including adjunct, visiting, or honorary);
• seek approval from USDA to subaward any portion of a funded arrangement, including but not limited to university students, post-doctoral fellows, visiting researchers; and
• complete a disclosure (updated annually) that includes all personnel, including the country of citizenship, who have worked or are working on projects supported by the USDA-funded R&D or S&T award.

Failure to comply with these requirements will result in the disqualification of the application. If an applicant knowingly fails to disclose information, the Department shall suspend or terminate all awards to that applicant and may take additional actions, including temporary or permanent disbarment in accordance with 2 CFR 180 and 2 CFR 417 ( or any successor regulations) from receiving government funding.

U of A: The employing entity of a recipient entering into an arrangement with USDA related to R&D or S&T must:

• prohibit applicants who either are currently or have in the past 10 years participated in malign FTRPs from working on projects supported by R&D and S&T awards;
• certify that each applicant who is employed by such entity listed on the application has completed the required research security training;
• certify that each applicant who is employed by such entity listed on the application has been made aware of requirements under this memorandum;
• provide any supporting documentation, including copies of contracts, grants, or any other agreement, specific to foreign appointments, employment with a foreign institution, participation in a FTRP, and other information reported as current and pending support for all applicants in an application; and
• review any documents required under this memorandum for compliance with USDA award terms and conditions, including guidance on conflicts of interest and conflicts of commitment.

Failure to comply with any requirement of this memorandum, or of a USDA-approved arrangement, may result in termination of the arrangement and enforcement of any applicable laws or regulations.

July 8, 2025 America First Memorandum for USDA Arrangements and Research Security (last visited 9/30/2025)

U of A must:

• Provide training to all faculty and researchers identified as Senior/Key Personnel on the requirement to disclose all research activities and affiliations (active and pending) in Other Support (see Other Support form).
  • The new requirement to train researchers to comply with other support disclosure requirements adds to the current policy (see NIH Grants Policy Statement (GPS), Section 2.5.1 "Just-in-Time Procedures") in order to provide a comprehensive plan in the area of disclosure requirements for recipients.
• Effective October 1, 2025,   implement trainings, in addition to maintaining a written and enforced policy, on requirements for the disclosure of other support to ensure Senior/Key Personnel fully understand their responsibility to disclose all resources made available to the researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.
  • U of A has addressed NIH’s Other Support training through the Research Security Training module in EDGE Learning.