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  • Washington Highlights

    AAMC Submits Comments to NSF on Common Disclosure Forms

    Anurupa Dev, Director, Science Policy & Strategy
    Heather Pierce, Senior Director, Science Policy & Regulatory Counsel
    For Media Inquiries

    The AAMC on Oct. 31 submitted comments to the National Science Foundation (NSF) requesting feedback on proposed common disclosure forms for the Biographical Sketch and Current and Pending (Other) Support sections of a research application, intended to clarify what is expected of senior personnel applying for research funding from federal agencies.

    The request was issued by the NSF on behalf of the National Science and Technology Council's Research Security Subcommittee, which has been tasked with implementation of the National Security Presidential Memorandum 33 [refer to Washington Highlights, Jan. 7]. The memorandum outlines federal actions to strengthen research security, including the development of standardized disclosure requirements.

    In its comments, the AAMC highlighted the role of harmonized requirements in promoting compliance and reducing administrative burden while addressing federal funding agencies’ need for information to address research security concerns. The letter also described a potential role for Convey, the AAMC-developed global disclosure system, in collecting and sharing the required disclosure information.

    The association additionally submitted a joint letter on Oct. 31 to the NSF with the Association of American Universities, the Association of Public and Land-Grant Universities, the American Council on Education, and the Council on Governmental Relations. These comments highlight the importance of clarifying definitions, ensuring a transparent and uniform process for updating the common forms, and limiting agency variation in required disclosure data elements and instructions.