New Policy and Training Requirement: Current and Pending (Other) Support

Published September 25, 2025, via Research News

Senior/key personnel on most federal awards and proposals are required to disclose sources of financial or in-kind support via the Current and Pending (Other) Support document. This formal disclosure document is submitted to sponsors during proposal submission, Just-in-Time (JIT), or annual progress reporting.

While sponsors publish their own disclosure criteria for the document, many federal agencies have similar requirements. Senior/key personnel must disclose all resources made available to the individual in support of and/or related to all research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at WashU. 

The NIH announced a requirement for institutions to have a policy in place to train on disclosure requirements for Current and Pending (Other) Support. WashU has developed a short online training that outlines disclosure requirements and addresses how to identify if a resource is a gift or financial support. 

WashU has established a Current and Pending (Other) Support Policy, effective October 1, 2025. The new policy requires completion of the Current and Pending (Other) Support training by:

  • All senior/key personnel on proposals to or awards from a federal sponsor
  • Research administrators with a DA I or DA II role in RMS

The new training has been assigned to all faculty paid by sponsored funds. Any senior/key personnel not assigned in Learn@Work must self-enroll and complete the training. 

Beginning October 1, The Office of Sponsored Research Services will confirm that senior/key personnel on NIH applications have completed training before Other Support documents will be submitted to the NIH. 

Additional Information for Research Administrators
While most sponsors indicate that gifts do not need to be included on the document, results from a recent audit by the DHHS Office of the Inspector General indicate that many individuals (both researchers and administrative staff) were incorrectly identifying financial support as a gift. 

To ensure that our research staff are correctly assisting individuals completing the disclosure, research administrators with the RMS role if either DA I or DA II have also been assigned the training. Moving forward, completion of this training will be required to request RMS access for either DA I or DA II.