Submitted Electronically to: CC: RE:Response to Request for Comments: Biosketch and Current and Pending Support Disclosure

We strongly recommend that NASA implement the common forms with no deviations, using the NSTC approved forms for the Common Form for Biographical Sketch and Common Form for Current and Pending (Other) Support Information along with the corresponding Definitions and Table. [...] The greatest level of effort proposed and committed may be due to the level of effort needed for certain researchers to perform experiments or analyses outlined in the proposal, even though other investigators might have been responsible for the design and oversight of the project. [...] We recommend that NASA aligns the definition of Senior/key persons with the NSPM-33 definition to align and standardize disclosure form requirements across the federal research agencies to the greatest extent practicable, in accordance with the NSPM-33 Implementation Guidance.3 Additionally, we urge NASA to support the NSPM-33 determination that broader classes of individuals (e.g., graduate, unde. [...] The submission sections (1 (c) and 2 (c)) specify that the Biographical Sketch and the Current and Pending Support forms will be made available “on the NASA Grants Policy and Compliance website as well as the NASA Shared Services Center website.” However, it does not specify the format expected to be used to submit the forms, e.g., PDF. [...] Section 2(e) of the Current and Pending Support Disclosures references “entities” as the party to disclose new current and pending support activities since the submission of the proposal or the RPPR when Principal Investigators generally submit RPPRs directly to NASA.