The form takes five minutes to fill out and years to audit. The Common Forms for Biographical Sketch and Current and Pending (Other) Support ask researchers to list every appointment, every source of research support, and every in-kind contribution that makes the work possible. What started as a grant-administration requirement under National Security Presidential Memorandum 33 (NSPM-33) is now arriving at journal submission as a second set of metadata: the author list and the disclosures behind it.
NSPM-33, issued on 14 January 2021, directed federal research agencies to standardise the information researchers must disclose about foreign appointments, funding, and talent recruitment programmes. The Office of Science and Technology Policy published implementing guidance on 4 January 2022. That guidance has moved from proposal systems into the ordinary work of deciding whose name goes on a paper and where each author is affiliated.
Disclosure rules built for grants now reach manuscript author lists
Researchers have always listed affiliations on manuscripts. The new guidance changes the status of that list. An affiliation is no longer a descriptive line; it is a disclosure record that can be checked against the biographical sketch and other support forms attached to federal awards. A professor who holds a visiting appointment at a foreign university must disclose it to the funding agency even if the institution does not appear on the published paper. The publication is one record. The federal disclosure is another. When they contradict, the contradiction is what research security officers notice.
The standardisation is deliberate. Before NSPM-33, agencies used different formats and asked different questions. A researcher could report a foreign appointment to the National Science Foundation but not to the National Institutes of Health, and each agency evaluated the information differently. The Common Forms now use a single structure for biographical sketches and current and pending support across federal agencies. Digital persistent identifiers, such as ORCID iDs, are meant to reduce confusion about who a researcher is, though that remains incomplete across disciplines and journals.
What an author must disclose before a manuscript goes out
The short answer is that more than the manuscript asks for will be needed from many co-authors. University research offices are increasingly asking principal investigators to review author lists against the following kinds of disclosure before submission:
- All paid and unpaid appointments, including adjunct, visiting, honorary, and emeritus positions at foreign institutions
- Current and pending research support from any source, domestic or foreign, including cash and in-kind support
- Financial interests and consulting arrangements tied to manufacturers, publishers, or laboratories that supplied materials used in the study
- Foreign components, a term of art in federal awards describing significant scientific work performed outside the United States, whether or not money changed hands
- Participation in foreign talent recruitment programmes, particularly those that compensate researchers for work aimed at another country's research enterprise
The last item is the most contentious. NSPM-33 defines malign foreign talent recruitment programs narrowly enough that ordinary international collaboration is not automatically suspect, but the burden of clarity falls on the researcher. An honest visiting professorship, disclosed in the same terms across grant and publication records, is ordinary. The same position omitted from one document and present in another is what turns a benign collaboration into an audit finding.
The publisher's role is narrow; the evidence trail is not
Publishers are not parties to NSPM-33. A manuscript management system does not automatically cross-check an author's funding disclosures against a federal database, and most editors will not ask to see a current and pending support form. That does not make the publication record irrelevant. When a federal agency reviews an award for undisclosed foreign support, the published paper can become an exhibit. An author list that names a foreign laboratory but does not match the grant's reported foreign component is a documentary gap that a university must explain, sometimes years after the article appeared.
The same compliance offices that parse banned terminology in grant narratives are now reviewing author lists for undisclosed affiliations. This convergence of research security and publication metadata was predictable once federal sponsors began treating the published literature as part of the administrative record. The precedent was set in proposal review; it is now routine in award closeout.
Two workflows compared
The practical change is easiest to see in side-by-side terms:
| Publication step | Before NSPM-33 implementation | Under current guidance |
|---|---|---|
| Author affiliation | Current institution where work was done, sometimes only the lead institution | All institutional appointments, including adjunct and foreign roles, aligned with grant disclosures |
| Funding statement | Grant number and broad agency name | All support sources, in-kind contributions, and any related financial interests |
| Foreign collaboration | Co-authorship itself was sufficient disclosure | Foreign component reported to the sponsor, with scope and location documented |
| Who checks | Usually only the submitting author and journal | Submitting author, department research administrator, sponsored projects office, and sometimes export control |
Where the friction shows up first
The friction is not theoretical. A paper with ten co-authors from six countries now requires ten disclosure histories before a university will release it for submission. In multi-institution collaborations, each campus has its own interpretation of how much of the other support form the corresponding author may see. Some will share full forms. Others will provide a one-page certification that lists no conflicts. Journals have no mechanism to reconcile these documents.
Data sharing mandates already force researchers to document provenance and access. Research security guidance extends that documentation to people and money. A manuscript that once moved from lab to journal in two weeks now sits in institutional review for twice that long, not because the science changed but because the co-authors' disclosure records did not match. Most of the delay is clerical. The institutions that reduce it are the ones that make disclosure part of the authorship conversation at the start, rather than at submission.
What university research offices are telling authors
The advice now circulating at research universities is concrete. Update current and pending support before asking anyone to write a manuscript section. Confirm with each co-author the exact institutional name and city as it will appear in the journal metadata, and make sure it matches the appointment listed in federal forms. Treat the acknowledgments section as a disclosure document, not a courtesy. If a foreign collaborator supplied samples, bench space, or salary for a co-author, put it in the sponsor's other support form before it appears in the paper.
For authors who want to see the underlying requirements, the OSTP implementation guidance for NSPM-33 is the anchor document. The National Science Foundation research security page covers the Common Forms, and the National Institutes of Health disclosure rules set out what grantees must report. These are not bedtime reading, but they are the documents a compliance officer will cite when a manuscript's author list differs from the grant record.
The question the guidance does not answer
NSPM-33 is clear about what an investigator must disclose. It is quieter about what a journal should do when two co-authors describe the same collaboration differently. A publisher is not a law enforcement office, and an editor is not an auditor. The journal's interest is in authorship and provenance; the federal interest is in foreign influence and national security. Those two interests overlap, but they do not merge.
The unanswered question is whether publishers will adopt disclosure standards that match federal expectations or leave the burden entirely to authors and institutions. For now, the burden sits where it usually does: with the researcher who signs the submission, checks the author list, and hopes the administrative record says the same thing as the published one.
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