Institutions of higher education (IHEs), that meet the definition specified in Section 101(a) of the Higher Education Act of 1965 (20 U.S.C. § 1001(a)) and are direct recipients of NSF funding on or after May 20, 2024, are required to submit a Foreign Financial Disclosure Report (FFDR). See Proposal & Award Policies & Procedures Guide (PAPPG) Chapter VII.D.3.a for additional information.

Section 10339B of the CHIPS and Science Act of 2022 (42 U.S.C. § 19040) requires that each recipient institution of higher education must annually report all current financial support, the value of which is $50,000 or more, including gifts and contracts, received directly or indirectly from a foreign source which is associated with a foreign country of concern. Recipients that have questions about whether they meet the definition of an institution of higher education under the Higher Education Act of 1965 should consult with their legal counsel.

Only institutions of higher education, as defined in Section 101(a) of the Higher Education Act of 1965 (20 U.S.C. § 1001(a)), are required to submit a FFDR. Nonprofit research organizations that do not meet the definitional criteria of an institution of higher education do not need to submit a FFDR disclosure.

No, the FFDR reporting requirement applies only to direct recipients of NSF funding and does not include subawardees, subcontractors, or individuals that are beneficiaries of the award.

A foreign country of concern is defined in 42 U.S.C. § 19221(a)(1), and means the People’s Republic of China, the Democratic People’s Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country deemed to be a country of concern as determined by the Secretary of State. As of 2025, the Secretary of State has not designated any other country as a foreign country of concern.

Foreign countries of concern are not the same as Countries of Particular Concern. Countries of Particular Concern is a designation by the Secretary of State, which refers to countries that have engaged in or tolerated “particularly severe violations of religious freedom” as outlined in the International Religious Freedom Act (IRFA) of 1998.

IHEs must report payments from any added foreign country of concern in the next annual report that covers the period when the country was added. For example, if the State Department designates an additional foreign country of concern on December 1, 2025, an IHE must report any support received on or after December 1, 2025, from that foreign country of concern in its FFDR submission for the July 1, 2025, to June 30, 2026, reporting period.

The submission window to report support from foreign countries of concern (see PAPPG Chapter VII.D.3.a. for additional information) opens September 1, 2025. The Foreign Financial Disclosure Report (FFDR) is due on October 31, 2025 at 5:00 p.m. (based on the submitting organization’s local time). The submission window for subsequent years will follow the same dates and be open from September 1 to October 31 of the respective year.

The submission window for each report year refers to support received from July 1 of the previous year to June 30 of the reporting year. For example, foreign support received between July 1, 2024, and June 30, 2025, must be reported during the 2025 submission window.

If an IHE that receives an award or funding amendment on an existing award on or after May 20, 2024, the IHE must submit an FFDR for each reporting period. Negative reports are required even if IHEs do not receive financial support with a cumulative value of $50,000 or more per source in gifts or contracts from a foreign country of concern.

Tuition payments for a specific student(s) are excluded from the reporting requirement (e.g., parent payment for child/children or other relatives). However, if a tuition payment is received from a foreign source in the form of a grant, scholarship, or other form of financial aid, the payment is reportable when the cumulative threshold of $50,000 from a foreign source is met.

Tuition for non-matriculated students has the same reporting requirements as tuition for matriculated students, as listed above.

Yes, an IHE must disclose reportable scholarships, fellowships, or other forms of financial support that go directly to students without passing through the IHE if the IHE has knowledge of the gifts or contracts and if the gifts or contracts meet the FFDR reporting thresholds (originates from a foreign source in a foreign country of concern and has a cumulative value that equals or exceeds $50,000).

IHE must disclose gifts or contracts made directly to an individual if the IHE has knowledge of the gifts or contracts and if the gifts or contracts meet the FFDR reporting thresholds (originates from a foreign source in a foreign country of concern and has a cumulative value that equals or exceeds $50,000). Note, if the individual is also listed as senior/key personnel on an NSF award, they must still report the gift or contract in their NSF Current or Pending (Other) Support document.

If individuals at an IHE review proposals for organizations based in countries of concern, but do not receive any financial support for completing the review, they do not need to disclose such reviews in an NSF Current and Pending (Other) Support document, and their IHE does not need to disclose the faculty member’s reviews in their FFDR disclosure. However, individuals that receive financial support (monetary or in-kind) to review proposals for organizations based in countries of concern must disclose the financial support in their Current and Pending (Other) Support document. If the IHE has knowledge of the financial support provided to the individual, and the financial support is from a foreign country of concern and has a cumulative value greater or equal to $50,000 per source, the financial support is also reportable in the FFDR disclosure.

• If a multiyear gift or a contract spanning more than one year from a foreign source in a foreign country of concern is initiated during the reporting period (July 1, 2024, to June 30, 2025), and $50,000 or more is received during the reporting period (July 1, 2024, to June 30, 2025), only the amount received during this reporting period must be reported in the “Gift Amount” or “Contract Amount” field in the FFDR portal.
• If a multiyear gift or a contract spanning more than one year from a foreign source in a foreign country of concern was initiated prior to the reporting period (July 1, 2024, to June 30, 2025) but $50,000 or more is received during the reporting period (July 1, 2024, to June 30, 2025), the amount received during the reporting period must be reported in the “Gift Amount” or “Contract Amount” field in the FFDR portal.
• Cumulative amounts of $50,000 or more received under a multiyear gift or contract in future years must be reported during the corresponding reporting period, not during the current reporting period.

Yes, the U.S. IHE must report gifts and contracts made to an international branch campus.

Every component of an IHE, whether a branch campus of a multicampus IHE, or a school of the IHE (e.g., a medical school affiliated with an IHE), that is a direct recipient of NSF funding and has its own Unique Entity ID (UEI) must prepare its own FFDR submission.

One exception is if all NSF funding is provided to the main campus of a multicampus IHE and the main campus then allocates the funding to the branch campus (i.e., the branch campus does not receive any direct funding from NSF during the reporting period). The main campus is considered the direct recipient of NSF funding and is responsible for reporting for all branch campuses in its FFDR submission. Each branch campus, even if it has a distinct UEI, does not have to prepare its own FFDR submission since it is not the direct recipient of NSF funding.

An intermediary includes:

1. an individual or entity other than an Institution of Higher Education that receives a gift from or enters into a contract with a foreign source and then passes part or all of the support from the gift or contract to the Institution of Higher Education, or
2. an individual or entity other than a foreign source that sends support from a gift or contract to an Institution of Higher Education on behalf of a foreign source.

A Pass-Through-Entity is not considered an intermediary under the FFDR requirements.

If the gift or contract originates from a country of concern and the gift or contract passes through an intermediary from a non-country of concern, the IHE is required to report the gift or contract if the cumulative value received during the reporting period is greater than or equal to $50,000.

For example, if an IHE receives a gift from a European foundation but the source of the gift originates from a country of concern and is greater than or equal to $50,000, the IHE must list the source of the gift as the foreign source based in the country of concern, the country of attribution should be the country of concern, and the intermediary would the European foundation.

Details relating to the foreign source must be reported in the “Type of Foreign Source” subsection of the gift or contract reporting section of the FFDR portal. Details relating to the intermediary must be reported in the Gift Recipient/Domestic Party to Contract subsection of the FFDR portal.

An IHEs must report gifts or contracts from a foreign source associated with a foreign country of concern with a cumulative value greater than or equal to $50,000 made to a foundation or related entity of the IHE in its FFDR.

The name and location of the foreign entity headquartered in a foreign country of concern must be reported in the “Add Foreign Source” subsection. The questions in the “Type of Foreign Source” subsection refer to the foreign entity. On the “Foreign Source Gift Details” or “Foreign Source Contract Details” page, report the country of attribution as the foreign country of concern where the entity’s headquarters is located. On the same page, report the U.S.-based subsidiary as an intermediary.

IHEs must report gifts or contracts based on the date that the gift or contract payment was received by the institution. If the date that the gift or contract payment is received by the IHE falls within the July 1, 2024, to June 30, 2025, reporting window, the gift or contract must be reported if the cumulative value of the gifts or contracts exceed $50,000 per source.

If a researcher was assigned to the contract by the IHE, the researcher’s name is not required to be reported. If a foreign source suggests or imposes a researcher on a contract, the IHE must report the researcher’s name.

If the PI or PD leading a project receives financial benefit from the gift or contract, then their names must be provided. If the funding provided via a gift or contract is to benefit named researchers other than the PI or PD, then the names of those other researchers must be provided in lieu of the PI or PD identified in the award notice.

If the institution determines that it is an institution of higher education according to Section 101(a) of the Higher Education Act of 1965 (20 U.S.C. § 1001(a)), then the institution must submit an FFDR if it received a reportable payment during the relevant reporting period.

No, NSF does not classify a no cost extension as a funding amendment, and a no cost extension by itself would not trigger the FFDR reporting requirement.

IHEs may use the NSF Award Search tool to determine if their institution has received an NSF award or award amendment during the relevant reporting period.

If an IHE receives financial or in-kind support from a foreign source associated with a foreign country of concern to conduct a clinical trial and the cumulative value of the support is equal to or exceeds $50,000, this is considered a contract and is reportable in the FFDR disclosure.

Yes, IHEs must report contracts providing licensing or royalty payments from a foreign source associated with a country of concern with a cumulative value equal to or exceeding $50,000.

If the agreement has no value, the IHE is not required to report the contract.

No, IHEs are not required to report income from dividends or capital gains from passive investments, such as mutual funds, that have exposure to companies headquartered in a foreign country of concern.

If an IHE is purchasing goods and services from a vendor located in a foreign country of concern, this is not considered financial support and the purchase is not a reportable item in the FFDR. However, if a foreign source in a foreign country of concern enters into a sales contract with an IHE and purchases goods or services from an IHE with a cumulative value equal to or exceeding $50,000, the payment for the purchases is reportable in the FFDR disclosure.

If the partner institutions collect tuition payments for a specific student(s), (e.g., parent payment for child/children or other relatives), and then remits the tuition payment back to the U.S. IHE, this is not a reportable event. However, if the partner institutions collect tuition payments in the form of a grant, scholarship, or other form of financial aid and remits these payments back to the U.S. IHE, the payment is reportable when the cumulative threshold of $50,000 from a foreign source in a FFDR reporting period is met.

The IHE must report the value received for each gift or contract payment. If the partner institution remits payment for multiple services in a single lump sum payment, the value of the lump sum payment must be reported when the total value of all gift or contract payments is equal to or exceeds $50,000. The individual line items do not need to be reported, only the total value of the lump sum payment needs to be reported. However, if the partner institutions remit gift or contract payments for each individual line item separately, then each gift or contract payment must be reported separately in the FFDR disclosure.

If the Wholly Foreign Owned Enterprise (WFOE) in a foreign country of concern received funds with a cumulative value equal to or exceeding $50,000 in the relevant reporting period and meets the definition of a foundation or related entity, the IHE must report the WFOE as such. If the WFOE received funds with a cumulative value equal to or exceeding $50,000 in the relevant reporting period but does not meet the definition of a foundation or related entity, the IHE must report the WFOE as an intermediary.

No, the FFDR requirement is specific to disclosing financial support received from a foreign country of concern as listed in the PAPPG (Introduction Chapter D.1.g.).

If a gift was received or a contract was entered into with a foreign source associated with a country of concern, and the foreign source is a natural person, then the citizenship of the natural person must be reported as the country of attribution. If the citizenship of the natural person is not known, then the country of the natural person’s principal residence must be reported as the country of attribution. IHEs must take the steps they need to ensure that their reporting is accurate.

Yes, visiting scholars who are externally funded must be reported as a contract providing in-kind support to the IHE.

An individual with the FFDR Preparer role can initiate and submit FFDRs using the Foreign Financial Disclosure Report (FFDR) page link included in the FFDR system-generated emails from NSF or by clicking the Foreign Financial Disclosure Report (FFDR) link under "Manage Financials" on the Research.gov   homepage after signing in.

The FFDR Preparer role is required to access the Foreign Financial Disclosure Report (FFDR) link on the Research.gov homepage. NSF assigned the FFDR Preparer role to all individuals with the Authorized Organizational Representative (AOR) role as of May 20, 2024 to assist the research community with the first reporting period for the new FFDR requirement. If a user needs the FFDR role, the Organizational Administrator must be contacted to ensure proper assignment. The FFDR role cannot be requested by users in Research.gov as can be done for other roles such as AOR or Other Authorized User (OAU).

To view assigned role(s):

• Sign into Research.gov
• Select ‘My Profile’ at the top of the page and then ‘View My Roles’ from the left navigation bar

If a user does not have the FFDR Preparer role and is required to submit a report, click 'See Org Contact(s)' for a listing of Organizational Administrators to assign the FFDR Preparer role to the user.

Yes, any user with the FFDR Preparer role and associated with the submitting organization can access, edit, or submit the report.

Users cannot request to add the FFDR Preparer role in Research.gov Account Management but can contact their Organizational Administrator to assign the FFDR Preparer role to them. As of May 20, 2024, the Foreign Financial Disclosure Report (FFDR) Preparer role is automatically selected when the Administrator assigns the AOR role to a user. Uncheck the FFDR Preparer role if the user should only have the AOR role and not the FFDR Preparer role. You can still assign the FFDR Preparer role to someone else within the organization.

Organizational Administrators can add the FFDR Preparer role for users within their organization on the View My Users Administrator Dashboard. Refer to the View My Users – Administrator Dashboard job aid   in the Account Management User Guide for step-by-step instructions with associated screenshots.

Organizational Administrators can remove an assigned FFDR Preparer role for users within their organization on the View My Users Administrator Dashboard. Refer to the View My Users – Administrator Dashboard job aid   in the Account Management User Guide for step-by-step instructions with associated screenshots.

No, NSF only assigned the FFDR Preparer role to users with the AOR role effective on May 20, 2024, to assist the research community with the first reporting period for the new FFDR requirement. NSF does not plan to assign the FFDR Preparer role to new AORs going forward, but Organizational Administrators can add or remove the role for users within their organizations at any time.

Only IHEs are subject to the disclosure requirement at this time and must have a user with the FFDR Preparer role to prepare and submit the annual report. Organizational Administrators can add or remove the FFDR Preparer role for users within their organization on the View My Users Administrator Dashboard. Refer to the View My Users – Administrator Dashboard job aid   in the Account Management User Guide for step-by-step instructions with associated screenshots.

The FFDR Preparer certifies that the information reported in the FFDR is accurate and complete.

All FFDR Preparers affiliated with an IHE will be sent a system-generated email notification on September 1 of each year which is the start of the submission period. The email will be sent from the ForeignFinancialDisclosure@nsf.gov email address.

Yes, FFDR Preparers for IHEs required to report that have not yet submitted an FFDR will be sent a system-generated email notification reminder on October 17, 14 days prior to the October 31 submission deadline.

Yes. System-generated submission reminder emails will be sent to FFDR Preparers for IHEs that have not submitted a required report on November 1, November 14, and November 28.

All users with the FFDR Preparer role are sent the FFDR system-generated emails from the ForeignFinancialDisclosure@nsf.gov email address. These include notification and reminder emails as well as submission confirmation emails.

The user should contact the NSF IT Service Desk at 1 (800) 381-1532 (7:00 AM - 9:00 PM ET; Monday - Friday except federal holidays) or via email to rgov@nsf.gov if the user believes an FFDR is required to be submitted but a system-generated email notification was not received. If an IHE did not receive a new award or a funding amendment on or after May 20, 2024, the FFDR Preparer will not receive a system-generated email notification to submit during the curent reporting period.

IHEs can also check the award dates of their NSF awards using NSF Award Search. Enter the award number and look for the “Latest Amendment Date.” If the “Latest Amendment Date” indicates a date on or after May 20, 2024, the IHE is required to submit a FFDR for each reporting period. If the “Latest Amendment Date” indicates a date before May 20, 2024, the IHE is not required to submit a FFDR.

Effective May 20, 2024, all AORs were assigned the FFDR Preparer role. This is a new user role for preparing and submitting the required Foreign Financial Disclosure Report. Please contact your Organizational Administrator to remove the FFDR Preparer role if necessary.

The user should contact the Organizational Administrator of the previous organization to request removal of the user's affiliation with the organization.

All FFDR Preparers affiliated with the IHE of the submitted report will receive a system-generated submission confirmation email. The email will be sent from the ForeignFinancialDisclosure@nsf.gov email address.

All FFDR Preparers affiliated with the IHE will receive a system-generated confirmation email when an in-progress report is deleted. The email will be sent from the ForeignFinancialDisclosure@nsf.gov email address. Please note that submitted FFDRs in Research.gov cannot be deleted or withdrawn.

The "Create Report" button will be disabled in the following scenarios:

• A report has already been created for the IHE. Only one report can be created in Research.gov for each IHE registered in the System for Award Management (SAM) and issued a Unique Entity Identifier (UEI). If the IHE's in-progress FFDR is deleted in Research.gov, the "Create Report" button will be enabled again.
• The report submission window has closed.

In a positive FFDR report, the IHE has received gifts from or entered into contracts with a foreign source associated with a foreign country of concern that they need to report, based on the requirements listed in PAPPG Chapter VII.D.3.a. In a negative FFDR report, the IHE certifies that they have not received gifts from or entered into contracts with a foreign source associated with a foreign country of concern, as outlined in the FFDR requirements listed in PAPPG Chapter VII.D.3.a.

An individual with dual citizenship including U.S. citizenship is not considered a foreign source for FFDR purposes. However, a gift or contract from the dual citizen would be reportable if the dual citizen acts as an agent on behalf of a foreign country of concern.

Yes, if the institution returned a gift or contract payment within the same reporting period the payment was received, the institution must still disclose the payment and may check the box in the Gift Details or Contract Details page titled “The gift/contract amount was returned to the foreign source in part or in full.”

If an institution reported a gift or contract in a previous FFDR submission but later returned the gift or contract payment, the institution may amend its report and check the box in the Gift Details or Contract Details page titled “The gift/contract amount was returned to the foreign source in part or in full.”

FFDR errors and warning messages can be viewed by clicking "Check Error(s) and Warning(s)" button under Report Actions. Automated compliance checks will be run, and a page will be generated to display any compliance validation errors or warnings triggered by the FFDR. The report can be saved, but any identified errors must be corrected in order to submit the report. Users can submit the FFDR with warnings; however, that is not recommended.

An in-progress report can be deleted from the report main page by clicking the "Delete Report" button under Report Actions. Once an in-progress report is deleted, the data is permanently removed and cannot be retrieved. A submitted report cannot be deleted.

Revisions and amendments of submitted reports can also be deleted by selecting the 'Delete Revision' or Delete Amendment' buttons, respectively. Clicking these buttons will delete the in-progress revision or amendment and the latest submitted version of the report will be retained.

Yes, the FFDR Portal will allow the entry of gifts and contracts that are less than the reporting threshold of $50,000. However, an IHE is not required to report gifts or contracts from a foreign source if the cumulative value is less than $50,000. As outlined in PAPPG Chapter VII.D.3.a, "In accordance with Section 10339B, Foreign Financial Support, of the CHIPS and Science Act of 2022, (42 U.S.C. § 19040), each “recipient institution of higher education" must annually report all "current financial support, the value of which is $50,000 or more, including gifts and contracts, received directly or indirectly from a foreign source" which is "associated with a foreign country of concern," as defined in the PAPPG Introduction, Section D."

Upon review of a submitted report, NSF may request that copies be submitted of any contracts, agreements, or documentation of financial transactions associated with the submitted FFDR.

Foreign support that is received after June 30 of the current reporting year will be reported during the next year's submission window. For example, if an IHE receives foreign support on July 31, 2025, this support must be reported during the 2026 FFDR submission window.

The FFDR submission window will close at 5:00 PM in the submitting IHE's local time on October 31. Once the submission window closes, IHEs will not be able to create, modify, or submit their reports; any in-progress reports will become read-only; and required reports that are unsubmitted will be considered overdue. If an IHE does not submit their required FFDR by this time, the FFDR Preparer must request an extension to submit the FFDR.

Beginning November 1 of each year a "Request Extension" button will display on the Initial Report(s) page. The FFDR Preparer will click the "Request Extension" button and then will select the organization requesting the extension. The FFDR Preparer clicks the "Select and Continue" button to submit the extension request.

All FFDR Preparers associated with the requesting IHE will receive an email notification confirming their extension request was submitted and approved. In addition, a green success message will display at the top of the IHE's FFDR main page communicating that the extension request was approved.

The IHE will have 30 calendar days after the extension request was approved to submit the FFDR. The "extended deadline" will display in the gray box on the FFDR main page with the new deadline date.

If the FFDR is not submitted by the extension deadline, the FFDR will still be considered overdue and the IHE would be required to submit another extension request to submit the report.

No. Any modifications needed for a submitted report must be made through an amendment rather than an extension. Please refer to the amendment request process below.

Yes. The FFDR can be revised until the extended deadline. This can be done by clicking the "Edit Report" link on the Initial Report(s) page, making revisions, and then resubmitting the report. After the extended deadline, any modifications must be made through an amendment request submitted to NSF.

Yes. If the FFDR is within its extended deadline and has not yet been submitted, the FFDR can be deleted. However, a new extension request would be required to create and submit the FFDR if the FFDR is deleted.

There will be a three-year window after each report year for FFDR Preparers to amend a submitted FFDR. For example, the report deadline for the 2025 FFDR year is October 31, 2025. FFDR Preparers can amend their submitted 2025 report until October 31, 2028. This is referred to as the "amendment window."

Beginning November 1 of each year a "Request Amendment" link will display on the Initial Report(s) page next to the IHE's submitted report. The FFDR Preparer will click this link to submit an amendment request.

No. Amendment requests will be automatically approved. Users will see their request is approved in the system shortly after submitting the request.

All FFDR Preparers associated with the requesting IHE will receive an email notification confirming their amendment request was submitted and approved. In addition, a green success message will display at the top of the IHE's FFDR main page communicating that the amendment request was approved.

The IHE will have 30 calendar days after requesting an amendment to submit their revised report.

If an IHE requests an amendment within 30 calendar days of the report's amendment window end, the IHE would have until the last day of the amendment window to submit their revised report. For example, if an IHE requests an amendment for their 2025 FFDR on October 25, 2028, they would be required to submit their revisions by October 31, 2028.

If a revised report is not submitted prior to the amendment deadline, any modifications will not be saved. The system will retain the last submitted version of the report and an additional amendment and 30 calendar day period would be required to revise the report. If an additional amendment is requested, the FFDR Preparer would work from their last submitted version of the report.

There is no limit to the number of amendments an FFDR Preparer can make to a submitted report. Research.gov will retain the last submitted version of the report.

No. Reports that are not submitted prior to the deadline will be considered overdue and would require an extension to submit the report. Once the report is submitted, the FFDR Preparer can request an amendment if revisions are needed.

Yes. The FFDR can be revised up until the amendment deadline passes. This is done by clicking the "Amend Report" link on the Initial Report(s) page, making revisions, and then resubmitting the report. After the amendment deadline, any modifications must be made through a new amendment request submitted to NSF.

No. Once a report is submitted to NSF, it cannot be deleted. However, the report can be revised through an amendment after the deadline passes.

The submitted report can be viewed in Research.gov by clicking the "View Submitted Report" link on the IHE's FFDR main page. After the submission period for the specified report has closed, the report can only be viewed in read-only mode and cannot be edited unless an amendment request has been granted.

A submitted report can be viewed in Research.gov by clicking the "View Report" link on the report main page. After the submission period for the specified report has closed, the report can only be viewed in read-only mode and cannot be edited unless an amendment request has been granted.

While print functionality is not yet available in the FFDR portal, FFDR Preparers can print the report from their Web browser.

No, but FFDR Preparers may display, print to PDF, and then save that PDF copy of the report from their web browser

FFDR data from the previous year will be pre-populated in the Research.gov FFDR portal on the next year’s report.

As noted in Section 10339B of the CHIPS and Science Act of 2022 (42 U.S.C. § 19040), NSF may request that a recipient institution provide true copies of any contracts, agreements, or documentation of financial transactions associated with disclosures made in the FFDR. IHEs must maintain a true copy of the relevant records subject to the disclosure requirement until the latest of:

1. the date that is four years after the date of the gift or contract agreement;
2. the date on which the gift or contract agreement terminates; or
3. the last day of any period that applicable State public record law requires a true copy of such gift or contract agreement to be maintained.

It is NSF’s general intent to make public the information provided or collected in the FFDR disclosures. Certain data elements will be treated as confidential, and will be publicly disclosed only to the extent required under applicable Federal law. A listing of the updated data elements for the 2024-2025 reporting period may be found here.

After soliciting and reviewing public comments on the FFDR disclosures, NSF believes that certain data elements could raise serious privacy concerns if they were routinely disclosed to the public. Accordingly, NSF will not routinely disclose to the public FFDR data elements that would reveal the names, departments, and positions of individuals receiving support, the names of agents acting on behalf of foreign governments, and the names and addresses of foreign sources and intermediaries.

For these data elements, NSF determined that relying upon IHEs to identify when the data should be treated as confidential could result in inconsistent treatment and inadvertently compromise individual privacy in certain cases where an IHE did not seek confidentiality. Thus, these data elements will be considered confidential without requiring that the IHE request or indicate such treatment. As noted, NSF does not intend to disclose such data publicly, except as may be required by applicable law.