In accordance with Section 10339B, Foreign Financial Support, of the CHIPS and Science Act of 2022 (42 U.S.C. § 19040), each institution of higher education that receives NSF funding must disclose annually, 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. See Proposal & Award Policies & Procedures Guide (PAPPG) Chapter VII.D.3 for additional information.
FFDRs must be prepared and submitted in Research.gov by individuals with the FFDR Preparer role. NSF assigned the FFDR Preparer role to all individuals with the Authorized Organizational Representative (AOR) role as of May 20, 2024. Organizational Administrators can add or remove the FFDR Preparer role for individuals within their organization as appropriate.
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Contacts for Questions
Who is required to submit a Foreign Financial Disclosure Report?
Direct recipients of NSF funding on or after May 20, 2024, which are institutions of higher education (IHE), as that term is defined in section 101(a) of the Higher Education Act of 1965 (20 U.S.C. 1001(a)) are required to submit a Foreign Financial Disclosure Report (FFDR). See Proposal & Award Policies & Procedures Guide (PAPPG) Chapter VII.D.3 for additional information.
Why are IHEs required to file?
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.” If a recipient has questions about whether they meet the definition of an institution of higher education under the Higher Education Act of 1965, they need to consult with their legal counsel.
Are the subaward entities required to submit a FFDR?
No, this requirement applies only to direct recipients of NSF funding and does not include entities that receive subawards or individuals that are beneficiaries of the award.
Are there required deadlines to submit the FFDR?
The submission window to report foreign support from countries of concern (see PAPPG Chapter VII.D.3 for additional information) received between July 1, 2023 and June 30, 2024 opens July 1, 2024. While the PAPPG and Award Terms and Conditions stipulate that the Foreign Financial Disclosure Report (FFDR) is due on July 31, 2024, NSF is providing a one-time grace period for the initial report until September 3, 2024 at 5:00 p.m. (based on the submitting organization’s local time).
Does the report cover a specific time frame?
The submission window for each report year refers to support received from July 1st of the previous year to June 30 of the reporting year. For example, foreign support received between July 1, 2023, and June 30, 2024, must be reported during the 2024 submission window.
Yes, a negative report is required. Any IHE that receives an award or funding amendment on an existing award on or after May 20, 2024, must submit an FFDR regardless of whether financial support in the value of $50,000 or more in gifts and contracts from a foreign country of concern was received.
Are IHEs required to report tuition payments?
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 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.
Are tuition payments for non-matriculated students reportable?
Tuition for non-matriculated students have the same reporting requirements as tuition for matriculated students, as listed above.
How should IHEs report multiyear gifts and contracts spanning more than one year?
Yes, gifts and contracts made to an international branch campus are required to be reported by the U.S IHE.
Is an FFDR required for each campus of a multicampus IHE?
Every entity 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) should prepare its own FFDR submission.
One exception is if all NSF funding during the reporting period is directed to the main campus of a multicampus IHE and the main campus then allocates the funding to the branch campus (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 the FFDR requirement applies to the main campus. The branch campus, even if it has a UEI, does not have to prepare its own FFDR submission since it is not a direct recipient of NSF funding.
An intermediary means an individual or legal entity other than an IHE that receives a gift or contract from a foreign source and then passes part or all of the gift or contract to the IHE.
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, an IHE is required to report the gift or contract if it 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.
How does a user access the FFDR functionality in Research.gov?
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 should 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):
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.
How does a user request to add the FFDR Preparer role in Research.gov Account Management?
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.
Will NSF assign the FFDR Preparer role each year?
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.
Can organizations that are not IHEs remove the FFDR Preparer role?
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.
How will an IHE be notified that the reporting submission period has opened?
All FFDR preparers affiliated with an IHE will be sent a system-generated email notification on July 1, 2024, which is the start of the first reporting period. The email will be sent from the ForeignFinancialDisclosure@nsf.gov email address.
Will FFDR preparers receive a reminder about the July 31st report submission deadline?
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 July 24, seven days prior to the July 31st submission deadline.
In the first year only, there is a grace period until September 3, 2024, to submit reports. System-generated submission reminder emails will be sent to FFDR preparers for IHEs that have not submitted a required report on August 1st, August 14th, and August 28th.
Who are the recipients of the FFDR system-generated email notifications?
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 users 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 first reporting period which opens on July 1, 2024.
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 Organizational Administrator of the user's previous organization should be contacted to request removal of the user's affiliation with the organization.
Who receives an email notification when an FFDR is submitted in Research.gov for the IHE?
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.
Who receives an email notification if an FFDR is deleted in Research.gov?
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.
How do IHEs create a report if the "Create Report" button is disabled?
The "Create Report" button will be disabled in the following scenarios:
What is the difference between a positive and negative FFDR report?
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.
Should IHEs disclose gifts and contracts from countries that are not listed as a country of concern?
No, the FFDR is specific to support received from a foreign country of concern as defined in the PAPPG (Introduction Chapter D.1.g. ).
How do users view FFDR errors and warnings?
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.
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.
What do IHEs do if the foreign financial gift is received after the July 31st submission date?
Foreign support that is received after July 31st 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, 2024, this support must be reported during the 2025 FFDR submission window.
What happens if an IHE does not submit a FFDR by July 31st?
A one-time grace period extension for the first reporting period is available for IHEs to submit the FFDR by September 3, 2024. Failure to submit timely reports will delay the processing of additional funding and administrative actions, including, but not limited to, no-cost extensions. In the case of continuing grants, failure to submit timely reports will delay processing of funding increments.
What happens if an IHE does not submit an FFDR before the grace period ends on September 3rd?
The FFDR submission window will close at 5:00 PM submitting IHE's local time on September 3, 2024. 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 before the grace period ends on September 3, 2024, the FFDR preparer must request an extension to submit the FFDR.
How can an IHE request an extension to submit a report after September 3, 2024?
Beginning September 4, 2024, 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.
What is the deadline for an IHE to request an extension?
IHEs have until the submission window opens for the following year to request an extension for the current reporting year and to submit their report. This is referred to as the "extension window." For the 2024 report year, the extension window will be open from September 4, 2024 through June 30, 2025.
Can an extension request be denied?
No. Extension requests for the 2024 report year will be automatically approved. Users will see their request is approved shortly after submitting the request and FFDR preparers for the IHE will also receive an email confirmation.
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.
How long will an IHE have to submit the FFDR after receiving an extension?
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 cannot be submitted within the 30 calendar day period, the IHE can request another 30 day extension.
If an IHE requests an extension within 30 calendar days of the end of the extension window, the IHE would have until the last day of the extension window (i.e., June 30) to submit their report. For example, if an IHE requests an extension for their 2024 FFDR on June 14, 2025, they would be required to submit their report by June 30, 2025.
What if the FFDR is not submitted by the extension deadline?
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.
Can an extension be requested for a submitted FFDR?
No. If the IHE submitted an FFDR prior to the September 3 deadline, any modifications needed for that 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.
Can an FFDR be deleted during the extension window?
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.
How long after the report deadline can FFDR preparers request an FFDR amendment?
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 2024 FFDR year is September 3, 2024. FFDR preparers can amend their submitted 2024 report until September 3, 2027. This is referred to as the "amendment window."
How do FFDR preparers request an FFDR amendment?
Beginning September 4, 2024, 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.
Can an amendment request be denied?
No. Amendment requests for the 2024 report year will be automatically approved. Users will see their request is approved 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.
How long will an IHE have to submit a revised FFDR after an amendment request is 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 2024 FFDR on August 25, 2027, they would be required to submit their revisions by September 3, 2027.
What if the amendment deadline passes and the FFDR revisions have not been submitted?
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.
How many amendments can be submitted for an FFDR?
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.
Can an amendment be requested for an unsubmitted FFDR?
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.
Can an FFDR be deleted during an amendment window?
No. Once a report is submitted to NSF, it cannot be deleted. However, the report can be revised through an amendment.
How do FFDR preparers view submitted FFDRs in Research.gov?
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.
Are FFDR preparers able to edit the report after it has been submitted?
FFDR preparers can edit submitted reports in Research.gov until the submission window closes. Report updates are done in Research.gov by opening the report, making revisions, and then resubmitting the report. After the report submission deadline, any modifications must be made through an amendment request submitted to NSF.
How do FFDR preparers print a submitted report?
While print functionality is not yet available in the FFDR portal, FFDR preparers can print the report from their browser.
Proposal & Award Policies & Procedures Guide (PAPPG)
Disclosures Required Under PAPPG Chapter VII.D.3 (PDF, 109.38 KB)
FFDR Webinar and Technical Demo: