The new NSF proposal and Award Policies and Procedures Guide (PAPPG) has been released and updated, effective January 25, 2016 (see PAPPG). OSP wants to ensure compliance to our sponsor and internal policies and procedures.
An excellent resource for understanding these changes is the NSF Webinar on Updates to Proposal & Award Policy (found here). Topics include:
- PAOOG Revisions - Implementation Schedule & Significant Changes
- NSF Public Access Plan
- Research.gov Notifications & Requests
- Automated Compliance Checking
- Reducing Administrative Burden
- Future Outreach Opportunities
You can also review the complete list of Significant Changes and Clarifications to the PAPPG as outlined below.
Significant Changes to the PAPPG Part I: Grant Proposal Guide (GPG)
Chapter I.F, When to Submit Proposals, has been updated to remove the ability to use other than 5 p.m. submitter’s local time in solicitations. Failure to submit by 5 p.m. submitter’s local time will result in the proposal not being accepted.
Chapter I.G.2, How to Submit Proposals, has been revised to reflect that an Authorized Organizational Representative (AOR) must provide the proposal certifications concurrently with submission of the proposal. This change is consistent with the process used in Grants.gov. In addition, proposal file updates and revised budgets (Chapter III.C and D, respectively) must be signed and submitted by an AOR and only an AOR can perform a withdrawal function on behalf of a proposing organization (Chapter IV.A).
Chapter II.C.1.d, Proposal Certifications, has been supplemented with a new certification regarding Dual Use Research of Concern.
Chapter II.C.1.e, Collaborators & Other Affiliations Information, is a new single-copy document that requires each senior project personnel to provide information regarding collaborators and other affiliations. This information used to be provided as part of the Biographical Sketch. The new format no longer requires proposers to identify the total number of collaborators and other affiliations when providing this information.
Chapter II.C.2.f, Biographical Sketch(es), has been supplemented to inform proposers that they may use third-party solutions to develop their biographical sketch, however, the information they submit must be compliant with NSF proposal preparation requirements. In addition, it is no longer allowable for the biographical sketches of all senior personnel to be grouped together in a single PDF file. Biographical sketches must now be uploaded separately for each individual identified on the proposal as senior personnel. Biographical sketches for Other Personnel and for Equipment proposals (Chapter II.C.2.f(ii) and (iii) respectively), however, should be uploaded as a single PDF file in the Other Supplementary Documents section of the proposal.
Chapter II.C.2.h, Current and Pending Support, has been revised to reflect that all current project support should be listed in this section of the proposal, including internal funds allocated toward specific projects. It is no longer allowable for the current and pending support of all senior personnel to be grouped together in a single PDF file. Current and pending support must now be uploaded separately for each individual identified on the proposal as senior personnel.
Chapter II.D.14, Dual Use Research of Concern (DURC), is an entirely new section and serves, in conjunction with coverage in the Award & Administration Guide, as NSF’s implementation of the US Government Policy for Institutional Oversight of Life Sciences Dual Use Research of Concern.
Clarifications and Other Changes to the GPG
Chapter I.G.4, NSF ID, has been updated to specify that each individual user of NSF systems should not have more than one NSF ID.
Chapter II.B.2, Format of the Proposal, has been revised to show that solicitations no longer may specify different type size, margin, or spacing requirements. All NSF funding opportunities will follow the formatting instructions contained in this section of the GPG.
Chapter II.C.1, Single-Copy Documents, has been changed to reflect that, since proposers submit the Information about PIs/PDs and co-PIs/co-PDs as part of the PI profile in FastLane, it has been deleted from the list of single-copy documents. Also, when submitting a list of suggested reviewers, PIs should include the email address and institutional affiliation of persons they believe are well qualified to review the proposal.
Chapter II.C.2.a(4)(h), Cover Sheet, contains guidance on the procedure to follow if the specific location of an international conference is not known at the time of proposal submission. A parallel change has been made to Chapter II.C.2.j.
Chapter II.C.2.b, Project Summary, has been modified to remind proposers that only Project Summaries that use special characters may be uploaded in the Supplementary Documents section. Such Project Summaries must contain separate headings for Overview, Intellectual Merit and Broader Impacts or the proposal will be returned without review.
Chapter II.C.2.d(iii), Results from Prior NSF Support, has been revised to reflect that the information must be provided for any PI or co-PI that has received NSF funding with a start date in the past five years (including any current funding and no-cost extensions). Information also has been added on which types of NSF awards must be reported on in this section of the proposal.
Chapter II.C.2.g(i)(b), Salaries and Wages, has been updated to parallel the language in 2 CFR § 200.413 on administrative and clerical salaries and wages.
Chapter II.C.2.g(v), Participant Support, has been supplemented with information on the types of costs that may be proposed and under what scenarios they are allowable.
Chapter II.C.2.g(vi)(f), Visa Costs, has been removed now that the Uniform Guidance contains coverage on this topic.
Chapter II.C.2.j, Special Information and Supplementary Documentation, now specifies the format that must be used for letters of collaboration.
Chapter II.D.5.b, Collaborative Proposals, reminds proposers that should a collaborative proposal from multiple organizations be awarded, both the lead and non-lead organizations are required to submit separate annual and final project reports.
Chapter II.D.7, Proposals Involving Vertebrate Animals, contains updated guidance on the information that must be provided in the Project Description for projects that involve use of vertebrate animals and the procedure to follow if IACUC approval has not been obtained prior to submission. For some types of vertebrate animals (e.g. non-human primates), additional review may be required.
Chapter II.D.9, Conference Proposals,has been supplemented to include information on the types of costs that may be proposed for conferences and under what scenarios they are allowable.
Exhibit II-1, Proposal Preparation Checklist, has been updated to reflect the changes made to the GPG and NSF’s electronic systems and streamlined to emphasize the most relevant items. Proposers are strongly encouraged to conduct an administrative review prior to submission, to ensure that proposals comply with the instructions in the GPG and/or the program solicitation, in the format specified.
Chapter III.E, Funding Recommendation, coverage on award abstracts and titles has been updated for consistency with NSF notices to the community on transparency and accountability.
Chapter III.F, NSF’s Risk Management Framework and the Decision to Award or Decline Proposals, has been supplemented with language regarding NSF’s implementation of the Federal Awardee Performance and Integrity Information System. The risk-based framework cumulative threshold has increased from $200,000 to $225,000 for proposers who have not received NSF funding in the last five years.
Significant Changes to the PAPPG Part II, Award and Administration Guide (AAG)
Chapter I.D.3.c(ii)(c), NSF Awards, has been revised to reflect that requests for NSF-approved extensions submitted after the grant end date must include justification for why they were not submitted earlier.
Chapter II.A.2, Grantee Notifications to NSF and Requests for NSF Approval, has been revised to state that, with the exception of significant changes in methods or procedures and significant changes, delays or events of unusual interest, all notifications and requests must be electronically signed and submitted by the AOR via use of NSF’s electronic systems.
Chapter II.D, Technical Reporting Requirements, has been revised to state that, in the case of annual project reports, the reports should be submitted no later than 90 days prior to the end of the current budget period. For final project reports and project outcomes reports for the general public, reports should be submitted no later than 120 days following expiration of the grant. Grants will be financially closed out on the first day of each month for all awards with end dates of 120 or more days prior to the financial closeout day. Parallel changes have been made to section II.C.3 with regard to annual and final cost sharing reports.
Chapter III.E, Award Financial Reporting Requirements – Final Disbursement Reporting, Consolidated Listing of Program- and Cost-Related Grantee Notifications to, and Requests for Approval from, the National Science Foundation, has been revised to reflect that grantees must liquidate all obligations incurred under their awards not later than 120 calendar days after the award end date and that NSF will financially close awards 120 days after the award end date.
Chapter VI.B.5, Life Sciences Dual Use Research of Concern (DURC), is an entirely new section and serves, in conjunction with coverage in the GPG, as NSF’s implementation of the US Government Policy for Institutional Oversight of Life Sciences Dual Use Research of Concern.
Chapter VI.D.2.c, Public Access to Copyrighted Material, is an entirely new section which provides information on NSF’s Public Access Policy. This policy also is referenced in Chapter VI.E.1 on publication and distribution of grant materials.
Clarifications and Other Changes to the AAG
Chapter II.B.2.e and 3, Changes in Project Direction or Management, has been updated to reflect that, when a grant is being transferred, if funding is requested to support a postdoctoral researcher, a mentoring plan must be provided and the PI must report on the mentoring activities in their NSF project reports. The same procedures must be followed if a request to subaward, transfer or contract out part of an NSF award includes funding to support a postdoctoral researcher and the original proposal did not include a mentoring plan.
Chapter III.D.3, Interest Earned on Advance Payments, has been updated with guidance that implements the applicable portions of 2 CFR § 200.305 on interest income.
Chapter V.A, Basic Considerations, has been supplemented with language noting that NSF policies which have a post-award requirement are implemented in the grant terms and conditions.
Chapter V.B.2, Administrative and Clerical Salaries & Wages Policy, is a new section that articulates when direct charging of these costs may be appropriate, in accordance with 2 CFR § 200.413.
Chapter V.D, Indirect Costs, has updated the language on predetermined rates in order to conform to the coverage in the Uniform Guidance. In addition, it discusses under what circumstances NSF may elect to set award specific rates.
Chapter V.F.4, Passports and Visas, has been revised to refer to the Uniform Guidance for coverage on visa costs.
Chapter VII.A.2, Suspension and Termination, has been supplemented with language regarding NSF’s implementation of the Federal Awardee Performance and Integrity Information System.
Chapter VII.B.3, Informal Resolution of Grant Administration Disputes, contains revised procedures to be followed when a grantee disagrees with or disputes a post-award decision made by an NSF Grants and Agreements Officer.