The National Science Foundation has recently updated their Proposal and Award Policies and Procedures Guide (PAPPG). Many of the changes made in the PAPPG are related to the issuance of the new Uniform Guidance (2 CFR § 200) and references within the Guide have been updated to reflect the new Uniform Guidance rather than the old OMG Circulars. Matters related to cost principles also now reflect the parameters of the Uniform Guidance (including allowability of certain items of cost).
NSF has also made several other changes to the PAPPG that could affect proposal development. In concert with the update of the PAPPG, NSF’s Fastlane system will also begin to run an additional 24 automated compliance checks on proposals to ensure that they follow the appropriate guidelines. (Such checks will run for proposals submitted in response to the GPG, Program Announcements and Program Descriptions, but will not run for proposals responding to Program Solicitations.) Principal Investigators and anyone assisting them with proposal development should be aware of these changes, and the Fastlane compliance checks that accompany them.
A summary of these changes (and accompanying new Fastlane validations) is provided below:
Proposal Content/Sections
Project Description
Project Description/Results from Prior NSF Support
The Project Description must still contain a section on Results from Prior NSF Support if any PI or co-PI has received NSF funding in the past 5 years, regardless of whether the support was directly related to the proposal or not. Consult the NSF PAPPG for full information on this requirement. It is the case that the current PAPPG further clarifies that the required listing of publications resulting from such an NSF award must provide a complete bibliographic citation, either in this section of the Project Description or in the References Cited section of the proposal.
Biographical Sketch(es)
The new PAPPG underscores that Biographical Sketches should not include personal information. Additionally, new information is being requested in the Professional Preparation section – the location of the individual’s undergraduate, graduate, and postdoctoral institution(s) must be provided. The new PAPPG also clarifies that the total number of collaborators and co-editors, and graduate advisors and postdoctoral sponsors, must be identified in the appropriate areas in the Collaborators & Other Affiliations section.
Supplementary Documentation/Letters of Collaboration
The PAPPG clarifies the use of letters of collaboration (formerly called letters of commitment) and clearly states that such letters should be limited to stating the intent to collaboration and should not contain endorsements or evaluation of the proposed project. Proposals which do not conform to these instructions will be returned without review.
Requirements related to inclusion of Subawards
The Uniform Guidance requires proposing organizations to make a case-by-case determination regarding the role of a suberecipient versus a contractor/vendor for each agreement. Inclusion of a subaward in a proposal or submission of a prior approval request for the addition of a subaward will be considered to document the organizational determination that is required. The PAPPG also clarifies that a proposed subaward budget should use that organization’s negotiated indirect cost rate or the deminimis 10% rate if they do not have a federally-negotiated rate. The PAPPG also specifies that all subrecipients named in a proposal must have a DUNS number and must be registered in Fastlane.
Budget-related items
- Salary / Administrative Salaries – The PAPPG has been updated to describe the conditions under which inclusion of administrative or clerical salaries may be appropriate on a proposal budget, as allowed by Uniform Guidance.
- Travel –This section has been revised to note that all travel (both domestic and foreign) must now be justified.
- Participant Support – This section has been clarified to indicate that categories of participant support other than those described in the Uniform Guidance must be justified in the budget justification and that they will be closely scrutinized by NSF. Funds requested as Participant Support costs cannot be rebudgeted without NSF prior approval.
- Materials & Supplies – This section now includes a description of computer devices, including when computing devices are considered as supply line items.
- Budget Justification – The budget justification is now limited to 3 pages and must be uploaded as a file. The budget justification can no longer be entered as text. Each subaward must also include an uploaded budget justification which meets the 3-page limit. The NSF Fastlane system will validate that the budget justification is an uploaded file and will check the file against the 3-page limit.
Other Budget-related Fastlane validations:
The NSF Fastlane system will run additional compliance checks related to proposal duration and requested amounts. For example, the system will enforce a maximum requested amount of $200,000 for a RAPID proposal and $300,000 for an EAGER proposal.
The “Residual Funds” line (Line K) will not be editable for any program other than the SBIR/STTR program and will thus not be editable for any Emory proposals. It will be renamed to “Small Business Fee.”
- General Statement on Proposal Acceptance
The new NSF PAPPG also contains a significant change in Chapter IV.B for Proposals Not Accepted or Returned Without review. This section lists a variety of reasons a proposal could be returned without review or not accepted by NSF. However, the current version of the PAPPG strengthens the language to state that a proposal will be returned without review for any of the reasons listed rather than stating that a proposal may be returned without review for any of the reasons listed. It is important to note that NSF includes the following as one of the potential reasons for return: “The proposal does not meet NSF proposal preparation requirements, such as page limitations, formatting instructions, and electronic submission, as specified in the Grant Proposal Guide (see GPG Chapters II.A, II.B, and II.C), the NSF Grants.gov Application Guide or program solicitation.” It is our experience that NSF very strictly enforces all guidelines in detail and OSP recommends strictly adhering to all guidelines as closely as possible.
- Miscellaneous updates for specific proposal types
Proposals for Equipment – The PAPPG has been revised to remove the requirement to include a References Cited section for equipment proposals. Additionally, the Facilities, Equipment and Other Resources section must include a brief description of support services available.
Proposals Involving Human Subjects – The PAPPG now clarifies that IRB approvals “in concept” or conditional approvals are not acceptable; only full IRB approvals are accepted. (A proposal may be submitted with IRB approval still pending.) Guidance is also provided on the procedures to be followed if IRB approval cannot be obtained at the time of award because development of the human research activities and protocol requires preliminary work to take place.
Proposals for Conferences – The PAPPG now specifies that NSF funds may not be spent for meals or coffee breaks for intramural meetings. Budgets for conference grants should be prepared with close attention to GPG Chapter II.C.2.g. Additionally, Facilities, Equipment, and Other Resources information is now required for conference proposals.