Written By: Viraj Parmar, JD
Office of Sponsored Programs
The National Science Foundation (NSF) recently changed and clarified numerous sections within its Proposal and Award Policies and Procedures Guide (PAPPG). As many of our researchers and staff know, the PAPPG consists of two parts:
- Part I, titled NSF Grant Proposal Guide (GPG), contains NSF’s proposal preparation and submission guidelines. The GPG provides guidance for the preparation and submission of proposals to NSF.
- Part II, titled NSF Award and Administration Guide (AAG), contains guidance on managing and monitoring the award and administration of grants and cooperative agreements made by the Foundation. Coverage includes the NSF award process, from issuance and administration of an NSF award through closeout.
Both Parts I and II are affected by NSF’s recent changes, all of which clarify the intended meaning of a sentence or section and ensure consistency throughout NSF systems and policy documents. And because the PAPPG, in conjunction with NSF’s Grant General Conditions, serves as the Foundation’s implementation of 2 CFR § 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, researchers and staff should appreciate and familiarize themselves with each revision.
The new PAPPG, including the changes and clarifications highlighted below, will be effective for proposals submitted, or due, on or after January 25, 2016.
- SIGNIFICANT CHANGES TO PART I INCLUDE THE FOLLOWING:
When to Submit Proposals
The PAPPG 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. Based on our experience with NSF proposals, it is our expectation that this requirement will be strictly enforced.
How to Submit Proposals
The PAPPG now requires that an Authorized Organizational Representative (AOR) provide the proposal certifications concurrently with submission of the proposal. In addition, proposal file updates and revised budgets must be signed and submitted by an AOR and only an AOR can perform a withdrawal function on behalf of a proposing organization. It has long been OSP’s practice to provide the proposal certification concurrent with the submission of the proposal, so this change should not affect OSP or researchers on campus.
Collaborators & Other Affiliations Information
NSF has introduced a new, single-copy document requiring each senior project personnel to provide information regarding collaborators and other affiliations. Note that this information used to be provided as part of the Biographical Sketch. Furthermore, the new format no longer requires proposers to identify the total number of collaborators and other affiliations when providing this information.
Biographical Sketch(es)
The new PAPPG continues to allow researchers to use the third-party solutions to develop a biographical sketch. However, submitted information must be compliant with NSF proposal preparation requirements. In addition, the new PAPPG with respect to biographical sketches states that it is no longer allowable for the biographical sketches of all senior personnel to be grouped together in a single PDF file. Rather, biographical sketches must now be uploaded separately for each individual identified on the proposal as senior personnel. But biographical sketches for Other Personnel and for Equipment proposals should be uploaded as a single PDF file in the Other Supplementary Documents section.
Current and Pending Support
The PAPPG now requires current project support be listed in the Current and Pending Support section of the proposal. This includes internal funds allocated toward specific projects. Also noteworthy is that the PAPPG no longer allows for current and pending support of all senior personnel to be grouped together in a single PDF file. Rather, current and pending support must be uploaded separately for each individual identified on the proposal as senior personnel.
Dual Use Research of Concern (DURC)
An entirely new section titled Dual Use Research of Concern has now been added to the NSF Grant Proposal Guide (GPG). This section indicates that proposing organizations are responsible for identifying NSF-funded life sciences proposal that could potentially be considered dual use research of concern as defined in the US Government Policy for Institutional Oversight of Life Sciences Dual Use Research of Concern and for compliance with the requirements established in that Policy.
- SIGNIFICANT CHANGES TO PART II INCLUDE THE FOLLOWING:
NSF Awards
The PAPPG 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.
Grantee Notifications to NSF and Requests for NSF Approval
The new PAPPG now states 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.
Technical Reporting Requirement
The PAPPG 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 the 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.
Award Financial Reporting Requirements – Final Disbursement Reporting
The PAPPG 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.
Life Sciences Dual Use Research of Concern (DURC)
The PAPPG now contains an entirely new section, which 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.
Public Access to Copyrighted Material
The PAPPG now contains 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.
The above is a list of the significant changes made to the PAPPG. However, NSF made additional changes and clarifications to a number of sections of both the GPG and AAG sections of the PAPPG. The full listing of these changes and clarifications can be found at: http://www.nsf.gov/pubs/policydocs/pappguide/nsf16001/sigchanges.jsp
A full copy of the PAPPG can be found on NSF’s website at: http://www.nsf.gov/publications/pub_summ.jsp?ods_key=nsf16001
General information about NSF programs may be found on the NSF website at http://www.nsf.gov/funding/browse_all_funding.jsp. Additional information about special requirements of individual NSF programs may be obtained from the appropriate Foundation program office. Information about most program deadlines and target dates for proposals are available on the NSF website at and target date information also announcements and solicitations and on relevant NSF Divisional/Office websites.