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RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

Association of
American
Medical
Colleges
(AAMC)

Other

In general, respondents supported, as does the AAMC, the goal of standardizing a format for interim research progress Thank you for your comment.
reports across federal agencies for the purposes of simplifying or streamlining reporting procedures. No concerns were
expressed about the categories or elements for the mandatory and optional information sought in the new format.

AAMC

Other

We have insufficient response to estimate the extent of the additional administrative burden imposed by the RPPR or to This comment has been noted. The work group will do
provide informed proposals for reducing this burden, but we need to caution that respondents uniformly believed that the everything possible to consider the burden in development
requested information in total would “substantially” add to the already prodigious paperwork burden under which our
of the RPPR format.
investigators labor. The AAMC thus shares COGR’s overriding concern for the extent to which agencies may mandate
“optional” reporting or create further requirements.

Arizona State
University
(ASU)

Other

It is considered a strength that the proposed format generally follows NSF reporting categories since this would result in The RPPR collects more extensive data than is currently
NOAA is ok with this.
less change for researchers currently involved with NSF funded projects. Additionally, standardizing the report format in collected, but the work group thinks both agencies and
a uniform manner would be beneficial to investigators and their staff since they would no longer need to become familiar grantees will receive better information. There may be
This puts more structure around pieces that used
with the various formats of individual agencies. However, since the proposed report format is very comprehensive, it will additional burden on at least the first report for the project, to be narrative. We could live with this.
result in an increased reporting requirement for those investigators working with agencies not currently requiring as
but we expect to repopulate the next form with any
much detail in their interim reports.
information that carries over. The work group thinks this
At ED, we have a general performance report and
improved report will help agencies collect better information. that format is not useful for our research
programs. This report really fits better for those
programs.

ASU

Other

It was suggested to trim down the interim progress report to just a summary of the year's progress in research, a brief
summary of future plans, lists of publications/patents, and a broader impact/outreach statement…eliminating any other
subcategories.

Only one section is mandatory, while the other sections are
optional. This combination of mandatory and optional
sections gives agencies the maximum flexibility to collect
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

While we understand the desire to keep this to the
absolute minimum, that will not suffice for the kind
of information NSF needs.
Let's discuss mandatory versus optional.
Agencies can pick and choose what they need to
perform their reviews for a specific program. This
could vary from agency to agency within program
to program.
One mandatory while others optional allow the
maximum flexibility to collect the information
required without overburdening others.

ASU

Other

ASU

Instructions Generally the instructions are considered straightforward and easy to understand.

Thank you for your comment.

No response required.

ASU

Instructions Improvement in the electronic flow for completing sections of the report without having to refer to pages of instructional
materials is desired in order to make the process of completing the report more intuitive.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

This comment will need to be deferred to those
developing the electronic systems. Our
requirement was to create the report, not the
system.

General
Page 1

It is felt that the single mandatory category of "Accomplishments" is the key element to be reported in the progress
report and that the others should be optional.

source.xlsx

Only one section is mandatory, while the other sections are This is how the format has been designed, so we
optional. This combination of mandatory and optional
are comfortable with this.
sections gives agencies the maximum flexibility to collect
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

10/17/2026

RPPR Comment Tracker
Comment
Source
ASU

Comment
Type
Other

General Comment

Comment Response

The lack of standardization of agency progress reports is an administrative burden for faculty investigators and
The workgroup agrees that testing with the impacted
electronic submission of the progress reports will lend itself to a more efficient process. However, not having a common community is worthwhile. This is an electronic system
solution for collecting the information electronically will be confusing to the investigators and will add to that burden. We implementation issue. The workgroup will forward your
support initially having federal agencies test and implement this with universities participating in the Federal
comment to those who develop the electronic solution.
Demonstration Partnership and then when a common agency solution is determined to implement it with all universities.

Notes
We have to get the FDP to agree to this. We also
need to know which agency will host this because
FDP would not be able to host. This will definitely
be on the agency side, so who would volunteer?
Absolutely a good idea to make sure all of the
kinks are out and I hope that any electronic
development would do testing.
This goes back to idea that Grants.gov was
supposed to be find, apply, and report, which is
not going to happen.
Would FDP consider piloting the non-electronic
version?
There would be some time where we will need to
use both paper and electronic. Some people will
continue to need to use paper.

ASU

Other

Access to view the PI submitted electronic progress reports is desired by institutional officials that have accepted the
federal funds and provide oversight in order to ensure that deliverables such as progress reports are provided in a
timely manner.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

Electronic issue.
Ties into who should submit - PI or AOR. This
should be kept in mind for any agency doing
electronic implementation.
Is there a question about organizations wanting
access to their reports. They did not want to
submit, they wanted access.

ASU

Other

Faculty investigator responses indicated that downloadable fillable forms are preferable to web-based forms based on
their experiences with NSF FastLane which they indicated still has several awkward problems with annual reports and
drop-down menus which are not very flexible.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

This comment not consistent overall with other
comments we have received.
We will pass this on, but we get very few requests
for downloadable forms.
The faculty who sat on the webcast said they
wanted web based forms.

ASU

Other

Administrators indicated that web-based forms would be preferable because it can provide a more user friendly format
without the need for access to multiple software programs or upgraded programs. A caveat was that having the ability
to create a printable copy from a web-based form would be necessary in order to retain a copy of the form for
institutional and investigator record keeping purposes.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

This comment not consistent overall with other
comments we have received.
We will pass this on, but we get very few requests
for downloadable forms.
The faculty who sat on the webcast said they
wanted web based forms.

Columbia
Other
University
Lamont-Doherty
Earth
Observatory
CU/LDEO

General
Page 2

In principle, the categories for which information is requested are all reasonable, in that they represent beneficial
The work group will keep this in mind as it develops the final We will keep this in mind as we develop the final
activities supported by federal funding agencies. In practice, reporting has become part of a giant vice that is squeezing version of the RPPR. Only one section is mandatory, while version of the RPPR.
researchers from all directions. On the one hand, funding is becoming more difficult to secure, as agency budgets fail to the other sections are optional. This combination of
keep up with inflation, or worse, decline in actual dollars. At the same time, the number of researchers competing for
mandatory and optional sections gives agencies the
We have flexibility of mandatory versus optional in
funding is increasing at a rapid pace. Consequently, agencies expect researchers to "do more for less", which leads to maximum flexibility to collect only the information required, order to minimize the burden.
a real situation where funding is insufficient to complete the proposed research. On the other hand, reporting
without overburdening others with unnecessary
requirements and other administrative obligations are constantly increasing. The combined effect is that it is becoming requirements. Agencies can select the information needed
more and more difficult to complete research projects given the funds that are awarded by agencies.
to perform its reviews for a specific program.

source.xlsx

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

My general recommendation is to minimize the reporting to include only elements that are absolutely essential. The real
impact of federally funded research, and the value to the nation, comes from completing the activities (e.g., publishing
papers, creating new education initiatives, etc.), not from reporting on them. My plea is to minimize the amount of
administrative paperwork so as to maximize the amount of time that researchers are able to devote to the primary
activity.

To illustrate, the time needed to prepare an annual report is estimated to vary between 5 and 16 hours (see Section IV "Paperwork Reduction Act" in the text extracted from the Federal Register and poster at http://www.nsf.gov/bfa/dias/policy/rppr/fedreg.pdf). I have m

U.S. Department
of Commerce-National Institute
of Standards
and Technology
DoC/NIST

DoC/NIST

Context: NIST has grant-making authority with respect to a range of research and science programs focused
Thank you for your comment.
predominantly on measurement science and standards. In addition, NIST has two statutory extramural programs.
Comments from the NIST laboratories will begin with "Lab:" and comments from the extramural programs will begin with
"Extramural:"
Other

Lab: We applaud the new standardized progress report because we believe its concise format will result in saved time
for the grant recipients, and also allow the federal government to more effectively collect grant data across various
agencies.

Thank you for your comment.

Other

Lab: We note that much of the information on the report is actually optional. So that raises two questions for us: 1.
Who determines if it is optional information or not--the Federal agency or the recipient?; 2. and when would it be
determined? At the time of the award?

The awarding Federal agency determines which categories The Federal agency determines whether
are required or optional. This should be determined as early categories are optional or required. This should
as possible, preferably at the time the funding opportunity is be determined as early as possible, preferably at
issued.
the time the funding opportunity is issued.
This should also be addressed in the agency
instructions for implementing the form.
We should revisit this language and strengthen it.
Make clear that agencies are the ones to make
this mandatory or optional.

DoC/NIST

Other

Lab: The listing of information requirements looks complete, yet the agency has plenty of flexibility to streamline the
Thank you for your comment. This part of the clearance
reports it will require depending on the project and eliminate many of those requirements. All but one of the major
process gives the recipient community an opportunity to
categories of information are considered to be optional, and the only mandatory category, "Accomplishments," has
provide its feedback on the form.
several subcategories, which are also essentially optional. Therefore, we do not think that the reporting format will add
significantly to the administrative burdens either of agencies or awardees, particularly if the format is standardized and is
used for different types of projects. If it has not already been done, before publication, the format should be reviewed by
a panel of people in the grant recipients community, not only by government agencies.

DoC/NIST

Other

Extramural: The following reporting categories, currently suggested as optional, should be considered as mandatory
reporting elements: products/outcomes, participants, impacts.

DoC/NIST

Instructions Extramural: If the awardees pay attention to the instructions provided within the format it would eliminate the PMT
Thank you for your comment.
interpretations of percentage of progress evaluated against the tasks and milestones on a quarterly basis. This will help
in the consistency between the PMTs interpretation of the amount of progress and the actual

I think they are saying they like it.

DoC/NIST

Other

Extramural: All electronic format is an advantage. Downloadable or web based is not all that important so long as
confidentiality can be guaranteed.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

Thank you. We will be providing these comments
to the people developing the system.

DoC/NIST

Other

Extramural: Information provided will make it easier to track diffusion on an on-going basis.

No response required.

General
Page 3

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The awarding agency can make it required if they desire,
but the work group would like to maintain the flexibility for
those agencies who do not deem this necessary or
appropriate.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

DoC/NIST

Other

Extramural: The first report will take a lot of time to complete, but subsequent quarterlies should be far easier and less
time consuming.

DoC/NIST

Other

Extramural: Much of the superfluous information is "up front," which implies that it is the MOST important information. There is no prescribed order. Each agency may determine
Actually most of the important information, is part of the optional section and typically at the end, which implies even of the order. If an agency determines that an optional section
lower importance. So it might be very difficult to teach our program priorities because the format of the reporting will
is mandatory for its recipients, the order may be influenced.
appear to subconsciously undermine it each and every time it is used.

DoC/NIST

Other

Extramural: We believe our typical award recipients would find this template very tedious and burdensome because of
having to wade through so much that isn't very relevant.

Only one section is mandatory, while the other sections are If agencies don't want to ask for something,
optional. This combination of mandatory and optional
agencies don't have to ask for this. It can be a
sections gives agencies the maximum flexibility to collect
very short report.
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program.

DoC/NIST

Other

Extramural: We support the idea and would be interested in participating in the Beta testing.

Thank you. The work group will provide this comment to the
agencies developing electronic systems so they know that
NIST would like to participate.

DoC/NIST

Other

Extramural: If it is possible for the template to be more of a collection of "modules" that each program selects and puts This is meant to be broad to allow maximum flexibility so
in an order that makes sense for the program's mission and priorities, this could be more easily tailored to reflect the
agencies can use it for all research and research related
program priorities relevant to us...this template is clearly focused toward a basic research program with a major program programs.
priority of education impact from the research, not impacts on society from the research, and the actual structure of the
template implies it heavily.

DoC/NIST

General
Page 4

Other

The workgroup agrees. There may be additional burden on We agree. We believe the advantages as we go
at least the first report for the project, but the workgroup
through the process is worth the burden being
expects to repopulate the next form with any information
imposed.
that carries over. It thinks this improved report will help
agencies collect better information and will be less
burdensome. The RPPR collects more extensive data than
agencies currently collect, but our grantees feel like both
agencies and grantees will receive better information.

There is no prescribed order. Agencies will
determine the order. This highest category is
mandatory which makes the question confusing. If
an agency determines something is mandatory,
that influences the order.
We tried to make it clear that the format is going
to be difficult to provide in paper form.

As long as they use the categories we provide,
they can put it in whatever order they want.
Reality is that they are correct. This has been
focused on a basic research program. Not just
research, but research and related activities. This
is the broad stroke to put in maximum flexibility so
agencies can use it for all research and research
related programs.

Extramural: This template doesn't really cover the reporting requirements as stated in OMB Circular A-110. Outline of There are two reporting forms, RPPR and PPR. Agencies Isn't this something we are trying to get away
the template and some comments by section compared to the reporting requirements in the DOC regulations 15 CFR
should use the PPR for its programs that require this kind of from? If they want this, they should be using the
Part 14, which implement OMB Circular A-110, for programs that use cooperative agreements or fund research that is cost data. Agencies can select which report meets their
PPR, not RPPR. We have kept away from cost
beyond basic curiosity driven education oriented research. See regulations as copied below with bolded italics of things reporting needs.
issue. They have to say generically in the
that are not adequately addressed in the template, more specific comments follow to address these concerns: 14.51
changes section (if an agency opts to use this
Monitoring and reporting program performance. (d) When required, performance reports shall generally contain, for
section). We have stayed away from costs
each award, brief information on each of the following: (1) A comparison of actual accomplishments with the goals
because in some agencies this is a PI submission
and objectives established for the period, the findings of the investigator, or both. Whenever appropriate and the
versus and institution submission.
output of programs or projects can be readily quantified, such quantitative data should be related to cost data for
computation of unit costs.
Some agencies have not implemented that their
quantitative data be related to their cost data. Can
agencies address this specifically?
All we are allowing agencies to do is use the
instructions to clarify a requirement by using
additional program specific requirements. I
recommend they use the PPR for their programs
that require this kind of cost data. There are two
reporting forms. Agencies can select which report
meets their reporting needs.

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10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

(2) Reasons why established goals were not met, if appropriate. (3) Other pertinent information including, when
There are two reporting forms, RPPR and PPR. Agencies As above.
appropriate, analysis and explanation of cost overruns or high unit costs. (e) Recipients shall not be required to submit should use the PPR for its programs that require this kind of
more than the original and two copies of performance reports. (f) Recipients shall immediately notify the DOC
cost data. Agencies can select which report meets their
At ED, some components have asked for overall
operating unit of developments that have a significant impact on the award-supported activities. Also,
reporting needs.
expenditure for a grant. Is it possible for agencies
notification shall be given in the case of problems, delays, or adverse conditions which materially impair the ability
to add something around Federal expenditures?
to meet the objectives of the award. This notification shall include a statement of the action taken or contemplated,
To get cost data, can get this from the PPR. NIH
and any assistance needed to resolve the situation.
has recommended building an optional section for
the cost component. We would have to have
something in the instructions for using this that
institutions would provide that information.
Something like, "use of this section must be
submitted by an organizational representative.
This is addressed in PPR. Institutions are
concerned with providing that information. Some
agencies do not do it this way at all.

DoC--National
Oceanic and
Atmospheric
Administration
(DoC/NOAA)
DoC/NOAA

Other

This standardized progress report format contains most of the information necessary for internal reporting as well as
provides a good basis for the reporting of accomplishments.

Thank you for your comment.

Other

The flexibility to add program specific questions in the Optional Categories is appreciated and will allow the Program
Office to retrieve specific data necessary for internal reporting and program monitoring.

Thank you for your comment.

DoC/NOAA

Other

The standardized research report format provides detailed guidance and may be used as a template for progress
Thank you for your comment.
reports provided by research grant recipients. The report format may also serve as broad guidance for education grant
recipients who conduct research to educate and train students.

DoC/NOAA

Other

There would need to be a period of educating the grantees as to what the report is looking for, as grantees might not be The work group has noted your comment and it will be
currently collecting or quantifying data such as training and professional development under their present system
considered in the implementation of the RPPR format.
(RPPR., Page 3.)

Council On
Government
Relations
(COGR)

Other

The single mandatory category – Accomplishments – focuses the progress report on its key element – progress in the
science – and we urge agencies to give careful consideration before requiring any of the optional or agency-specific
categories.

COGR

Other

Our over-riding concern remains the provision allowing agencies to create agency or program specific mandatory
Different agency needs will require report flexibility and
We don't know what OMB's criteria are. This will
categories, report formats or instructions. We understand the need for flexibility to accommodate unique statutory or
agencies can use the RPPR to address any agency specific be the same for our competing application
program-specific reporting but we urge agencies to remember the goal of the Federal Financial Assistance Management needs.
systems.
Act to streamline and simplify financial assistance procedures. We recognize that the GPC can only propose and
We have to get approval from OMB on these
recommend report formats and we will look to the Office of Management and Budget (OMB) in its review and approval
forms and if OMB has forms, then different
of information collections to assist in achieving maximum uniformity. Our principal question to OMB will be what criteria
agency needs will require report flexibility and
it will use to assess and, if appropriate, permit agencies to impose non-standard requirements? We endorse the caution
agencies can use the RPPR to address any
to the agencies to minimize the degree to which they supplement the proposed standard categories. The goal of
agency specific needs.
achieving efficiencies and benefit to recipients through the standardization of reporting is lost with a broad proliferation
of agency-specific forms.

COGR

Other

We would include an additional caution to avoid “re-purposing” sections of the mandatory and optional categories as
The work group has noted your comment.
well. This process of re-purposing fields has plagued the electronic application submission process through Grants.gov
and we would hope to avoid this as we move forward with the reporting formats.

COGR

Other

The real lasting benefit of the standard Research Performance Progress Report will only be realized when it is available The work group agrees that testing with the impacted
for completion and submission electronically. The lack of standardization in progress reporting is the principal burden community is worthwhile. This is an electronic system
identified by investigators participating in the survey of administrative burdens conducted by the Federal Demonstration implementation issue. The work group will forward your
Partnership. Despite differences both in institutional and individual work environments, the faculty respondents reported comment to those who develop the electronic solution.
a similar set of top administrative burdens with progress reporting topping the list. Our experience is that the creation
and implementation of electronic solutions at the Federal level is a time-consuming process. Deferring implementation
of a standard format for progress reporting until there is a common solution for collecting the information electronically
would be disheartening to our investigators. We would urge the consideration of a rapid deployment of an electronic
solution as a demonstration project through the Federal Demonstration Partnership. Tapping into the expertise on
university campuses may speed the deployment of the solution.

General
Page 5

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The work group has noted your comment.

Use the response already provided to FDP.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

U.S. Department Other
of Defense
(DOD)

The proposed format for interim performance reports [72 FR 63629, November 9, 2007] generally strikes a good
balance. It contains sufficiently detailed guidance on content to achieve greater standardization across agencies and
programs. At the same time, it provides needed flexibility to be usable across those diverse agencies and programs.

Thank you for your comment.

DOD

Address the format as a research policy matter, rather than an issue for a type of funding instrument. Given that the
Research Business Models Subcommittee is an arm of a research policy rather than grants policy body, it seems
curious that we developed a format for reporting on research program performance and then proposed it for comment
only for grants. It seems that we might increase the benefit of the format if we viewed it more broadly as being related
to the program, rather than to grants, contracts, or other legal instruments used to transfer program funds. DoD and
some other agencies carry out research programs using both assistance instruments and procurement contracts
(selecting for each project the appropriate legal vehicle).

If DOD would like to use this for contracts, it may do so.
That flexibility is available.

Other

Notes

Similarly, universities and other organizations receive procurement contracts, as well as assistance instruments, for
If DOD would like to use this for contracts, it may do so.
research performance. They therefore could benefit more from the reporting format if agencies’ use of it were not
That flexibility is available.
limited to their assistance awards. We believe the format appropriately can be used for basic research, at least some
applied research, and perhaps some advanced research, irrespective of the kind of agreement used. Although an
individual agency can in principle expand the format’s use for its own programs, RBM will better serve the community by
identifying as a matter of Government‑wide research program policy—not grants policy—all of the programmatic types
for which we think the format would be appropriate.

RECOMMENDATION I.1: Specify the format’s use for all basic research and encourage its use, to the extent
practicable, for applied and advanced research (also known as pre‑competitive technology development), especially for
projects carried out by universities and other non‑profit organizations.

We deliberately did not define for an agency what
research and research related is. They already
have the flexibility to do this. This should be
clarified in the agency specific instructions.
DOE would not accept this for contracts.
If we try to specify what type of research, it takes
away the flexibility of using the RPPR or PPR.

DOD

Other

Provide more data, rather than text, fields. It is costly and burdensome to import text to populate agency data systems. Thank you for your comment. This is an electronic system
RECOMMENDATION I.2: The format should include data fields for information that any agency wishes to have as data. implementation issue. The work group will forward your
To collect data on journal articles, DoD awarding offices request data fields for article title and journal name, volume,
comment to those who develop the electronic solution.
date, and page number.

DOD

Other

Provide for attachments, such as graphics, that can not be transmitted as text or data. RECOMMENDATION I.3:
Explicitly state in the instructions that the format permits attachments of supplementary material not suitable for text or
data fields

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

This is an electronic system implementation issue
that will be forwarded at the appropriate time.
Except where agencies need to submit data in the
form, an attachment is ok. This is an
implementation issue.

Disgruntled in
Houston

General
Page 6

Other

It would be very useful for a Congressional Oversight to take a look at the practice of release of findings from
investigations that were sponsored by Federal grants. Some Federal agencies (ATDSR, to be precise) demands that
researchers not publish results until the agency gave them a clearance. Meanwhile agencies have their own agendas
and their own turf war. Research investigators and the scientific discovery are lost in this war somewhere.

These issues should be addressed with the Agency for
Toxic Substances and Disease Registry (ATSDR). The
work group will refer your specific concerns to ATSDR.

To exemplify, for reason I cannot understand, ATSDR seeks the so-called “courtesy” approval from CDC (???) for
These issues should be addressed with the Agency for
release results of research on the grants they sponsored (there is no “courtesy” reciprocation on the side of CDC).
Toxic Substances and Disease Registry (ATSDR). The
Meanwhile CDC has “chip on their shoulders,” as the agency considers some areas of research (ex, birth defects) their work group will refer your specific concerns to ATSDR.
“turf” and therefore, blocks requests for release of investigations sponsored by ATSDR.

We have noted your comment.

Meanwhile, the public has no opportunity to even glance results and does not receive much needed information. Please These issues should be addressed with the Agency for
disallow this outrageous practice of demanding release rights to the intellectual discovery in exchange for Federal grant Toxic Substances and Disease Registry (ATSDR). The
money. This is not the purpose of research, and scientists should not be pushed around by bureaucracy in exchange for work group will refer your specific concerns to ATSDR.
much needed federal dollar.

We have noted your comment.

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RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

U.S. Department Instructions The proposed Research Performance Progress Report (RPPR) intermingles general background information with
The work group has noted your comment.
of Education
instructions. We recommend having one “background information” section and then a separate “instructions” section for
(ED)
respondents. Even though the current draft includes sections that say “instructions,” the reader has to search for them
and it remains unclear what information is provided for reader edification and what information requires a response.
This could lead to inconsistent responses. Separate sections would resolve the problem.

This is associated with trying to provide a format
via this medium. Until you can see how an
electronic system can do this, it would be difficult
to see how this really works. People were really
thinking about this like a form. It is a challenge for
those who are viewing this for the first time and
don't see the benefits or this format.

ED

Other

There was a typo in the notice and after working
with OMB, they printed a correction.

ED

Instructions We recommend that the form clarify how respondents with multiple projects within one award will input their data. For Different agency needs will require report flexibility and
Agency specific requirement.
example, many National Institute on Disability and Rehabilitation Research (NIDRR) grantees conduct multiple projects agencies can use the RPPR to address any agency specific
in multiple categories (e.g., research, training, technical assistance, dissemination). There should be a clear and
needs.
established way to enter data for each project in the award

ED

Other

While this document was published in the Federal Register, we cannot determine whether this is one of the notices
required under the Paperwork Reduction Act of 1995 (PRA) or, if it was published under the PRA, whether it was the
first or second required PRA notice. We note that the comment period is 60 days, which suggests this is the first PRA
notice. If this document was published pursuant to the PRA, we recommend that the next notice clarify that it is
published under that Act.

ED

Other

The notice is not clear regarding the source of the burden hour estimate of 5 to 16 hours. Is this estimate based only on This estimate is based on all agencies' input on what the
NSF grantee reports or reports submitted to all agencies? If the estimates are based only on NSF experience, we
burden may be.
strongly encourage NSF to provide estimated burden hours for each agency or provide one estimate of average burden
hours based on all agency experience with reporting. This effort is essential so a single form, with a single OMB control
number can be approved for use by all agencies.

This estimate is based on all agencies input on
what the burden may be.

ED

Other

The notice does not discuss record keeping burden for the proposed RPPR. Given the fact that the reports are
designed to collect data only regarding the most recent reporting period, we believe that grantees would have to
maintain past reports, so there will be at least some record keeping burden associated with the RPPR. We strongly
urge NSF to include an estimate of the record keeping burden in the final PRA notice.

We will still have to have a burden estimate in the
final PRA notice.

ED

Other

The format for the form was not clear from the file that was made available for comment. The draft RPPR describes
This is a format, not a form. Agencies can define page
each category and provides instructions on each category, but it does not give notice of how much space will be
limits when appropriate.
available for each category. Persons responsible for reporting need to know the maximum size of each category. In a
paper form, the space allocation is clear through visual inspection and instructions that inform reporters of whether they
may provide additional information on a separate sheet of paper. In the electronic context, a filer needs to know how
many alpha and numeric character spaces are available for each category. Please specify the size of each reporting
field. We recommend that the next Federal Register notice for the RPPR make available to the public, both a paper
version of the form and a document that describes how many character spaces would be available for each field of the
expected electronic format.

The second sentence of the second paragraph on page 6360 of the Federal Register notice states: “Award recipients Thank you for your comment. There was a typo in the
would be required to report on the mandatory category and may be required to report on the mandatory category and
notice, which has now been addressed.
may be required to report on any of the optional categories...” (italics added.) Further, page 1 of the draft RPPR states,
“Federal agencies will direct recipients to report on the mandatory category and may direct them also to report on the
optional categories, as appropriate.” Based on this, it appears that the words “may be required to report on the
mandatory category,” above, can be deleted. In any case, the language needs to be clarified.

This is the first 60 day PRA notice.

There will be a burden estimate in the final PRA notice.

This is the first 60 day PRA notice. OMB cleared
this as a PRA notice.

This is all over the map on what agencies expect.
They keep thinking this is a form.
Make clear that if agencies require it in a paper
format, how would that work?
Would there be a character limitation if a system
is used?

ED

Other

The proposed RPPR does not explain the implications under the PRA for agency inclusions of added categories or
As specified in the Federal Register notice, agencies may It says in one place that this will need to be
additional instructions. Will additional instructions require PRA approval by OMB? We assume that added categories of develop additional agency- or program-specific reporting
cleared by OMB.
reporting will require PRA approval by OMB. However, will agencies be required to vet additions and instructions
categories and instructions, however, to maintain maximum
through the NSTB RBM, the Grants Policy Committee for PL 106-107, or some other process before going to OMB or
uniformity, agencies will be instructed to minimize the
can an agency go directly to OMB?
degree to which they supplement the standard categories.
Additional agency- or program-specific reporting categories
are subject to review and clearance by OMB via the PRA
process. Prior to submission to OMB, however, agencies
will be requested to consult with the RBM subcommittee, to
ensure non-duplication of like data by the research
agencies.

ED

Other

The draft format does not contain the required language regarding effect of not displaying a currently valid OMB control The OMB clearance number will be on the notice.
number (5 CFR 1320.5(b)(2)(i) &(ii)) nor does it describe how the form will make that information available on or with the
form “in a manner that is reasonably calculated to inform the public” of that information. In other words, how and where
on a paper version or in the display of the electronic version would the RPPR display the OMB control number and the
required request for persons using the form to provide comment to OMB regarding the burden imposed by the form.

General
Page 7

source.xlsx

We have a way to show OMB clearance number,
but it will be different by electronic system.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

ED

Other

It is not clear from the notice when the drafters of the proposed RPPR anticipate that the form would be implemented by These are implementation issues that are yet to be
These are implementation issues that are yet to
agencies, once approved by OMB. Current ED research programs either use OMB approved program-specific
determined. Once the work group goes through the
be determined. Once we go through the
performance reports or use the standard ED 524B, Grant Performance Report
development of the format, implementation concerns will be development of the format, implementation
(http://www.ed.gov/fund/grant/apply/osep/continuationpackage2008/324.doc). Some programs have electronic data
easier to address.
concerns will be easier to address.
collection systems or databases that have been designed to collect and house data for a specific program. It would be
helpful to know the implementation timeframe for the RPPR and whether agencies are expected to implement the RPPR
No agency will be prepared to implement right
form for current grantees mid-project period or whether the form will only apply to new research grants awarded after a
away.
certain date. As noted above, it would be useful to know the expected procedures for obtaining approval for agency or
program specific categories or instructions for the RPPR in order for agencies to better gauge when the form can be
fully implemented for their research programs.

ED

Other

We also recommend that further information be provided regarding whether “specialized research grant” programs that It is up to the agencies to determine which programs are
use other OMB approved reporting formats instead of the RPPR will need to follow a certain procedure to become
research or research related programs.
exempt from using the RPPR.

We have not determined this for agencies.
Agencies should decide.

ED

Other

Additionally, the data requested in the proposed RPPR should allow for improved monitoring, management, and
reporting about the research activities. When designing the electronic system, we suggest that the developers explore
organizing the input screens around these different uses for the data.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

Thank you for your comment. We will forward
your comment to those who develop the electronic
solution.

Emory University Other

By in large I am happy with the draft format. It is critical that this form be simplified to its bare bones, and most of the
optional sections can be dropped.

Thank you for your comment.

Given how this format is created, agencies will
only be using the sections they feel they need to
determine appropriate progress. Some agencies
will only use the required section. The optional
sections are ones we want to retain.

U.S. Department Other
of Energy-National Energy
Technology
Laboratory
(DOE/NETL)

The stated objective of the initiative is “to establish a uniform format for reporting performance on Federally-funded
research projects” administered through research grants and cooperative agreements. Based on this objective, it is
most appropriate that the reporting format accommodate the fundamental principles of sound project management,
which all award recipients are expected to follow. These periodic reports must provide sufficient information for
Government program officials to assess progress toward project objectives within the context of the planned work
scope, schedule, and budget. Without timely and accurate progress reporting on research and development (R&D)
projects, it is not possible to satisfy requirements of the Government Performance and Results Act for evaluating
progress toward R&D program goals.

The work group agrees. This is consistent with what the
work group has attempted to do.

DOE/NETL

Other

The draft RPPR does not include sufficiently detailed content that would satisfy DOE project management policy and
OMB requirements to report, monitor and validate cost, schedule, and technical progress relative to the performance
baseline. This information is vital to DOE decision-makers.

If the RPPR is not suffcient, the PPR may be used, or an
They want monthly reporting, they want to see
agency may develop its own agency specific format, subject every reciept. Much more detail than they need.
to OMB approval.

DOE/NETL

Other

The standard approach to research progress reporting should also consider the frequency of reporting needed to satisfy The work group is keeping with the reporting requirements
project management and OMB requirements for monitoring and validating progress toward program goals and
currently specified in A1-10. If an agency wants additional
objectives. Standard project management practice is to report and assess progress at least monthly to ensure effective requirements it may request clearance from OMB.
communications among project participants. Current financial assistance regulations specify that progress reporting
shall not be required more frequently than quarterly or less frequently than annually. Quarterly reporting may be
appropriate for basic science grants. Applied RD&D projects have time-critical milestones relative to goals and
objectives, they tend to be complex, and they are likely to have significant scope, cost, and schedule risks. The award
recipients must communicate progress among project participants at least monthly to effectively manage the work in
accordance with the established baseline. DOE must monitor the progress monthly to independently assess
performance trends, respond to risk events before they become critical, and provide timely status reports needed for
management decisions.

DOE/NETL

Instructions In general, the draft RPPR does not provide a clear and definitive format that would be instructive for individuals
The work group believes they have accomplished this.
managing R&D projects. The directions could be simplified to clearly state the project information that must be reported.

Wouldn't the agency provide the reporting
requirements

DOE/NETL

Other

We shouldn’t do anything until we have it
electronically.

General
Page 8

Final implementation should be deferred until a common approach is established for reporting electronically, preferably Thank you for your comment. This is an electronic system
through a web-based application. It is not clear that the intent of standardized reporting is to “collect information” but
implementation issue. The work group will forward your
rather is intended to provide a means to effectively report progress toward project objectives. This progress is reported comment to those who develop the electronic solution.
relative to the planned scope, cost, and schedule. If the recipients of financial assistance awards are actively managing
the R&D project, which includes effectively communicating among project participants and their management, there
should be no burden to the recipient in reporting progress monthly. It is the exception for R&D organizations not to be
proficient in information technology for management and communications purposes.

source.xlsx

The RPPR was designed for basic research
projects.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

U. S.
Department of
Health & Human
Services (HHS)

General Comment

Comment Response

Notes

Context: To assist in the development of this response, the Office of Grants Policy, Oversight and Evaluation,
No response required
OS/ASRT/OG of the U.S. Department of Health and Human Services solicited input from the HHS grant awarding
agencies, which in turn solicited input from their grants and program management staff. Substantive feedback was
received from the National Institutes for Health, the Food and Drug Administration [comments not received through the
formal Federal Register process--we are following up with HHS to try to locate the FDA comments], the Agency for
Healthcare Research and Quality, the Centers for Disease Control, the Health Resources and Services Administration,
the Centers for Medicare and Medicaid Services, and the Administration on Aging. While OGPOE had anticipated to
submit a single response on behalf of all HHS grant awarding agencies, it is clear that this is not possible as there is
little consensus among our awarding agencies and programs regarding the proposed RPPR elements and
implementation.
Alternatively, we have encouraged HHS awarding agencies to submit their comments directly to you. The comments
provided in this response attempt to highlight some of the issues identified by multiple agencies which OGPOE feels
warrant significant attention.

HHS

Other

There was no consensus among reporting HHS awarding agencies regarding the appropriateness of the categories and Only one section is mandatory, while the other sections are
elements. More than half of commenters expressed support for the categories and elements, however some
optional. This combination of mandatory and optional
questioned the utility of the elements to agencies and cited an excessive burden on grantees. Another comment noted sections gives agencies the maximum flexibility to collect
that although appropriate, some of the categories and elements would need some revision to include currently required only the information required, without overburdening others
program-specific reporting information in the interim progress reports as well as in final reports.
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

HHS

Other

Should other categories be mandatory? Several HHS awarding agencies requested that multiple additional elements be Only one section is mandatory, while the other sections are
mandatory, some of which are listed above in response to Question 2 [change in personnel, unobligated balance,
optional. This combination of mandatory and optional
IRB/IACUC approval, clinical trials]. One agency requested that Product/Outcomes be mandatory, and another agency sections gives agencies the maximum flexibility to collect
requested Impact be mandatory.
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

HHS

Other

However, these awarding agency and/or program-specific needs might be satisfied if awarding agencies retain the
The work group will keep this in mind as it develops the final This is not the first time this issue has come up.
authority to require their grantees to respond to the questions/elements within an optional category. Please note that
version of the RPPR. Only one section is mandatory, while Use of optional and mandatory is not clear
this requirement (i.e., that a grantee must respond to an optional category where required to do so by the awarding
the other sections are optional. This combination of
enough.
agency) should be more clearly stated in the RPPR—comments received by OGPOE suggest that some HHS awarding mandatory and optional sections gives agencies the
agencies’ staff understood that it might be up to the grantee to choose whether it would respond to an optional category. maximum flexibility to collect only the information required,
without overburdening others with unnecessary
requirements. Agencies can select the information needed
to perform its reviews for a specific program. Information
required can vary between agencies and programs.

HHS

Instructions In general, HHS awarding agency commenters found the instructions straightforward and easy to understand, although
some noted that agency-specific and program-specific instructions will be necessary to capture required reporting
elements (e.g., PART), to ensure the responses can be compiled in aggregate for agency’s entire program, and to
otherwise meet agency-specific or program-specific needs.

Thank you. The agency may consider using the PPR. It has
specific section for reporting on PART. The agency may
also pursue developing agency specific requirements
through OMB.

HHS

Other

A clear majority of awarding agencies recommended delaying agency implementation until a common electronic
solution is operational. Agencies cited excessive burden to both agencies and grantees, as well as the applicability of
the Government Paperwork Elimination Act, as the primary reasons for this position.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

HHS

Other

There was no consensus regarding whether to use a downloadable fillable form or a web-based form.

No response required

HHS

Other

The provision of a clear definition of “research” and additional guidance regarding the applicability of this format to
agencies’ research programs would also be helpful. Some HHS staff commented that they were unsure as to the
applicability of the RPPR to their programs and/or whether it would be used in addition to or in lieu of their programs’
current program-specific progress reporting forms.

Agencies should determine if this format is appropriate for
their needs. The RPPR attempts to give flexibility to
determine what is right for their program.

General
Page 9

source.xlsx

There will be research programs, in which the
community asks why arent they using the RPPR?
We have this same issue on the development of
research terms.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

HHS

Other

OGPOE applauds the efforts taken to develop a standard research performance progress report, however, the
So noted. The work group will continue to work to make
conflicting reactions to the proposed interim Research Performance Progress Report provided by a number of programs sure that everyone's comments are carefully considered
within the seven responding HHS agencies and their array of programs leads OGPOE to have serious concerns about when developing the next version of the RPPR.
adopting the RPPR without additional review and revisions. Given the potential for disruption to the annual flow of
research award funding across government that is dependent upon such report information for continued funding and
considerations for additional new funding, OGPOE recommends the National Science Foundation and the Research
Business Models subcommittee continue to work with agencies and grantees to further refine the format.

HHSAdministration
on Aging
(HHS/AoA)
HHS/AoA
HHS/AoA

Other

Are the categories and elements appropriate? Yes

No response required

Other
Should other categories be mandatory? No.
Instructions Are the instructions straightforward and easy to understand? Yes.

No response required
No response required

HHS/AoA

Other

Should agencies defer final implementation until there is a common solution for collecting the information electronically? No response required
No.

HHS/AoA

Other

Should agencies use a downloadable fillable form or web based form to report progress? Yes.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

HHS--Agency for Other
Healthcare
Research and
Quality
(HHS/AHRQ)

This format appears to be appropriate for patient safety grants that I have had in the past. This may be somewhat
overwhelming for my dissertation grantees. If it is clear that N/A is okay and not all fields are mandatory, this should
work for this mechanism (vehicle –new word learned yesterday during the Project Management Training).

No response required

HHS/AHRQ

Other

This draft report looks very similar to a final report format. It asks for the impact made by the project which could be
problematic because it may force grantees to make draw conclusions or make assumptions about their projects before
they are really ready to do so.

If the requirement is a burden, the agency need not request
it from grantees. Only one section is mandatory, while the
other sections are optional. This combination of mandatory
and optional sections gives agencies the maximum flexibility
to collect only the information required, without
overburdening others with unnecessary requirements.
Agencies can select the information needed to perform its
reviews for a specific program. Information required can
vary between agencies and programs.

HHS/AHRQ
HHS/AHRQ

Other
Other

The categories and elements appear appropriate.
Abstracts are nice to have for Agency Highlights (250 word maximum is satisfactory).

Thank you.
Thank you for the comment, the work group will consider it
when developing the final format.

HHS/AHRQ

Other

The general structure of the report seems fine. One question would be how much tailoring would be allowed if the
report ‘format’ is approved. If we would like to use the progress reports to monitor results related to our PART goals—
would we be able to add those fields? As well as other more specific fields/questions we currently have.

The agency may consider using the PPR. It has a specific
section for reporting on PART. The agency may also pursue
developing agency specific requirements through OMB.

HHS/AHRQ

Other

There will be demand to make heavy use of Agency and Program specific supplemental formats. The organization and The agency may consider using the PPR. It has a specific
response categories from the draft format make sense as does the idea that there would be a single mandatory format section for reporting on PART. The agency may also pursue
with optional formats for specific types of grants. It may be unrealistic to expect agencies to minimize the number of
developing agency specific requirements through OMB.
agency or program specific formats, however, given that each Agency and program will have it’s own PART objectives,
they will see their information needs differently and so some flexibility around assuring that Agencies and programs
have the ability to collect data on their PART metrics seems appropriate.

General
Page 10

source.xlsx

Notes

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

HHS/AHRQ

Instructions Structured vs. unstructured questions – may want to allow Agencies to define instructions differently. There is an open The standardized instructions were developed to ensure
ended nature to the draft format. What agencies and their contractors often want or need to do is aggregate and
consistency across agencies wherever possible. The work
summarize findings from the program as a whole and compare reporting outcomes across grantees. Unambiguous,
group will forward your comment about the programattic
closed ended questions are more conducive to this objective. Close ended questions are challenging to incorporate into information required to those who develop the electronic
a format that’s meant to work across federal grants, however, there may be opportunity for different agencies or
solution.
programs to use/provide different types of instructions associated with each of the sections of the report that allow the
responses to be analyzed in a closed ended manner – for example, AHRQ’s definition of what they want grantees to
report in the “accomplishments” section may be different and more closed ended than another Agency and if the format
can accommodate variations in the instructions to grantees, this may be a way to have a consistent format but also
allow each Agency to get responses structured in a manner that makes sense for them.

HHS/AHRQ

Other

HHS/AHRQ

Instructions Are the instructions straightforward and easy to understand? 1. Yes. 2. It is long and wordy. Is it possible to have the The electronic format will make the RPPR easy to use. Tabs In an electronic system, much of the instructions
report format and a guide? This is just a thought. 3. Yes, but I think the report requirements are a bit lengthy.
will allow the grantee to view the essential instructions only. will be pared down, the justification for reporting
can be hidden on a different tab.

HHS/AHRQ

Other

Agencies should be able to use a fillable form that is savable to their own PCs.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

HHS--Centers
for Disease
Control &
Prevention
(HHS/CDC)

Other

The categories and the elements appear to be appropriate; however, the formatting appears to be difficult to delineate
the individual categories and the corresponding instructions and examples for each.

The form is designed as an electronic format. The format
will be clarified when in electronic format.

HHS/CDC

Other

Should other categories be mandatory? The sponsoring agency/program component may wish to make some of the
optional categories mandatory (program-specific decision). This comment in no way recommends changing the
elements and instructions within the category.

Thank you.

HHS/CDC

Other

Should other categories be mandatory? Budget and table of key personnel. Current copies of all IRBs if human
subjects are involved.

Only one section is mandatory, while the other sections are
optional. This combination of mandatory and optional
sections gives agencies the maximum flexibility to collect
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

HHS/CDC

Other

Should other categories be mandatory? IACUC, Clinical Trials information should also be addressed when applicable.

Only one section is mandatory, while the other sections are
optional. This combination of mandatory and optional
sections gives agencies the maximum flexibility to collect
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

HHS/CDC

Other

Should other categories be mandatory? Yes, the Products/Outcomes Category.

Only one section is mandatory, while the other sections are
optional. This combination of mandatory and optional
sections gives agencies the maximum flexibility to collect
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

HHS/CDC

Other

Should other categories be mandatory? The one piece that is missing that I think is important as a mandatory element Many of these requirements are available in the optional
is a description of challenges (e.g., problems, barriers, delays) that they experienced and how they were resolved as
sections of the format. The awarding agency can make the
well as any challenges that they anticipate and how they propose to prevent them. This information can help our staff to sections required if they desire, but the work group would
focus in on the issues of greatest concern to the PI's and also allow us to learn whether challenges that we are
like to maintain the flexibility for those agencies who do not
concerned about are recognized by the PI.
deem this necessary or appropriate.

General
Page 11

Agencies have been allowed to add agency
specific requirements on past forms and there is
no consistency. To do this gives the illusion of
standardization. This group sounds like they need
the PPR more than the RPPR. Though the work
group will send this to the electronic folks to see
what can be done about the programatic info
needed.

Should other categories be mandatory? No, unless we have different formats for different mechanisms (grants) and this No response required.
would defeat the purpose of streamlining.

source.xlsx

The work group was designing this as an
electronic format. Is there a better way to show
the format on paper?

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

HHS/CDC

Instructions Are the instructions straightforward and easy to understand? Overall, instructions appear to be easy to read. In the
Mandatory category, sub-topic "Accomplishments" and "Instructions-Accomplishments", it seems the words "project"
and "activity" are used interchangeably. Interchangeable use of these terms is confusing. See the first bullet under
"Accomplishments" and the first sentence under instructions. It seems the agency approves the project and the
activities therein.

Thank you. The language on the format will be updated.

Not sure why it would be problematic. Activites
are not the project.

HHS/CDC

Instructions The instructions are relatively straightforward; however, consistency with wording needs to be applied such as "none,"
"nothing to report," and "no change" are listed as possible answers to various questions.

Thank you, the work group will work to standardize the
language.

Prefer nothing to report. Except there are certain
blocks where it would not be appropriate. "None"
refers to a number or specific response.

HHS/CDC

Other

Should agencies defer final implementation until there is a common solution for collecting the information electronically? Thank you for your comment. This is an electronic system
No
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

HHS/CDC

Other

Should agencies use a downloadable fillable form or web based form to report progress? A web-based or fillable form
for the report has value.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

HHS/CDC

Other

Should agencies use a downloadable fillable form or web based form to report progress? We suggest piloting the
format using the downloadable fellable form. The pilot will inform the identification of a common solution for collecting
the information electronically and the appropriateness of the elements and its usability.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

HHS/CDC

Other
Other

We applaud the efforts being undertaken to establish a uniform format for reporting performance on Federally-funded
Research projects. It will certainly improve our ability to compare research projects across the government.
How will this replace the current 2590 form that we use for interim progress reports
(http://grants2.nih.gov/grants/funding/2590/2590_forms.pdf)?

Thank you.

HHS/CDC

HHS/CDC

Other

Will there be page limitation for each section or for the overall report?

This is a format, not a form. Agencies can define page
limits when appropriate.

HHS/CDC

Other

HHS/CDC

Other

The required section length is reasonable and the rest is optional. I think there would be value in a standard report, no Thank you.
surprises from PGO each year and it allows comparability.
I am not clear if it is in addition to the 2590, so we need clarification on that point. If it is then I think it is an unnecessary It is not in addition to the 2590. The work group agrees that
burden to the PI and against the paper reduction act's intent.
both formats should not be used. For agencies currently
using the PHS2590, the bulk of the material collected in the
PHS 2590 will be replaced by the RPPR. However some
material currently collected is not part of the RPPR. The
work group envisions the PHS2590 will eventually be
amended to reflect only those agency-specific requirements
not covered in the RPPR.

HHS--Health
Resources and
Services
Administration
(HHS/HRSA)

Other

General
Page 12

Only one section is mandatory, while the other sections are
optional. This combination of mandatory and optional
sections gives agencies the maximum flexibility to collect
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs. For agencies currently using the PHS2590,
the bulk of the material collected in the PHS 2590 will be
replaced by the RPPR. However some material currently
collected is not part of the RPPR. The work group envisions
the PHS2590 will eventually be amended to reflect only
those agency-specific requirements not covered in the
RPPR.

Please note that owing to the diversity of HRSA grant programs, there were a wide array of comments, some of which No response required
were mutually exclusive depending on the question or issue being commented on. While some felt there might be utility
in its implementation others expressed concern that it would be burdensome, and not achieve its intended results. To
better understand the reactions generated by the proposed form, we have not attempted to develop a consensus
response and have provided as many of the comments as we felt appropriate.

source.xlsx

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

HHS/HRSA

Other

Prior to the implementation of a standard progress reporting tool for research projects HRSA believes it is essential that Different agency needs will require report flexibility and
a definition be provided for “research project”. Is research, for purposes of utilizing this form, limited to biomedical-type agencies can use the RPPR to address any agency specific
research or is this meant to incorporate social science type research as well? Further, if the definition is restricted to
needs.
biomedical research, can agencies which award social science research be exempt from use of the form if it does not
adequately capture reporting needs of the agency?

HHS/HRSA

Other

Is there an implementation timetable for the proposed reporting form? HRSA’s progress report and performance
measurement is electronified. Therefore, any required changes in format/questions will require system changes. A
timeframe for implementation will be necessary in order for HRSA to implement these changes in the enterprise–wide
project management system which incorporates performance measurement and progress reporting.

While there is no timetable at this time, part of the overall
Agencies are always given plenty of advance
implmentation, agencies are always prvoided implmentation notice for when a form will be implemented.
instructions for how much time permitted to use this format.

HHS/HRSA

Other

This seems to be an extremely lengthy and burdensome progress report format. The Federal Register notice says one
intent is to make it easier to administer Federal grant programs through standardization of the types of research
information required in performance reports. It is doubtful this will be the result of this format. Rather, it is likely to add
additional burden to the reporting system.

Only one section is mandatory, while the other sections are
optional. This combination of mandatory and optional
sections gives agencies the maximum flexibility to collect
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

HHS/HRSA

Other

In addition, the focus is on interim, or progress reports. It is questionable whether the additional burden imposed by the Only one section is mandatory, while the other sections are
new interim reporting requirements is worthwhile. Much of the information asked for could be usefully included in a final optional. This combination of mandatory and optional
report, and appears to add little value when reported on an interim basis.
sections gives agencies the maximum flexibility to collect
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

HHS/HRSA

Other

However, another office noted that the overall reporting changes proposed by the National Science Foundation will
Thank you for your comment. It should be noted that this
significantly enhance awardee accountability and promote a better understanding of the impact of public investments in proposed format was developed by an interagency group.
research.

HHS/HRSA

Other

One HRSA Bureau noted that while the proposed reporting form is quite comprehensive, it would be cumbersome for
some of its research grants to Centers because these Centers complete or work on anywhere from 4 to 30 research
projects a year. It was further noted, however, that grants to Centers would presumably remain exempt from using this
form.

HHS/HRSA

Other

One respondent noted that in general, because research projects vary so much, the proposed reporting form should be Different agency needs will require report flexibility and
more open ended, with more general questions but fewer of them. While another respondent noted, the proposed form agencies can use the RPPR to address any agency specific
appeared to cover the broad elements that its office was asking its grantees to report on.
needs.

HHS/HRSA

Other

One commenter noted, research projects are more "step-dependent" than other kinds of projects like demonstrations or No response required.
especially training grants. That is, success of the project is very dependent on each step or stage being carried out
successfully. While research projects vary greatly, most follow a pattern of steps similar to the following: hypothesis
development; methodological development; instrument development; survey administration; data collection; data
analysis; report writing; and report dissemination.

HHS/HRSA

Other

The draft is surprisingly general (page 2) in pinpointing where the grantee stands with regard to progress on the project - Only one section is mandatory, while the other sections are The report can cover what they are asking for.
in terms of the above steps. Also, it appears there are at least three dimensions the supporting agency would be
optional. This combination of mandatory and optional
interested in regarding a project's status: (1) the salience or policy-importance of the research, (2) threats to success of sections gives agencies the maximum flexibility to collect
the research, and (3) the locus on the time scale for completion. It does not seem that the report form addresses those only the information required, without overburdening others
clearly. Further, beginning around page 5, the questions appear burdensome and possibly unnecessary. These are
with unnecessary requirements. Agencies can select the
generally included in the grantee's approved proposal, and what the agency needs to know is if there has been any
information needed to perform its reviews for a specific
variance from the original plan rather than a reiteration of what's already been stated.
program. Information required can vary between agencies
and programs.

HHS/HRSA

Other

One Bureau noted two cross-cutting concerns about the RPPR. The first is reporting level. The instructions should
Only one section is mandatory, while the other sections are
clarify the level of reporting, either at the overall level or at the individual project level. The Rural Health Research
optional. This combination of mandatory and optional
Centers (RHRCs) each have one cooperative agreement that covers four years, with three individual research projects sections gives agencies the maximum flexibility to collect
added each year, i.e., a total of twelve individual projects by year 4. It was not clear whether “Accomplishments” and
only the information required, without overburdening others
“Products” would be reported once at the overall level, for each year of the cooperative agreement, or for each individual with unnecessary requirements. Agencies can select the
project that is in progress. The Bureau noted the latter approach would result in a much larger reporting burden and
information needed to perform its reviews for a specific
was concerned about the RPPR meeting their need to report on the progress at the overall level of an entire research
program. Information required can vary between agencies
center (as opposed to simply reporting on a stand-alone research study).
and programs.

General
Page 13

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Thank you for your comment.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

In short, the RPPR seems reasonably well-suited to the collection of information about the progress of individual
research studies. However, it does not provide an adequate mechanism for reporting on the progress of the full scope
of what our research centers do, such as providing technical expertise to public and private stakeholders and
disseminating policy-relevant observations to diverse rural, local, state and federal stakeholders. Because the RHRCs
frequently respond to requests for information that go well beyond the funded research studies, it is essential to ORHP
to document progress on this important service to our constituents. Consequently, the Bureau recommends that the
RPPR collect research progress on an overall level.

HHS/HRSA

Other

In addition, some of these categories, for example those pertaining to development of human resources and
Only one section is mandatory, while the other sections are
infrastructure, are particularly relevant to overall reporting at the level of a research center as opposed to an individual optional. This combination of mandatory and optional
rural health research project. For example, a center provides “opportunities for research and teaching” and can improve sections gives agencies the maximum flexibility to collect
the representation of underrepresented groups in the sciences. With the emphasis in the cooperative agreement on
only the information required, without overburdening others
minority student/faculty recruitment and development, significant outcomes in human resources would be expected at
with unnecessary requirements. Agencies can select the
the overall level, rather than individual project-level outcomes.
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

HHS/HRSA

Other

The second crosscutting concern is reporting burden and the method for electronic collection of the data. Preliminarily it Only one section is mandatory, while the other sections are Optional is at the discretion of the agency. If don’t
seems that estimates of the burden for completing this form (5 to 16 hours) are understated. Information necessary to optional. This combination of mandatory and optional
need it, don’t ask for it.
complete this form is significantly more extensive than that which is currently reported in interim reports to ORHP, such sections gives agencies the maximum flexibility to collect
as project-specific details on individuals who have worked at least one person-month per year on a study. These, as
only the information required, without overburdening others
well as other provisions in the RPPR, pose an undue burden for awardees that may more than double the estimated
with unnecessary requirements. Agencies can select the
reporting time. We estimate that 32 to 40 hours seems to be more reasonable. Of course, if optional categories are
information needed to perform its reviews for a specific
made mandatory, burden will be higher.
program. Information required can vary between agencies
and programs.

HHS/HRSA

Other

The optional sections pose substantial burden on the respondents and the purpose and utility of the information is not
evident. If a form is going to be standardized, optional sections have very limited utility. Information obtained from
optional sections should never be used to make generalizations about the universe of respondents, as only a portion of
respondents will provide the information.

HHS/HRSA

Other

Another commenter noted that although appropriate, some of the categories and elements would need some revision to Agencies may pursue developing agency specific
include currently required program specific information reporting to be included in the interim progress reports as well as requirements through OMB.
in final reports.

HHS/HRSA

Instructions There was general agreement that the instructions are straightforward, but one commenter found it questionable to have The required use of the optional forms will be at the
so many optional categories in the form.
discretion of the agencies, not the grantees.

HHS/HRSA

Other

Regarding the question of deferring implementation until there is a common situation for collecting this information
electronically: OMB requires the option of submitting information to the Federal Government electronically, except
under special circumstances (one time surveyor for special populations (migrant, homeless, etc.)) The Government
Paperwork Elimination Act (GPEA) builds on the requirements and scope of the Paperwork Reduction Act of 1995
(PRA). All transactions that involve Federal information collections covered under the PRA are also covered under
GPEA. GPEA required Federal agencies, by October 21, 2003, to allow individuals or entities the option to submit
information or transact with the agencies electronically and to maintain records electronically, when practicable. The
electronic submission, maintenance, and/or disclosure of information is regarded as a means of decreasing the burden
and/or increasing the practical utility of the collection.

Thank you, your comment has been noted.

HHS/HRSA

Other

That said, there is general agreement in HRSA that agencies should defer until there is a common solution.

Thank you, your comment has been noted.

HHS/HRSA

Other

This information, especially to truly make a “technology transfer” and share products and tools developed through
Thank you for your comment. This is an electronic system
Federally funded research should be captured electronically in a searchable format and downloadable in a fillable form. implementation issue. The work group will forward your
Suggest the use of a web-based form that is backed by a relational database that will actually be useful/capable of
comment to those who develop the electronic solution.
searching.

HHS/HRSA

Other

The issue of electronic reporting is a critical one for reporting burden. If the form is one that can be downloaded and
filed electronically so that previous year’s documents could be used as a base and edited/updated, this would be userfriendly and fairly quick. If information has to be entered into a website it will mean that every year awardees are
starting over from scratch, which is much more time consuming. Also, HRSA awardees have experienced situations
with Grants.gov in which the systems are down and additional staff time is needed due to lost work, multiple tries at
getting in, etc. Therefore, ORHP recommends that electronic reporting be on an electronic form that is easily
downloaded and that implementation of the RPPR be deferred until a common electronically downloadable form exists
and has been tested.

HHS/HRSA

Other

Is OMB approval required for the narrative questions under “accomplishments?” Agencies have been able to obtain this Yes, OMB will approve will the entire final format. The intent
narrative information without asking specific, standardized questions by providing brief instructions for respondents to
of the format was to standardize the reporting requirements
describe project goals, accomplishments, problems, solutions, etc.
across agencies.

General
Page 14

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The required use of the optional forms will be at the
discretion of the agencies, not the grantees. Additionally,
the optional format has been succesfully used before to
produce informative reports.

Again confusion about who decides if it is
optional.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

HHS/HRSA

Other

The material notes that standardized reporting will have benefits -- however, it is notable that much of the proposed form The nature of research reporting requires that the
You can use search engines to search text, there
asks for information in open ended, free form text. Thus, extracting and compiling results in order to make statements information requests remain open ended to allow for
are electronic tools to help with the research.
about national impacts etc. will not be automated.
accurate reporting of accomplishments. If an agency
requires more specific questions, it may pursue developing
agency specific requirements through OMB.

HHS/HRSA

Other

As the sponsor of this proposed format, has NSF reviewed similar forms from other Federal agencies? The Department The work group started with a process of looking at existing
of Agriculture has several forms under a currently valid OMB number (0524-0042) for research funds awarded for basic research progress reports, and the collective decision of the
and applied research. The forms are brief and include a progress report, research funds (expenditures, disbursements, group was to start with the NSF format. It has been
and unliquidated obligations), and a final progress/termination report. The forms are up on the web under the Dept of
extensively modified to meet the agencies needs.
Agriculture’s Current Research Information System (CRIS). [http://www.ocio.usda.gov/forms/doc/AD0421-N-04-99.pdf]

HHS/HRSA

Other

Concern has been raised over existing performance measures and data collection and the impact of the new form on
This format has been developed for submission of progress
such program specific data collections. For example, MCH grantees are currently required to complete program specific reports for research and research related awards. If
information on Performance measures and Data collection forms through HRSA EHBs, as a part of their non-competing program specific performance data is necessary the agency
continuation/progress report. Will this RPPR replace that reporting requirement?
may also pursue developing agency specific requirements
and clearing them through the PRA process with OMB.

HHS/HRSA

Other

Will there be a maximum page limit for the RPPR progress report?

There is not a page limit, but an agency may set one.

HHS--National
Institutes of
Health
(HHS/NIH)

Other

NIH is supportive of this format and these categories are appropriate for most NIH research project grants and
cooperative agreements.

Thank you for your support.

HHS/NIH

Other

NIH plans to use the option of augmenting the RPPR with agency-specific requirements for other programs that use an Thank you for your comment.
annual progress report (i.e., training and career development programs), as well as a streamlined progress report option
that we use for a large majority of our research programs.

HHS/NIH

Instructions NIH supports the optional fields; however we suggest clarifying that the “option” is that of the agency, not the institution. Thank you, the instructions and format will be updated to
While this is mentioned in the beginning, it might be helpful to include a note under the “Optional Categories” section
clarify this point.
that these are to be used at the discretion of the agency, not the institution.

HHS/NIH

Instructions Are the instructions straightforward and easy to understand? Yes

HHS/NIH

Other

Agencies should wait until there is a common electronic solution. Downloadable fillable forms would be appropriate as Thank you for the comment.
an interim solution. However, if there is a web-based form that would tie to agencies’ current systems (e.g. NIH uses the
eRA Commons system), then the web-based forms may be useful. [NIH currently supports both electronic and paper
submission with the electronic submission provided through eSNAP, and the downloadable forms being provided on our
forms Web site.]

HHS/NIH

Other

In the Federal Register notice on page 4, last paragraph and in the RPPR in page 2, second paragraph, the statement is The workgroup feels that this paragraph provides necessary
made that “Agencies also may develop additional agency- or program-specific reporting categories and instructions
details about the format.
(e.g., the National Institutes of Health may need to collect additional information on clinical trial awards); however, to
maintain maximum uniformity, agencies will be instructed to minimize the degree to which they supplement the standard
categories.” We believe this statement is confusing in light of the fact that an earlier statement is made in both
documents that “agencies may use other OMB-approved reporting formats for specialized research grants, such as
centers/institutes, clinical trials, or fellowship/training awards.” We believe the suggestion that clinical trials might be
subject to a totally different reporting format or they might be asked limited additional questions on the standard form
introduces unnecessary confusion into these documents about how such an important aspect of NIH research will be
handled.

Thank you for the comment.

Therefore, we strongly suggest that the paragraph “Agencies also may develop additional agency-or program-specific
reporting categories and instructions (e.g., the National Institutes of Health may need to collect additional information on
clinical trial awards); however, to maintain maximum uniformity, agencies will be instructed to minimize the degree to
which they supplement the standard categories,” should be deleted from both documents. Each document has an
example of how the EPA might modify a reporting category that precedes the NIH example, which is much clearer and
should suffice as an example of how a category might be modified.

General
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10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

National
Other
Association of
State
Universities and
Land-Grant
Colleges
(NASULGC/
ESCOP)

The Experiment Station Committee on Organization and Policy (ESCOP) strongly supports a single standard reporting Thank you for the comment.
format for recipients to report progress on activities supported by Federal agencies’ research grants. This would reduce
the reporting burden on university research faculty who receive grants from multiple Federal agencies. However, for
this standard format to be both efficient and effective it must capture all appropriate and relevant information regarding
the research activity and the resulting database must be extractable or “mineable” for information useful to granting
agencies and recipient institutions. The detailed comments below outline some activity information particularly
important to agricultural research that the currently proposed RPPR format would not capture. ESCOP suggests that
these new or modified data elements be included in the final RPPR format.

NASULGC/
ESCOP

ESCOP suggests that a similar web-based portal be established to access the RPPR to enter report information for all Thank you for your comment. This is an electronic system
Federal-funding agencies. The design and programming of this portal should be developed by a joint group, which
implementation issue. The work group will forward your
represents all Federal-funding agencies and stakeholders (grant recipients) to ensure it meets the needs of each
comment to those who develop the electronic solution.
individual agency and recipient institutions. In addition, the RPPR should appear through this portal with all appropriate
fields pre-populated with previously entered core information to avoid re-entering data that have not changed from grant
initiation or previous reporting periods.

Other

Notes

National Center Other
for Atmospheric
Research
(NCAR)

The National Center for Atmospheric Research (NCAR), which is a FFRDC, funded by the National Science Foundation This is an agency specific issue.
and managed by the University Corporation for Atmospheric Research. We have five laboratories and several divisions
within each laboratory. Each division and laboratory has many goals and objectives. NCAR receives their core funding
from NSF through a large cooperative agreement. We also receive individual NASA, NOAA, FAA, DOD, etc awards as
interagency agreements through NSF. These funds are added to the main cooperative agreement, but issued under a
separate cooperative support agreement. Each year we are required to submit an annual progress report for the core
funding under the main cooperative agreement and another progress report for the interagency agreement transfer
awards (A decision is pending as to whether we will submit one report containing information for all the IA awards
combined or submit one report for each award). It can be quite challenging to submit a progress report for a large
cooperative agreement using a format that is geared more towards an individual investigator award.

This will need to be worked out between NSF and
the grantee.

National Science Other
Foundation
(NSF)

There needs to be a place for reporting on the outcome of supplements. Many of these are for additional training and
Agencies may pursue developing agency specific
outreach opportunities beyond the original scope of the project, and this information should be captured and associated requirements through OMB.
with the award.

How are supplements handled now? They are
under the same report, not separate. All lumped in
to the annual report.

NSF

Other

Why are research centers/institutes, clinical trials, fellowship/training awards excluded from this project? (See last
sentence in second paragraph, page 1) Throughout the introductory comments it is made clear that agencies may
provide additional program-specific instructions and may develop additional agency- or program-specific reporting
categories. Couldn't this, therefore, include specific language related to each of the excepted types of awards?

At an agency's discretion the format may be more widely
used . The work group's intent was to give agencies
flexibility for reporting on the noted examples.

NSF

Other

Will use of this reporting instrument enable the automatic capture of data (i.e., for products/outcomes; training;
participants; partner organizations; impact)?

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

NSF

Other

Will the submitted reports be searchable? It is extremely important to develop a system that has a dynamic and
Thank you for your comment. This is an electronic system
searchable data base. We presently store a lot of information in our electronic reporting system, but we do not have the implementation issue. The work group will forward your
ability to search that system (short of searching by each pdf file), or, most importantly, aggregate information from
comment to those who develop the electronic solution.
multiple reports across a variety of organizational levels. It would be wonderful to have an ability to identify and
aggregate a variety of kinds of scientific impacts across reports at the cluster, division, and directorate levels for
example. I hope this effort will result in an improvement in this sense so that we can make efficient use of the
information we are collecting.

General
Page 16

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Will the current work group be the ones
developing the electronic solution? There may be
a good chance that we will get involved in this
process There are some folks who have made
commitments, such as the GMLOBs, and
agencies that received exceptions. We should
define this ahead of time, where we think this will
go.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

NSF

Other

As far as I can discern, there is only one mandatory reporting category (i.e., Accomplishments) based on the
organization of this document. All other categories fall under Optional Categories, including Participants, and Impacts.
It seems we would want other categories of information collected routinely in all granting agencies.

Only one section is mandatory, while the other sections are
optional at the discretion of the agencies. This combination
of mandatory and optional sections gives agencies the
maximum flexibility to collect only the information required,
without overburdening others with unnecessary
requirements. Agencies can select the information needed
to perform its reviews for a specific program. Information
required can vary between agencies and programs.

NSF

Other

Whatever system is developed it should be platform neutral. I would recommend the Grants.gov model of
downloadable forms be avoided as uploading and downloading files can cause corruption.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

NSF

Other

What are the plans for linking progress reports for all years of the award? The system should make it possible for the PI Thank you for your comment. This is an electronic system
to use a previously submitted progress report as a template for a current submission.
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

NSF

Make the report more quantitative. The proposed report appears to be LESS quantitative than the current NSF
reporting format. Given that we are always being asked COV questions for which data do not exist, perhaps this is an
opportunity to collect more pertinent information.

Thank you for your comment.

Notes

It is not less quantitative. There must be some
other data type that they desire.

It is very close to the current NSF Progress Report - although it is somewhat more burdensome for our PIs, especially in Thank you for the comment.
the level of detail requested about ongoing activities.
Why not reorder as subject-verb-object: who did what with what effect, basically reversing the order of accomplishments Because agencies will not use all the sections, reorganizing
and personnel? Doing so improves the flow, because the report goes from accomplishments to their impacts and
it this way would not make sense.
significance.

NSF

Other

NSF

Other

NSF

Other

If standardized categories were used throughout, similar to those used for the demographic items, the data would be
more useful.

University of
Arizona

Other

The basic thesis of this policy is that this will "save work" and "increase comparisons of research" across federal
The development of the format was a legitimate attempt by There may be a short term impact for a long term
agencies. This policy will do nothing of the kind. It's another make-work project and unfunded mandate on already
an inter-agency workgroup, under OFTP, to develop a
goal of streamlining….
struggling researchers, who have seen the possibility of even getting federal grants reduced to success rates (even with standard format. The intent of the format was never to
excellent reviews) of <10%.
"Increase comparisons of research across agencies". As
with any standardization project, there may be a short term
burden increase in order to produce a long term gain.

University of
Arizona

Other

Different federal programs have different goals. What is a nice report for NASA might be useful for USDA or USGS.
Quite the contrary, the work group has heard from the
This is another mindless scheme cooked up in Washington. “Although different Federal agencies utilize a variety of
grants community that this is wanted and desired.
formats for reporting progress on activities supported by research grants, similar information is usually collected. These
variations increase administrative effort and costs for recipients of Federal awards and make it difficult to compare
research programs across government." There is no evidence this is the case.

University of
Arizona

Other

"Development of standard reporting categories will facilitate the development of a common electronic solution for
The development of the format was a legitimate attempt by
collecting the information in lieu of collecting it through numerous agency-unique reporting forms currently used." This is an inter-agency workgroup, under OFTP, to develop a
a make-work scheme for some federal subcontractor.
standard format. As with any standardization project, there
may be a short term burden increase in order to produce a
long term gain.

University of
Arizona

Other

"In furtherance of Public Law 106-107, this proposed format will directly benefit award recipients by making it easier for This is the first step, the work group will develop the final
recipients to administer Federal grant programs through standardization of the types of research information required in report after concluding the efforts on the progress report.
performance reports. This proposed format is for interim progress reports only,..." but not final reports, so what's the
point?

University of
Arizona

Other

" Agencies may develop an agency- or program-specific category, if necessary, to meet programmatic requirements,
although agencies would be instructed to minimize the degree to which they supplement the standard categories." So,
they won't be standard, anyway. More work for nothing.

General
Page 17

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The work group developed a format that standardizes as
much as possible. There are challenges involved in
developing something uniform across the agencies.

Not sure how we could do this, but open to ideas.
Would you perhaps put this in agency guidance
for the PIs? Is it standardized enough across
agencies that we should have icncluded this in the
format. It is hard to develop something uniform
across the agencies. We standardized as much
as possible.

The work group has worked hard to minimize the level of
agency specific requirements.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

General Comment

Comment Response

Notes

University of
Arizona

Other

"Comment is requested on any aspect of the reporting components proposed, such as appropriateness, feasibility,
completeness, or mandatory specification. The NSF also invites the general public and other Federal agencies to
comment on estimates of burden as required by the Paperwork Reduction Act of 1995 (PRA)." Clearly, this increases
paperwork and is not consistent with the above act.

As with any standardization project, there may be a short
term burden icrease in order to produce a long term gain.

University of
New Orleans

Other

One of the things that we should be able to do with electronic tools we have nowadays is receive a form to complete
that has all the boilerplate already added. So when an award is made it would be good to have the reporting sheet
already set up with title, PI, dates, amounts etc. It should also include the goals and objectives from the proposal and
the questions should be have they changed, not what are they? Similarly with the who is involved - all the info on
people who were on the proposal could be on the form already and the question is then what have they done and who
else is involved.

Thank you for your comment. This is an electronic system
implementation issue. We will forward your comment to
those who develop the electronic solution.

University of
New Orleans

Instructions One of the things that takes too much time in reporting is the stuff that doesn't normally change - make the forms
include that upfront and ask me to report if it has changed.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

University of
New Orleans

Instructions It would also be helpful for mandatory fields to be noted - if its OK to respond 'none' or NA to a question make that the
default. If the form requires information make that clear on the form. I assume this will all be online and in a format
where it doesn't accept the form if the mandatory fields are not completed.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

University of
New Orleans

Other

It is good that the “mandatory” sections will be highlighted.

Thank you for the comment.

University of
New Orleans

Other

It will be good if the report can be submitted via email; this will make life easier.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

University of
Vermont

Other

As stated in the very last sentence of the Supplementary Information, section I. Background: "Information, once
reported, does not have to be provided again on subsequent reports." All of the information collected via grants.gov
should be available to the RPPR. You should not implement the RPPR unless and until grants.gov can feed such
information into it. The goals and objectives information collected via grants.gov would be displayed on the RPPR with
an option to identify changes only if there were any during the reporting period.

The information collected on Grants.gov would not be
What is submitted through Grants.gov is usually
appropriate for the RPPR, as the information often changes too high, and then we budget it down. So
between application and award.
Grants.gov is not the right place to get this
information. There's also the case where there are
multiple funders. The information may be
available on agency systems.

University of
Vermont

Other

Recipients need to know how their reports will be used in government and other information systems and who will be
reading what they write. Will these reports be public information? If so, how will they be available and searchable?
What search criteria and report outputs will be available? Researchers will want to be able to find peer-reviewed
publications for a particular topic. I see nothing in grants.gov or the draft RPPR that would categorize these reports or
provide useful criteria for searching by different topics or categories of research. All the outputs needed from a
database should be identified before the input forms are designed.

Language will be added clarifying this issue.

There was nothing ever discussed by the group to
make the whole report publicly available. The final
reports are made available, but the interim reports
are not.

University of
Vermont

Other

When you allow the recipient to enter "none" or "nothing to report..." or similar phrase, it diminishes the importance of
the information (it is effectively optional). When someone is searching the database of research reports they are going
to see many reports that just say "nothing to report.” If you must have optional fields, leaving them blank is better than
asking users to enter "nothing to report”. From experience, I know that many will not say exactly “nothing to report” as
instructed but will instead say something like “I do not have anything to report at this time” or try to explain why they
have nothing to report. You have no way for computer logic to determine whether an actual report has been entered
unless it is left blank.

The work group agreed that using "none" or "nothing to
report" is more accurate. While a blank could represent
"nothing to report" it may also represent a spot that the
grantee forgot to fill in.

Our experience has shown that if you don't ask,
you cant assume that blank means nothing to
report. Blank could be forgot to fill it in. There
could be a check box in the electronic
implementation. How big a difference is there
between "nothing to report" and "I dont have
anything to report at this time." We could add "at
this time"?

General
Page 18

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Comment
Source
DoC/NOAA

Comment
Type
Other

Other Elements That Sould be Included Under the Reporting Categories

NOAA would suggest the following additions to the Mandatory Reporting Category: 1) Guidance is needed regarding
the level of detail necessary to address the mandatory reporting category. Perhaps a character or word limit would be
useful.

Comment Response

If desired, agencies may issue word limits within their
guidance.

Notes

What is the concern? That someone will write too
much? This is a decision that needs to be
discussed with the program manager.

2) A summary project description which also includes expected outcomes, milestones, location of activities, PIs and Co- A summary abstract would add to the burden. The reports
PIs as well as the flexibility to request other project information the program office may need to be addressed. This
will not be large enough to justify abstracts.
would help the Program Managers to review each progress report in a timely manner.
3) Current budget information is also needed to help with project monitoring. The government standard forms do not
supply enough detailed budget information to address the monitoring needs of the Program Manager.

A budget section will be created.

This is a technical communication. If they need
more budget information perhaps they should look
for the PRA. Optional budget category? NIH will be
needing it. Use the detailed budget in the RNR. Is
the project report the right place to put this? NIH
and HHS request this. Are there others outside of
HHS?

Agencies may pursue developing agency specific
requirements through OMB.

Are there specific examples of where it should go?
Do we want that level of detail?

DoC/NOAA

Instructions

The report format should include in its questions, one or two questions that address the quantifiable aspects of the
research, performance measures and metrics. The questions should be designed to not only illicit a yes/no response
but a brief description as to how something was conducted...for example, "How have collaborators or contacts been
involved"? The questions should include some management questions that may provide some helpful insight into the
infrastructure that led to the significant accomplishments/outcomes/deliverables.

ED

Other

As noted above, some ED research programs use the standard ED 524B, Grant Performance Report, which not only
A budget section will be created.
includes reporting on grant performance, but also financial reporting on items such as indirect costs, budget
expenditures and carryover, thus eliminating the need for grantees to submit separate financial reports, such as the SF269, Financial Status Report. ED has found that having both financial and performance information combined in the
same report has facilitated the review of both annual and final reports from grantees. For example, if a grantee reports
in the ED 524B that it has expended all of its grant funds for a given budget period, however, it has not conducted
planned activities and achieved project objectives, ED program staff would closely review potential problems with the
grant prior to awarding continuation funding for the grant. ED recommends the addition of an optional Financial Data
Category to the RPPR for agencies that would also like to collect financial and budgetary information with the
performance information in the RPPR.

This is different than adding a budget section. NIH
might like this. Even in the special reporting
requirements we took away anything about report
balances. So have a second financial category?
What would we get on this part of the report?
Wouldnt this be agency specific?

DOE/NETL

Other

The DOE is committed to financial assistance award and administration practices that are based on sound project
Only one section is mandatory, while the other sections are
management principles. It is expected that each financial assistance award will reflect the following principles: project optional. This combination of mandatory and optional
objectives are defined up front and used to judge project success; project performance risks (technical, financial, and
sections gives agencies the maximum flexibility to collect
otherwise) are identified and mitigated in the implementation strategy; scope, schedule, and budget are established for only the information required, without overburdening others
each project; and projects are managed and reported against established scope, schedule, and budget. Implicit in
with unnecessary requirements. Agencies can select the
these expectations is that each project has an associated management plan commensurate with the perceived risk of
information needed to perform its reviews for a specific
implementing the project. The project or research management plan is developed and maintained by the recipient of the program.
award. The plan delineates the scope, schedule, budget, and risks for the project. Award recipients must report
progress relative to what they planned to accomplish within the allotted schedule and budget.

This approach offers agencies a lot less
flexibility.They may use the PPR instead of the
RPPR.

It is suggested that the RPPR format be simplified to include the following categories: *[a. Title page; b. Executive
Summary - What is the research intended to accomplish?; c. Technical Progress - What was done and what does it
mean?; d. Issues/Problems - What identified or unidentified risk events occurred, and how are they being handled?; e.
Schedule Status - Are milestones being met?; f. Cost Status - Are funds being expended as anticipated?; g. Optional
Reporting - Optional special information to support program mission]. Only category “g” is optional. While the
proposed RPPR format makes reference to the above categories and does suggest tailoring of the optional elements,
this simplified format clearly delineates the progress reporting expectations for the project. This structure is not
dependent on basic, applied, developmental or demonstration activities; the level of detail will vary with the complexity
of the project and associated risks.

Other Elements to Include
Page 19

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DOE/NETL

Other

A significant portion of DOE program and project activities, which constitute annual expenditures in excess of $2 billion, Only one section is mandatory, while the other sections are
are applied research and development and technology demonstration (RD&D) programs and projects that have the
optional. This combination of mandatory and optional
primary objective of introducing a concept or product into the marketplace. The proposed format[*] focuses on basic
sections gives agencies the maximum flexibility to collect
science grants that do not have the time-critical goals and objectives that are characteristic of programs developing
only the information required, without overburdening others
technologies that address industry issues, such as those in DOE’s Office of Energy Efficiency and Renewable Energy, with unnecessary requirements. Agencies can select the
Office of Fossil Energy, and Office of Electricity Delivery and Energy Reliability. The Office of Management and Budget information needed to perform its reviews for a specific
(OMB) has recognized differences in performance monitoring expectations between the basic science and the applied program.
RD&D programs. The format delineated above[*] provides the fundamental project status data needed to monitor
performance relative to program goals and objectives.

DOE/NETL

Other

With the above approach, the award recipients report what they are doing using their established management systems, Most agencies don’t require this level of detail.
and the reports clearly document their accountability to the expectations established by the financial assistance
agreement. Standard project management practice is to report schedule and cost status in tabular or graphical form to
allow assessment of variance from the planned values; it would be beneficial for purposes of standardization to provide
an example of each.

HHS

Data
Element

Are there other elements that should be included under the reporting categories? IRB approval date, for human
subjects.

The format will be updated to include a special reporting
requirements section in the "Changes" portion of the report.

Could put it in the special reporting section. But
even there it is framed differently. The last optional
section needs to be agency specific requirements.
We could reformat a bit. Changes, Problems
section is essential.Keep the Changes, Problems
section and then have a new special reporting
requirements section. What will happen when new
requirements are developed, will the form have to
be recreated? This is a living document. If
something new comes out, we will need to build it
into the format. Cant the dates be included in the
agency specific instructions?
For NIH, they are captured as distinct data
elements, so having them as text is not useful. If we
dont put these distinct data elements in the RPPR,
NIH will need to have them on agency specific
forms.

Data
Element
Data
Element

Are there other elements that should be included under the reporting categories? IACUC approval

HHS/AoA

Other

Other elements that should be included under the reporting categories: Institutional Review Board approval dates;
Institutional Animal Care and Use Committee approval dates; Clinical trial – Phases I, II, III; Data & Safety Monitoring
Plan; FWA number; Other key personnel; Authorized Official Representative

HHS/CDC

Other

Other elements that should be included: A budget for the next budget period must be included in table form followed by A budget section will be created.
a narrative justification for each budget item.

HHS/CDC

Other

Other elements that should be included: A table of key personnel, their percent effort and their salary must be included This is covered under the participant section.
followed by a narrative contribution to the project by each individual.

HHS/CDC

Other

Other elements that should be included: Budget information should be mandatory. This was not included. Also, options A budget section will be created.
for budget format such as modular should also be considered.

HHS/CDC

Other

Other elements that should be included: We suggest additional mandatory categories: IRB status (performance sites
and expiration dates); anticipated unobligated dollars; major challenges and solutions.

HHS/CDC

Other

Other elements that should be included: I believe that an expenditure report should be provided as part of the progress A budget section will be created.
reporting protocol so the Project Officer can better determine if the project is on track. I noticed the report asks for
financial information regarding any partner contributions, therefore I believe this expenditure tracking reporting by the
coag recipient is appropriate.

HHS/HRSA

Other

Given the delays often encountered by Institutional Review Boards reviews, especially in projects undertaken in multiple There is a section provided for this purpose.
institutions, it may be instructive to have grantees elaborate on such delays, the reasons for them, and plans to
overcome unintended consequences.

HHS
HHS

Other Elements to Include
Page 20

Are there other elements that should be included under the reporting categories? Clinical Trials

RPPR Comment Tracker

The format will be updated to include a special reporting
requirements section in the "Changes" portion of the report.
The format will be updated to include a special reporting
requirements section in the "Changes" portion of the report.
The format will be updated to include a special reporting
requirements section in the "Changes" portion of the report.

These elements are covered under the accomplishments and
the proposed Budgetary sections.

10/17/2026

HHS/HRSA

Other

If the project were visited by an agency directed TA provider or other evaluative team, the outcomes of that review and
its impact on the work of the project in the next project period would be helpful to know.

The evaluation team should provide this, not the recipient.
However, agencies may pursue developing agency specific
requirements through OMB.

HHS/HRSA

Other

A commenter noted that for MCH funded research, there would need to be developed additional instructions under
“Accomplishments” and “Changes/Problems/Special Reporting Requirements” for grantees to provide current
information on recruitment and would require the completion of an Inclusion Enrollment Report Form.

Agencies may pursue developing agency specific
requirements through OMB.

HHS/HRSA

Other

Perhaps other program specific categories should be programmatically determined. For example, content related to
funding factors, faith-based and community based partnerships and national objectives related to Healthy People 2010
and health literacy should be included.

Agencies may pursue developing agency specific
requirements through OMB.

HHS/HRSA

Other

A suggestion was made to require that annual IRB review documents and materials associated with “conditions of
award” be attached to the progress report if not provided previously.

The format will be updated to include a special reporting
requirements section in the "Changes" portion of the report.

HHS/NIH

Other

Budget Category: Suggest consideration of an optional budget category. For those agencies where this progress
report is also used to conduct the fiscal/administrative review prior to the next award, a detailed budget is appropriate.
For consistency, suggest using the detailed budget from the SF424 (R&R). Instructions could include a request for
information on any significant unobligated balances.

A budget section will be created.

NASULGC/
ESCOP

Instructions

ESCOP also suggests that consideration be given to including a reporting field that would allow grant recipients to
reference related projects and other sources of funding (federal, state, private, etc.) that support the overall research
program that includes the specific grant’s activity. The intent would be to also report the institutional support for the
program. This recommendation would allow funding agencies and recipient institutions to more accurately determine
“leveraging” across funding sources and to identify interaction among research support entities.

This is beyond the scope of the format. The focus of this
format is on single Federal grants.

Other Elements to Include
Page 21

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RPPR Comment Tracker
Comment
Source

Comment
Type

Cover Page Data Elements Comment

Comment Response

ASU

Data
Element

Most respondents felt the categories and elements included are appropriate.

Thank you for the comment.

ED

Data
Element

The Cover Page for the hard copy version of the RPPR needs to include a signature line for the authorized
representative.

A signature block will be added. The work group will notify
those designing the electronic solution that there will need to
be the capability to both submit with signature and and
without a signature as required by the agency.

Emory
University

Data
Element

It would be very helpful if the form were prepopulated with as much information as possible, especially all the
COVER PAGE DATA ELEMENTS, and if possible Specific Aims and Goals, timelines, etc. from the grant
proposal. These data elements should be readily available metadata from the electronically submitted grant
proposal, which I am assuming is stored at Grants.gov in an XML format following some sort of DTD or
Schema.

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

HHS

Data
Element

Are there other elements that should be included under the reporting categories? No capture of the
Administration Official data (name, title, address) signing for the institution.

The format will be updated accordingly.

Data
HHS-Centers for Element
Medicare and
Medicaid
HHS/CMS

Add additional elements: grant amount, due date of report, signature and title of project director, and date of
report.

A block for capturing submission date will be added to the
format.

HHS/CDC

Data
Element

The following elements should be included on the cover page: email address and telephone number of the PI The form will be updated based on the comment.
and business official; Human Subjects and/or Vertebrate Subjects involvement; and direct, indirect and total
cost for the next budget period.

HHS/NIH

Data
Element

Add data elements would capture any changes in Project/Performance Site locations. This will be critical in
view of the new FFATA requirements. Specific data elements would be those found in the SF424 (R&R)
Project/Performance Site Location.

HHS/NIH

Data
Element

Add Administrative Official data (name, title, address, phone, fax, e-mail) signing for the institution/
The format has been updated, in response to a previous
organization. This can be optional data for those agencies where this is not a requirement of the annual
comment, to capture similar information.
progress report; however adding this to the Federal wide form would eliminate the need for NIH to
accommodate this as an agency-specific requirement. This is somewhat tied to the lingering question of
submission. If electronic submission is the end result, these data elements may become obsolete. However,
anticipating a paper usage of this for some time, we would require these data elements.

Cover Page Data Elements
Page 22

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The work group will gauge the government wide need for
this data element.

Notes

We don’t have a due date
currently. Submission date would
be helpful for paper.

We should wait until we
determine if there are others that
would want to capture this. Add it
into the area where we are
talking about other changes.
Could add "Change in
performance site" as a discrete
data element.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

ASU

Instructions In the mandatory section it asks the investigator to report changes to the agency-approved application or plan. If
The work group will update this section based on the
these are significant changes that would require prior agency approval, the instructions need to indicate that the
comment.
investigator needs to work with the appropriate institutional administrator to request agency approval of the change.

We tried to address this earlier in
a different way. We may want to
do something to ensure things
are not being reported twice.
How do we address this?

DoC/NIST

Instructions Extramural: Template really does not emphasize comparison of actual to planned as specified in the DOC regs, it The work group will update this section based on the
stresses only the "findings of the investigator" as preeminent, which is fine for basic research and not for research comment.
beyond research and for cooperative agreements. "What wasn't accomplished that was planned?" is not part of the
instructions. See 15 CFR 14.41 on reporting to see all the options. "Both" requirements are needed.

These are the sort of things a
program needs to know. Add a
statement to identify what was
not accomplished.

DoC/NIST

Instructions Extramural: Reasons why goals were not met and why appears to be mandatory and not optional in the
This concern has been addressed by the comment above.
regulations, however, the proposed template makes it optional. But very few basic research grants have
"established goals," which is not pointed out, but they could describe the baseline of the technology/science in the
knowledge base at the start of the grant/cooperative agreement that is in academia and/or the private sector.

DoC/NIST

Instructions Extramural: Strongly suggest that accomplishments include three key sections: 1. Baseline of the
technology/science; 2. Accomplishments against goals; and 3. Changes, Problems, Opportunities, Special
Requirements.

DoC/NIST

Instructions Extramural: The question on dissemination (page 3) really needs to be moved to the IMPACTS section, as it
appears to be redundant in the Accomplishments section.

Accomplishments Comment

Comment Response

Sections 2 and 3 are addressed in other sections on the
format. The work group feels that proposed section 1
requests a level of detail more in depth than desired for a
progress report.
The apparent redundancy is intentional to ensure agencies
using only a select few of the optional sections capture this
data.

DoC/NOAA Instructions The fifth bullet under accomplishments states: "What do you plan to do during the next reporting period to
Agencies may pursue developing agency specific
accomplish the goals and objectives?" The accompanying instructions go on to state: "Describe briefly what you requirements through OMB.
plan to do during the next reporting period to accomplish the goals and objectives and explain significant changes
in approach or methods from the agency approved application or plan." It would be helpful to specifically request
grantees to address whether or not a no cost extension will be needed. Grantees should be requested to address a
caption of this nature: Grantees should state that there are either no foreseeable circumstances that will require an
extension or that they are expecting that there may be a need based on upcoming events that will require an
extension to be filed before the next progress report

ED

Instructions Unit of analysis: It is not clear in the instructions for the mandatory Accomplishments category whether the unit of This has been changed to the project level based on another
analysis for reporting on accomplishments is at the “activity” (see page 2) or the “project” (see page 3) levels. The comment.
seemingly interchangeable use of the terms “activity” and “project” may cause problems in implementation as many
larger research grants have multiple projects and each project typically involves multiple activities. We recommend
clarification on what the unit of analysis is for reporting accomplishments.

ED

Instructions While the proposed RPPR, includes a mandatory category entitled Accomplishments that covers accomplishments This is accomodated by the new category "Special Reporting
Requirements."
made during the reporting period under the approved goals and objectives of the project, this category does not
specifically address the grantee’s progress towards meeting performance measures that 1) the Federal agency has
established for the research grant program, if any or 2) the grantee has established for its project in the approved
grant application. While agencies may use different terminology to describe similar concepts, we recommend that
the term “performance measures” be specifically included under the Accomplishments category to ensure proper
reporting on performance measures for the project or program, where applicable.
Instructions Further, in addition to reporting on progress towards meeting their performance measures, it would be useful if
Agencies may pursue developing agency specific
grantees would be required to provide a discussion of performance measurement trends, if applicable. This could requirements through OMB or may consider using the PPR
include process, as well as outcome measures, for example, % of scheduled dates met, % of customers who value for their reporting requirements.
the product, % of funded research reports in peer reviewed journals.
Instructions Some agencies use different terms to cover milestones and target dates for a project. This agency uses terms that This would potentially confuse the grantees.
reflect those used in the Government Performance and Results Act of 1993 (GPRA). Thus, we talk about
performance targets and interim performance targets. We think language consistent with GPRA terminology would
make the form more easily applicable to research programs managed by more agencies. We would support a
change that added to the list of bullets under the accomplishments heading a new bullet entitled: Interim and final
performance targets of the approved application.

ED

ED

Accomplishments
Page 23

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Notes

If you are not using anything but
accomplishments, then you
would not be getting this
information. Dissemination is
very important. Does not need to
be moved.
A PI might be confused and think
that this counts as a request for a
no cost extension.

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RPPR Comment Tracker
Comment
Source

Comment
Type

ED

Instructions There appears to be some redundancy in requesting that grantees describe any changes in the goals, objectives, This section will be updated to reduce redundancy.
approach, methodology or scope originally approved in the application. For instance, under major goals of the
activity under the Accomplishments category, the Project Director (PD) or Principal Investigator (PI) is asked to list
any revised goals and objectives. Later, under plans for the next reporting period, they are asked to explain
significant changes in approach or methods. Finally, under changes/problems, the form asks that the PD/PI report
any changes in approach during the reporting period and reasons for these changes. We suggest that reporting on
any changes in goals, objectives, approach, methodology or scope be reported once in the beginning of the form
under major goals of the activity.
Data
The mandatory question regarding training opportunities in the Accomplishments category anticipates two bases for "Nothing to report" accurately describes both of these
Element
not providing information: training was not intended; or, there were no significant training developments during the reponses.
reporting period. However, the form offers only one response for both situations, “none.” We believe that the report
would be more useful to agencies if each possibility were addressed separately. If no training opportunities were
planned under the grant, the report could include a response of “None planned.” If there were no significant
developments under planned training opportunities, the report could include a response of “Nothing significant.”
These responses would be easy to include in paper versions of the form with check-off boxes and an on-line
version of the form could similarly display check-off boxes.

ED

ED

ED
ED

ED

Accomplishments Comment

Comment Response

Notes

Instructions The wording of the “training and professional development” question is vague and could be construed to be limited This section will be updated based on the the comment.
to individuals working or involved with the project (e.g., undergraduate or graduate students, post-doctoral fellows,
college faculty, K-12 teachers). This definition seems overly restrictive and could have the effect of excluding a
substantial amount of training and professional development activities provided to others. For example, many
large research grants target outside audiences (e.g., practitioners in the field or ultimate beneficiaries of the
research/consumers) in order to increased knowledge of recent research findings and build capacity to utilize
findings.
Gathering this evidence would increase the reporting burden
Instructions Under the question “How have the results been disseminated to communities of interest?,” we recommend also
asking what evidence there is, if any, of the effectiveness of these dissemination efforts or strategies.
of agencies.
Instructions Tracking Performance Over Time: In both the Accomplishments and Impact categories, there is no provision for
There is no change necessary. Reporting periods are
identifying accomplishments and/or impacts that have been reported in more than one reporting period (e.g.,
artificial endpoints. The grant life cycle is comprised of all the
budget period or project year), but at different stages of development. Most noteworthy accomplishments of
reporting periods from award to close out.
research and development (R&D) activities are not discrete events that occur within a one year time frame and then
disappear; rather, both accomplishments and impacts typically mature over time from smaller, incremental
accomplishments or milestones. For example, in one year a grantee may report the successful development of a
product (e.g., a database) or technology that is reported as a peer-reviewed publication the following year.
Agencies need to have a way to link these accomplishments and track their evolution. We recommend that RPPR
form ask grantees: (a) whether accomplishments and/or impacts reported in the current reporting period (e.g.,
budget period or project year) are an outgrowth of accomplishments and/or impacts reported in a previous period;
and (b) if so, describe the relationship. [Comment repeated on Impact tab.]
Instructions Linking Accomplishments and Impacts to Goals: We are concerned that the current version of the form provides no The work group feels this linking will naturally occur.
mechanism by which grantees can link accomplishments and impacts to goals and/or performance measures. This
is particularly important for grants with multiple projects and goals – such a linkage would help agencies determine
grantee progress in different areas. We recommend that the RPPR form require grantees to link their
accomplishments to their goals and/or performance measures. One way to do this would be for the form to use an
internal numbering system identifying and linking project goals and activities with the goals and accomplishments to
which they apply. [Comment repeated on Impact tab.]

Wouldn’t the PI automatically be
linking the accomplishments to
the approved application. We do
not not need to elaborate on it.

DOE/NETL Instructions Only the Accomplishments section of the draft RPPR focuses on actual progress in any appreciable way, and the No response required.
nature of the information described is focused on basic science grants. The information is not adequate to support
DOE’s substantial involvement and due diligence for advanced R&D and major demonstration projects
administered through cooperative agreements. These projects are not administered through grants and many are
unique, cost-shared partnerships between DOE and private sector organizations. As such, these projects are
subject to all of the requirements associated with financial assistance rather than those associated with acquisition.
However, the nature of the projects is such that the participants must explicitly define expectations in terms of
scope, cost, and schedule that are more typical of a contract funding mechanism. The private sector participants
must adhere to accepted project management standards to effectively execute these complex projects that have
significant private sector and Government investment.
For NETL to be able to exercise due diligence as regards project management, it is imperative that reporting
mechanisms--particularly content and frequency--be consistent with those used in the private sector for projects of
this nature. Specifically, we need to be informed, on a monthly basis, of the project status categories delineated
above. See [*] on the Other Elements tab.

Accomplishments
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RPPR Comment Tracker
Comment
Source

Comment
Type

HHS/AoA

Instructions The following element could be added under Mandatory Reporting Elements (Accomplishments): On pace with
reviewed and approved workplan?

This issue has been resolved by another comment.

HHS/CMS

Instructions Under ACCOMPLISHMENTS: What was learned? Add the following: What are the approved major goals and
objectives of the activity.
Instructions Under ACCOMPLISHMENTS: What was learned? Add the following: What is the status of each goal to be
achieved during the reporting period?
Instructions Under ACCOMPLISHMENTS: What was learned? If appropriate, what corrective action is planned to resolve
implementation problems. Is technical assistance required from grantor agency?

The act of the agency funding it signifies approval.

Instructions Reasons goals were not met should be stated.
Instructions "No change" is unacceptable for plans for next reporting period. The Aims should be stated regardless of whether
or not they have changed.

This is addressed in the format.
The aim of the form is to alleviate the reporting burden on the Could remove the paranthetical if
grantee. Agencies should have this information.
that would help. So would they
need to repeat their application?
Focus on goals for the next
reporting period. Change the
parenthetical? If it has been
provided before we are not going
to keep asking for them to say it
again. Leave as is.

HHS/CMS
HHS/CMS

HHS/CDC
HHS/CDC

Accomplishments Comment

Comment Response

Notes

This is addressed by reporting on progress.
Agencies may pursue developing agency specific
requirements through OMB.

Corrective action has a very
negative connotation. This would
be responded to under the
Changes/problems section.

HHS/HRSA Instructions Under what was accomplished (top of page 3), it is suggested that the form also identify any barriers or challenges This issue is addressed in the Problems and Changes
the grantees encountered.
section.
HHS/NIH

Instructions Accomplishments: In the instructions for “What was accomplished under these goals” suggest including “positive The section will be updated based on the comment.
and negative” as part of the item 3) significant results. For this reporting period describe: 1) major activities; 2)
specific objectives; 3) significant results, including major findings, developments, or conclusions (both positive and
negative); and 4) key outcomes or other achievements. As the project progresses, the emphasis in reporting in this
section should shift from reporting activities to reporting accomplishments.

NASULGC/ Instructions Add a data element on the need or problem that is being addressed by the research activity. In other words, what is No action needed.
ESCOP
the potential usefulness to society of the ultimate application of these research results?
NASULGC/ Instructions Add a data element to indicate other sources of funding (federal, state, private, etc.) that support the overall
ESCOP
research program that includes the specific grant’s activity.
NASULGC/ Data
ESCOP
Element

In the major goals and objectives data element, if they have not changed from the original proposal, this field should Thank you for your comment. This is an electronic system
be pre-populated.
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

NASULGC/ Instructions In the results dissemination data element, the report should indicate if the dissemination was through a formal
ESCOP
outreach organization, such as the agricultural cooperative extension or industrial extension services, or an
independent activity.

NSF
NSF

NSF

Agencies may pursue developing agency specific
requirements through OMB.

This information should already be provided.

Instructions What was accomplished under these goals? The different between significant results and key outcomes was not
No change needed.
clear. Although the document already contains detailed instructions about the optional sections, it could include
distinctions between the two to avoid confusion.
Instructions How have the results been disseminated to communities of interest? Typically PIs considered research
This will be collected in the Products/Outcomes section and
under the Accomplishments.
publications and abstracts of poster/oral presentations in meetings as modes of disseminating results to the
communities of interest. Are they supposed to be included here? Products/outcome optional category will also
include this information. Will this information also be presented in the key outcomes under the accomplishments
section?
Instructions On p. 3 the following appears near the bottom: "Describe briefly what you plan to do during the next reporting
This issue has been addressed by another comment.
period to accomplish the goals and objectives and explain significant changes in approach or methods from the
agency approved application or plan." It seems to me that describing significant changes in approach or methods is
redundant, at least in part, with information requested at the bottom of p. 10 and on p. 11:
CHANGES/PROBLEMS/SPECIAL REPORTING REQUIREMENTS.

Accomplishments
Page 25

source.xlsx

This section is designed to get
outreach materials. Cant have a
specific example for every type
of award done.

10/17/2026

RPPR Comment Tracker
Comment
Source

NSF

Comment
Type

Accomplishments Comment

Comment Response

Notes

In this context, if this document represents the ordering of information that the PI will present in the progress report,
then as a program manager reviewing the information I would want to see a description of significant scientific
changes, or changes in plans about staff that could affect the scientific progress of the award, to be presented right
after a listing of the activities and accomplishments, or imbedded within that section. Such changes can affect
plans for achieving objectives in the next reporting period, that is, the section on p. 3 where information on such
changes was first requested in the document.
Instructions We agree that this should be a mandatory category for the RPPR. This information documents the progress of the Thank you for your comment.
research during the reporting period, thus providing information to the funding agency and other stakeholders about
the progress of the work and accountability by the researcher.

University of Instructions The guidance for the mandatory accomplishments category states: "List the major goals of the activity as stated in
Vermont
the approved application or as approved by the agency." You should not be asking recipients to repeat the goals
and objectives for each reporting period. This information should be collected once at the project's inception, and
should already have been provided in the grants.gov electronic application process. If it is not requested in
grants.gov as you need it for the RPPR, then you should modify the way it is collected in grants.gov so that the
information is usable at reporting time.

Accomplishments
Page 26

source.xlsx

Thank you for your comment. This is an electronic system
implementation issue. The work group will forward your
comment to those who develop the electronic solution.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

Products/Outcomes Comment

Comment Response

ASU

Instructions

Requesting invention, patent application, and license information is duplicative and should be eliminated from the interim report
since it already should be collected through the use of iEdison (https://s-edison.info.nih.gov/iEdison/) by all agencies. Perhaps
instructions should emphasize that this information is to be reported through iEdison.

The purpose of this section is to provide the program officer
with a record of all that has occurred within the reporting
period, including patents.

ED

Instructions

In the heading: “Products/Outcomes: what has the project produced,” the term “outcomes” should be changed to “outputs”.
“Outcomes” refers more to changes in policy, practice and behavior – this is covered in a later section. This particular section
addresses accomplishments such as publications, rather than the results of those accomplishments. Therefore the correct term
would be “outputs.” This should be changed throughout that section.

The term has been updated based on the comment.

ED

Instructions

The list in the examples is not meant to be inclusive.
However the format will be updated to clarify this.

ED

Instructions

Regarding the Products/Outcomes category, the draft format does not cover copyrightable works, which are a significant possibility
for a research project. For example, the researcher could have written code for a program that will help others in future research.
Computer code is copyrightable as well as patentable, depending upon the context of the program. We recommend a category for
copyrightable products be added to the proposed RPPR, in addition to the journal articles that might be copyrighted as well.
The form asks respondents to identify any networks and/or collaborations fostered by the research activities. This information most
likely will be in the grant application. What would be more useful would be information on the impact and effectiveness of the
collaboration/s.

ED

Instructions

Notes

Outcomes is a more consistent
language? No, Outputs are only
the tangible things.

There is a collaboration after the work begins, so the
information captured in the grant application may not be
complete.

Publications, Conference Papers, and Presentations: Through experience, some ED program offices have found that merely asking Agencies may pursue developing agency specific
grantees to provide lists of publications, conference papers and presentations produces data that are not very useful for external
requirements through OMB.
accountability or for internal monitoring. This approach places too much emphasis on the number of outputs rather than on the
quality and on how they contribute to advancing agency or grantee goals. This is particularly true for conference papers and
presentations, where for large grants and/or well-established PIs the list can be very long, numbering upwards of 50 presentations,
with many of them variations on each other with the same basic content and different titles.

To avoid the pitfalls of misplaced quantification and increase the utility of this type of performance information, we recommend an
recommended alternative approach that involves the following steps: (1) ask grantees to provide full citations for all journal and/or
book/chapter publications produced in the performance period, thus allowing journal articles to be checked against an independent
source (e.g., Thomson Scientific) to determine their peer-review status; (2) from this list, ask grantees to identify the 1-3 “most
important” publications in terms of advancing grant and/or agency goals, and for each of these to summarize the key findings and
implications; and (3) ask grantees to identify a “limited number” (e.g., no more than 10) of other types of publications (e.g., technical
reports, policy briefs, etc.) and conference presentations that they think are most important in terms of advancing grant/agency
goals.

Emory
University

Other

My sole criticism of the draft format is in the collection of publications and research reports. It is absolutely critical that scientific
The work group feels that publications naturally fits in the
peer-reviewed research publications not be viewed as Optional. This should without question be included in the Mandatory section. products section.

Emory
University

Other

A peer-reviewed scientific article is the final product, the final data set and formal interpretation of the meaning of the data. These Please see the response to the comment above.
articles and the research that they represent were bought by the US taxpayer with tax dollars, who paid for the research, the
analysis of the data, and even the writing of the article. The US public should be granted full and free access to these articles as
soon as they are published, and most certainly by the following Progress Report. It should be the duty of the Granting Agency to
collect these articles and assure that the articles are deposited in easily accessible and freely accessible forms. An excellent
example is the NIH-NLM PubMed Central database. The only flaw of the PubMed Central database is the collection of penultimate
versions, not the final version, of the article directly from the authors. This version may have many errors in it. It is critical that the
final published article is the version that is deposited, which will assure that the fully peer-reviewed and edited (in essence, the fully
corrected and final) version is the one in the public domain. The government should settle for nothing less than the real McCoy.

HHS/CMS

Instructions

Under PRODUCTS/OUTCOMES: What has the project produced? Add a final bullet: Program Income Generated.

Products/Outcomes
Page 27

source.xlsx

The work group feels that this is captured in the budget
section.

Already addressed? Program
income is only a product in the
most general sense. If it will be
required, put it in the budget
section.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

Products/Outcomes Comment

Comment Response

HHS/HRSA Instructions

A concern with the current iteration of the RPPR involves the requirement to list peer-reviewed publications. While there is general This issue has already been addressed in the format.
agreement that the documentation of these research outcomes is important, it is noted that the time required to have a manuscript
accepted for publication tends to be considerably greater than the one- to two-year duration of most of one program’s funded
research studies. In other words, in most cases publications would appear long after the corresponding progress report had been
submitted. Consequently, the commenter for the program in question did not feel much weight by funding agencies should be
placed on this measure and recommended that intermediate measures such as submitted and/or accepted manuscripts should be
included.

HHS/HRSA Instructions

One category, dissemination to “communities of interest,” requires further clarification. The category appears to refer to
This issue is covered in the accomplishments section of the
dissemination to the lay public (“communities… not usually aware of these research activities…. [to enhance] public
format.
understanding”). However, the first section, “communities… not usually aware of these research activities” could apply to any cross
disciplinary communication.

HHS/HRSA Instructions

Page 5, Web Site(s) or other Internet Sites(s) requests a listing of the URL’s where research activities are disseminated. A short
description of each site would enhance the report.

The format is being updated based on the comment.

HHS/NIH

Instructions

Suggest adding a specific category for Data & Research material (such as cell lines, DNS probes, animal models).

This type of information should be placed under "other".

HHS/NIH

Instructions

Suggest adding a clarifying instruction in the Invention section clarifying that this is not a substitute for completing the required
invention reporting.

The format has been updated to clarify this point.

NASULGC/ Instructions
ESCOP

This issue has been resolved by a previous comment.
Replace “Outcomes” with Outputs in the title of this category. All the data elements being reported in this category are more
accurately classified as outputs using the standard logic model for depiction of a program’s action sequence. See the following URL
for references on the use of this model and definitions of terminology.
http://www.uwex.edu/ces/pdande/evaluation/evallogicmodel.html

NASULGC/ Instructions
ESCOP

The Publications, Conference Papers, and Presentations data element information should include any electronic references (URL) The instructions are being clarified based upon your
that may be available for the publications listed. These URLs would then not be included under the subsequent Web Sites or Other comment.
Internet Sites data element and the instructions would indicate that.

NASULGC/ Instructions
ESCOP

It should be clear whether or not publications reported in the Publications, Conference Papers, and Presentations data element may This issue has been addressed by a previous comment.
include those submitted, under review, accepted, in press, etc. or only those that are publicly available at reporting time.

NASULGC/ Instructions
ESCOP

Add a data element to report number of people not defined as participants in the Participant category who were directly involved in
this research activity, i.e. focus groups, survey respondents, clinical trial subjects, taste panels, etc. An option may be given to
include relevant demographic information on these people.

Agencies may pursue developing agency specific
requirements through OMB.

NCAR

Other

Similar to items one and two, our organization publishes approximately 800 journal publications per year. As mentioned above, it
would be very helpful if the system could accommodate an upload of this information instead of typing each publication separately
into the system.

This is an electronic system implementation issue. The work
group will forward your comment to those who develop the
electronic solution.

NSF
NSF

Instructions
Other

Do the key outcomes in the mandatory section on accomplishments overlap with this section?
Will there be a facility for uploading pdfs of publications?

NSF

Other

NSF

Other

University of Instructions
New
Orleans
Products/Outcomes
Page 28

Notes

No.
This is an electronic system implementation issue. The work
group will forward your comment to those who develop the
electronic solution.
George Strawn has indicated that NSF has a new program for reviewers and PI's which allows people to pick up their publications This is an electronic system implementation issue. The work
group will forward your comment to those who develop the
from standardized ISI categories. Would it be feasible to use that program for this project?
electronic solution.
We do not agree that the proposed "Products and Outcomes" category should be an optional category of the RPPR, as proposed in Only one section of the form is mandatory for agencies to
the Federal Register notice. Instead, we believe this should be a mandatory category as it would contain references to journal
request, while the other sections are optional. This
articles, conference proceedings, web sites, and other products resulting from federally- funded research. This category is a
combination of mandatory and optional sections gives
primary means for informing various stakeholders and interested parties of the outcomes and products of all federally-funded
agencies the maximum flexibility to collect only the
research. To not require the submission of such information is to undercut the very cornerstone of the methods used to further
information required, without overburdening others with
scientific research and ensure accountability and transparency for federal research dollars.
unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program.

I am happy also happy to see that “conference papers” can be included and lumped in with regular publications. This makes sense Thank you for your comment.
because rarely do we actually publish results while we are still writing progress reports for particular projects.

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10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

University of Instructions
Vermont

Products/Outcomes
Page 29

Products/Outcomes Comment

Comment Response

Notes

The instruction for publications asks the recipient to indicate the "status of the publication (published, accepted, awaiting publication, The work group disagrees. It is easier for applicants and
submitted, under review, other)." Articles or other works that have only been submitted or are under review are not actual
publication people to find it all in one category.
publications and they may never be published. If you are asking for "publications", they should be only works that are published
(meaning that they are reviewed, edited, cited, and can be located and obtained whether paper or electronic). "In press" or
"accepted for publication" are at least going to be published, even though the location information is not yet known (when you
include these, the same publication needs to be reported again in order to include the location information once it is known). You
should provide a correct definition of what a "publication" is in the guidance so that only actual publications are included, otherwise
this important category becomes diluted with inaccessible or unsubstantiated material. If information about submitted and underreview works is of value, it should be included in a different category.

source.xlsx

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

Participants Comment

Comment Response

DoC/NIST

Instructions

Extramural: Organization information should LEAD this section, and put all requests for optional individual demographics at the
very end only. We are opposed to collecting demographic information of individual key personnel, etc. Grantor agencies should
be able to clarify what they want and these instructions do not indicate how demographic information on individuals will be
protected and how each individual gets to give approval to what information is provided. This could lead to potential lawsuits. An
individual could potentially be maligned and the information may end up in a grant database that could really cause the person
ongoing harm. If it remains optional, stronger language on how information will be protected is imperative!

DoC/NIST

Instructions

Extramural: Making the organizational information on participants a separate section would strengthen and raise the importance of The instructions have been updated to clarify the distinction
this to the IMPACTS section, and help with tracking impacts later. Right now it comes across as too intertwined with the individual between individuals and organizations.
demographics and the value of the information comes across as less important.

DoC/NOAA

Instructions

It is not relevant or appropriate to require demographic information (under the 'Participant' section) in these reports. Reports are
required so we can monitor progress on grant activities and ensure appropriate progress is being made. We should not be using
these reports as a means to collect data for some other purpose. (...Also, too late to do anything about this, but the proposed
report format should have been described in the FRN itself to make it simpler for people to review!)

DoC/NOAA

Instructions

Demographic information. Please clarify if the demographic information as described on Page 7 regarding Gender, Ethnicity,
This information request is optional. The instructions have
Race, and Disability Status is a mandatory or optional field. Although I do understand the value of this information, I would expect been clarified to reflect that point.
that it would be optional, or at least include an entry under each entry that includes a declined to designate option.

DoC/NOAA

Instructions

On a separate comment, the level of information that colleges have about Disability Status of students is not often reflective of the The demographics being requested only pertains to the
student population, and that there is a choice of disclosure of such information by students, and others, so that data often collected people who have directly worked on the award.
in this area is not representative. (American Association of Advancement of Science, AAAS has some references I can look up if
useful.). Do you know if before such a report would be implemented, information about which type of report that would be required
would be included in the FFO or the awarding document?

COGR

Other

COGR

Other

We appreciate the elimination of the request for the last four digits of the participants’ social security number in the Participants
optional category.
We continue to be concerned with the demographic information requested on the research staff and potential conflicts with official
institutional records and violations of state and Federal privacy laws. State laws and university policies often require this
information to be redacted from any archived materials – electronic or paper. Providing this information within the RPPR could be
viewed as a compliance risk for some institutions. Providing gender, ethnicity, racial and disability information is a private,
personal decision and, we believe, not the prerogative of the principal investigator(s). Publicly-funded schools and those that
receive federal funding must comply with the Family Educational Rights and Privacy Act (FERPA) provisions requiring written
consent before the release of educational records or personally identifiable information, with some exceptions. The courts have
stated that race/gender information, fall within this provision. We understand this is an optional category and the information is
useful to Federal agencies in reaching government-wide education and training goals for under-represented populations.

COGR

Other

ED

Instructions

Participants
Page 30

We share those goals and need to identify different ways to assist the Federal agencies in making those assessments but do not
believe this is the appropriate mechanism for provision of that information.
We have similar concerns with the identification of participation of individuals by person month. The RPPR request for a
quantification of time spent on the project may not reflect the institution’s official effort reporting and certification system. The
appropriate mechanism for ascertaining the time spent on a project is through the institution’s effort reporting system.

Notes

The instructions are being clarified based on this comment.

Right now, the descriptions
section doesn’t really address the
three sections. A collaborator is a
person. It was lumped into one
category because at the end of
the day, the individual is the
important level. Demographic data
always makes people think in
terms of individuals.

This is an optional section. If the agency does not want to
request demographics then it does not need to request the
information from the grantee. The instructions have been
clarified to reflect that point.

Thank you for your comment.
This is optional and if another institution has regulations
preventing the reporting on it, the grantee can choose not to
provide this data.

This data can be generated from whatever database is most
appropriate.

With regard to privacy safeguards, we recommend that a sentence be inserted in the text on Page 5 under the “Participants”
The work group feels that this information would be potentially
category, immediately after the words Privacy Act. Recommended text is in brackets below: “PARTICIPANTS: Who has been
confusing for the grantees typically submitting the report.
involved? … Confidentiality of demographic data will be in accordance with the agency's policy and practices for complying with
the requirements of the Privacy Act. [This includes the requirement that agencies will ensure that System of Record Notices reflect
any new, deleted or revised categories or use purposes of individually identifiable information collected.] Agencies use
demographic data for statistical purposes, primarily to help: …”

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10/17/2026

RPPR Comment Tracker
Comment
Source
ED

Comment
Type
Instructions

Participants Comment

Comment Response

We believe that the disability status categories describing participants are too broad and should be re-categorized to better
The format is being updated based on the comment.
describe participants under our research grants, especially those funded by the National Institute on Disability and Rehabilitation
Research in the Office of Special Education and Rehabilitative Services. The only disability categories listed in the proposed
RPPR are: “Hearing Impairment, Visual Impairment, Mobility/Orthopedic Impairment, Other and None. Left out, for instance, are
categories such as developmental and intellectual disabilities; psychiatric disabilities, and cognitive disabilities. These are large
categories and should not be lumped into “other”. We recommend that the drafters of the RPPR format consider the thirteen
categories identified under the Individuals with Disabilities Education Act (IDEA). The U. S. Census Bureau also constructed six
categories of disability status for data collection. Those categories are: sensory disability, physical disability, mental disability, selfcare disability, going outside the home disability, and employment disability.

Notes
These are the same data
elements in the RNR, so we are
keeping data elements consistent
across reports. The are the same
elements required at the time of
application.

We recommend a more thorough discussion of disability and an expansion of the concept in the proposed RPPR data collection
system. Finally, we recommend that next to the “other” category, a blank space be provided to allow applicants to write in the
name of the other disability/disabilities.
ED

Instructions

We recommend asking about participatory action research – how were stakeholders (including those with disabilities) included in
the research process.

ED

Instructions

Page 5 of the Participants section states, “if a person has contributed significantly to the project during the reporting period, provide The work group feels the instructions are clear. This section
name, role...” This information likely would have been included in the application. It is unclear who, other than
captures any individual or organization that has been directly
people/organizations named on the award and in the budget justification, this question is seeking to capture. We recommend
involved with the project.
clarifying this point.

ED

Instructions

We recommend that the drafters of the proposed RPPR format ensure that the race and ethnicity categories describing participants So noted.
are consistent with the revised OMB guidelines regarding both the direct collection of racial and ethnic data from individuals and
the manner that aggregate racial and ethnic data should be reported to agencies. When reporting aggregate data to agencies,
individuals who identified as more than one race should be reported in the “two or more races” category.

ED

Instructions

On pages 5-6 there are a series of bullets describing how demographic data is used by agencies. Then there are a series of
bullets that appear to be questions requiring a response. Again, it is not readily clear that the first set of bullets do not require a
response. This is an example of an earlier general comment recommending separate sections for instructions and background.

ED

Instructions

We recommend that the drafters provide definitions of the terms “one person month” and “whole person month” as used on page 6 The report already does this.
of the proposed RPPR.

ED

Instructions

The example on page 6 asks for information about “funding support,” and the example provided as a response states “this award.” The report has been upgraded based on this comment.
It would be more helpful if the respondent provided the name of the agency or agencies (or private funders) providing the support.

DOE/NETL

Instructions

The labor-statistics-like information proposed in the draft RPPR, while necessary to support the National Science Foundation
This information may change every year, requiring that
(NSF) mission, is inappropriate for inclusion in a progress report since it has no bearing on cost, schedule, or technical progress. agencies update it regularly. Many of the agencies only
This information is not likely to change on a quarterly basis and is more appropriate to be obtained as a separate “one-time” or “as require annual and final reports.
required” report.

HHS

Instructions

The use of the term “participants” in the RPPR may be problematic. Some agencies equate this term with “participants of a study.” The people included in the "participants" section extend
In the RPPR it refers to personnel on the grant. Suggest changing to “senior/key personnel” as this would be consistent with the beyond the "senior/key personnel".
SF424(R&R). Also, a few commenters felt grantees would provide unnecessary “participant” information on administrative
personnel.

HHS/HRSA

Data Element The information requested on participants (individuals that have worked on the project) asking for name, gender, race/ethnicity,
The report has been upgraded based on this comment.
and disability status is subject to the Privacy Act and would require agencies to establish a system of records. The practical utility
of this information is unclear. The data obtained will be unreliable and inaccurate, unless each respondent has in place a
mechanism by which they collect this information on their participants in the format that is proposed.

Participants
Page 31

source.xlsx

Agencies may pursue developing agency specific
requirements through OMB.

The work group has clarified the section.

(Other than this award) "Sentence
Funding is welcome but not
required" is misleading. Pick a
group that does Graduate
fellowships. Ford Foundation?

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

Participants Comment

Comment Response

HHS/HRSA

Data Element Even though this information is voluntary at present, there is serious concern regarding information on race, ethnicity, and disability This section is not mandatory. Additionally, the work group
about participants. In general, the proposed regulations fail to make a compelling case that the demographic data that will be
has upgraded the report to clarify this point.
reported “…benefit[s] everyone regardless of demographic category” or that reporting of this data will ensure that “underrepresented groups will have the same knowledge of and access to programs…” (p. 5). By law, employees of one awardee are
not required to divulge such characteristics. If researchers chose not to provide this information, we would not be able to comply
with such an RPPR mandate should it be mandatory.

HHS/HRSA

Instructions

For another awardee, disability status is considered health information and may not be disclosed at the individual level. It is
This section is not mandatory. Additionally, the work group
possible that voluntary disclosure would be achievable. However, it is noted that obtaining “voluntary” disclosure would require the has upgraded the report to clarify this point.
awardee to survey all participating faculty and staff, which might be perceived by them as intrusive. It is also possible providing
individual-level data on disability status is a HIPAA violation. Certain disabilities may be present but not obvious (mental health
impairments, physical conditions the individual prefers to keep private). Based on the rationale provided in the draft RPPR, what is
really being sought is EEO information, which could be provided in aggregate with less violation of privacy.

HHS/HRSA

Instructions

Re persons who have worked one person month or more: Clarification is needed regarding who are to be listed here. Include
The work group has clarified the instructions to address the
administrative staff? investigative staff? The reporting burden is substantial and duplicative. Identification of individuals and their concerns. Anyone who recieves compensentation from the
roles was in the grant proposal. The detail included in the draft RPPR – e.g., the example of a change under-graduate to graduate project should be listed, no matter the role they play.
status is given, “preferably explaining the change in involvement” – constitute an unreasonable reporting burden. Additional
justification would be needed to explain the requirement for information at this level of detail. Few of our investigators would be
identified as participants. E.g., the Principal Investigator devotes 30% FTE to the RHRC, but it is spread over three current
projects and also Center-level administrative and policy/technical dissemination activities. Thus, the PI would not be included as a
participant under the proposed definition. In some cases, reporting the number of people working on a project would pose a
privacy risk. A definition on the order of 20% or more of all person hours spent on the project seems more reasonable.

HHS/HRSA

Instructions

Page 5 participants: Who has been Involved? states that demographic data submission for persons who have contributed
This section is not mandatory. Additionally, the work group
significantly to the project is voluntary, but Page 6, Participants: What individuals have worked on the Project? has no note that the has upgraded the report to clarify this point.
demographic data requested is voluntary. If the demographic data collection on page 6 is not voluntary it would appear to be a
change in policy and it is suggested that this statement be reviewed by OGC. If the Page 6 demographic data are to be voluntary,
then the note on Page 5 should be clear that it covers all demographic data and not just the data on Page 5 regarding significant
contributors.

HHS/NIH

Instructions

A bit of a disconnect exists in the current text. On page 5, where this category is first described, it indicates "If a person has
contributed significantly to the project...". This wording could be construed to imply only senior/key persons since "contributed
significantly" is how that category of participant is defined. However, later in the instructions the first question refers to "What
individuals have worked on the project?" and includes each person (not just senior/key) who has worked at least one person
month.

HHS/NIH

Other

NIH fully supports the concept of this being a full personnel report (not just senior/key persons). In fact we now have a legislative The report will be updated based on this comment.
requirement to specifically report back to Congress on the workforce we support, in particular postdocs. So this level of detail will
be even more critical for us now.

HHS/NIH

Instructions

Since the detailed instructions already cover what we need, our suggestion is to modify the first sentence in the 1st paragraph
under the category description as follows: If a person has worked at least one person month on the project during the reporting
period, provide name, role in project, and major activities performed.

The report will be updated based on this comment.

NASULGC/
ESCOP

Instructions

The definition of Participant should better explain that it does not include people who participated by generating research results
through being part of activities such as focus groups, survey respondents, clinical trial subjects, taste panels, etc.

The work group will update the report to clarify that
participants do not include those people who have
participated in focus groups, trial subjects, etc.

NASULGC/
ESCOP

Instructions

The report currently indicates this.

NASULGC/
ESCOP

Instructions

In the individual participants data element, if the participant was an undergraduate or graduate student or in a post-doctorate
position, the report should indicate that person’s current status if different than when participation occurred. This information will
allow assessment of the educational impact of the activity.
All three Participant data elements reported should provide additional information on international participants, particularly
resources provided by the international participant or their institution.

Participants
Page 32

source.xlsx

Notes

The report will be updated based on this comment.

Agencies may pursue developing agency specific
requirements through OMB.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

Participants Comment

Comment Response

NCAR

Instructions

At any given time we have around 550 employees working on the core funded research at or above the one person month per
This is an electronic system implementation issue. The work
year. In the format proposed, we would need to list every participant, their role in the project, the # of months worked, their
group will forward your comment to those who develop the
contribution and the funding support, in addition to their demographic information. We understand that NSF and other agencies
electronic solution.
need to have this information in their databases to track, however, as an FFRDC with a large cooperative agreement, it can be
very time consuming to enter this information. It would be advantageous if there was an upload capability so that we did not need
to type in each person and their corresponding information. In addition, it will be a very onerous task to acquire that specific
information for each individual participant.

NCAR

Other

Last year we listed over 600 organization partners. To identify the partners, we either had to search in the database and select the This is an electronic system implementation issue. The work
partner or we had to add the organization within the Fastlane system. As mentioned above, it would be very helpful if the system group will forward your comment to those who develop the
allowed for an upload capability.
electronic solution.

NSF

Instructions

This optional section requests information about collaborations. The same information is also requested products and outcomes
category (networks and collaborations).

NSF

Instructions

While we appreciate the fact that participants involved now includes information on ethnicity, etc., we would also like to see
Agencies may pursue developing agency specific
information captured about the students trained under awards. These students are often not actually "participants" officially, but
requirements through OMB.
this is a part of the overall outreach provided by the award. We feel this information is important. Furthermore, it would be nice if
the reporting could include advances achieved through the award. What did they start with and how many more students from
diverse backgrounds are now heading out to careers in research? Where are the trainees going? Hopefully not only into medical
fields.......

NSF

Instructions

There is a request for information on "non-formal collaborations or contacts with others outside the United States." This is made as Agencies may pursue developing agency specific
part of a bulleted list of 'for instances' regarding collaborations. Given the increasing importance of international collaborations,
requirements through OMB.
shouldn't this request for information be raised above the level of one among several 'for instances'?

NSF

Instructions

Also, it is not clear what a 'non-formal collaboration' entails as opposed to a formal one - and why do we want information only on
the non-formal ones?

The work group will update the report based on this comment.

NSF

Instructions

In the same vein as (3), given our interest in interdisciplinarity, mightn't information regarding this also be raised above its current
status of one 'for instance'? In fact, more information may be needed about the disciplines involved and the character of the
impacts (e.g., what, if anything, has been "transformed," and for whom?).

Agencies may pursue developing agency specific
requirements through OMB.

NSF

Instructions

On page 6 I think the phrase "funding information is not required, but welcome" actually applies to the demographic information
being requested. That wording is confusing and allows the respondent to easily opt out. It might be better to phrase it along the
lines of "the following demographic information is not mandatory, but would be extremely useful to NSF (or whichever agency is
collecting)."

The work group feels that the current language is appropriate
for the nature of the request.

NSF

We agree that these two categories should be optional in the RPPR.

Thank you for your comment.

University of Other
Vermont

[You should not implement the RPPR unless and until grants.gov can feed such information into it.] The same applies to
participant information which is collected in the grants.gov electronic application and is not likely to change during each reporting
period. It should be collected at the project's inception via grants.gov, and displayed in the RPPR, with an option to identify
changes only if there are any.

The work group plans to move forward with implementation.
The data provided to Grants.gov is only for the pre-award
phase. The work group will pass your comment along to
those developing the electronic solution. There is the intention
to develop a solution that will be capable of storing data and
prepopulating the report where appropriate.

University of Other
Vermont

Collecting gender, race, and ethnicity information about participants is not only time consuming but suggests that there may be
Agencies will not do any evaluation based on the information.
more or less value associated with work done by people of one gender, race, or ethnic background than another. The use of the The use of the report may have been misinitepreted. The
term "race" in reference to human beings is outdated. Scientists have established that genetically there is no such thing as "race" demographics information being requested are government
in the human population. The term “race” is nothing but subjectively assigned anatomical and social distinctions. Human genetic wide standard categories used consistently in several forms.
and cultural diffusion makes it senseless to attempt to divide human populations into these groups. Most Americans are of
complex ancestry, are multi-ethnic and multi-“racial” and will select one of their ancestries over another at one time (for example on
a census form), and a different one for another purpose (such as this one). This kind of data, especially when it is optional, would
be highly misleading when used to develop statistics about populations being served, which you state as your reason for collecting
this.

Participants
Page 33

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Notes

The work group will update the report based on this comment.

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RPPR Comment Tracker
Comment
Source

Comment
Type

ASU

Instructions

DoC/NIST
DoC/NIST

Extramural: Impact section--this would be really great for the TIP emphasis.
Other
Thank you for the comment.
Instructions Extramural: Very publication oriented…and very little quantitative information about the achievement of the science No action Needed.
or technology relative to the knowledge-base to see how much "better" this actually is…you could really wave
hands here and have no concrete impact to point to that is measureable in terms of improved science/technology
achievement, so adding some quantitative comparison to a baseline of "what could be done at the start of the
project" is needed or this is so much hand waving that it isn't funny. We would never get info like a "performance
improvement of x over y for z dollars in this project" with these instructions it would all be anecdotal hand waving
and counting of pubs, patents and presentations. Adding some questions to describe impacts relative to the
previously defined baseline would greatly strengthen this and make it more concrete and less prone to hand
waving.

ED

Instructions Tracking Performance Over Time: In both the Accomplishments and Impact categories, there is no provision for
There is no change necessary. Reporting periods are
[Comment was also under
identifying accomplishments and/or impacts that have been reported in more than one reporting period (e.g.,
artificial endpoints. The grant life cycle is comprised of all the Accomplishments tab.]
budget period or project year), but at different stages of development. Most noteworthy accomplishments of
reporting periods from award to close out.
research and development (R&D) activities are not discrete events that occur within a one year time frame and then
disappear; rather, both accomplishments and impacts typically mature over time from smaller, incremental
accomplishments or milestones. For example, in one year a grantee may report the successful development of a
product (e.g., a database) or technology that is reported as a peer-reviewed publication the following year.
Agencies need to have a way to link these accomplishments and track their evolution. We recommend that RPPR
form ask grantees: (a) whether accomplishments and/or impacts reported in the current reporting period (e.g.,
budget period or project year) are an outgrowth of accomplishments and/or impacts reported in a previous period;
and (b) if so, describe the relationship.

ED

Instructions Linking Accomplishments and Impacts to Goals: We are concerned that the current version of the form provides no The work group feels this linking will naturally occur.
mechanism by which grantees can link accomplishments and impacts to goals and/or performance measures. This However, if the program feels this capability is essential, it
is particularly important for grants with multiple projects and goals – such a linkage would help agencies determine may pursue developing agency specific requirements
grantee progress in different areas. We recommend that the RPPR form require grantees to link their
through OMB.
accomplishments to their goals and/or performance measures. One way to do this would be for the form to use an
internal numbering system identifying and linking project goals and activities with the goals and accomplishments to
which they apply.
Instructions Regarding the optional Impact category, the instructions tell respondents to use “a ‘field’ or ‘discipline’ that
The work group will update the report based on the
corresponds to a single academic department.” We recommend adding the words, “if appropriate,” after
comment.
“department.” All research may not be done in an academic setting. For example, this Department funds research
on prosthetic devices, which are not generally covered by an academic discipline.
Instructions The second sentence on p. 8 should be amended to add the word “policy,” so the new sentence would read,
The work group feels the present instructions accurately
“Describe distinctive contributions, major accomplishments, innovations, successes, or any change in policy,
captures the intent of the section.
practice or behavior…” (italics added).
Instructions
The work group will update the report based on the
On page 8 it is unclear if the second set of bullets are background information or items requiring a response. If
comment.
requiring a response, why are they separated from the instructions section on page 9.
Definition
of
Impacts:
Defining
impacts
in
part
in
terms
of
“major
accomplishments”
is
likely
to
cause
confusion
Instructions
The work group feels the language used in the report is
among PD/PIs completing the RPPR form as it appears to be redundant with the previous Accomplishments
appropriate.
category. Rather, the emphasis should be on describing the use or adoption of R&D findings and products
produced under the grant award to advance knowledge, build capacity to generate research, change or improve
policy, practice, and/or improve overall society.
Instructions Impact on the Development of Human Resources: We are concerned that this type of impact described in the
The report currently addresses this concern. The specifics
proposed RPPR is limited to the human resource development in science, engineering and technology instead of
provided are examples, not a defininitive list of types of
being extended to include all potential beneficiaries of R&D investments, including practitioners and end-users or
impact.
consumers. We recommend that this definition be broadened to include impacts on the functioning of human
subjects/participants in R&D studies.

ED

ED
ED
ED

ED

Impact
Page 34

Impact Comment

Comment Response

Notes

This goes beyond the scope of a grants specific progress
Some respondents indicated the need to expand further on the Optional Category for Impact on society. It was
report. However, agencies may pursue developing agency
suggested that the Impact section ask for a description of potential policy implications or actual policy actions based specific requirements through OMB.
on the scientific findings. This would provide an opportunity for investigators to describe the science in a more
policy-relevant manner which would communicate the value of science in its ability to serve the values of society.

source.xlsx

Wouldn’t the PI automatically be
linking the accomplishments to
the approved application. We do
not not need to elaborate on it.
[Comment was also under
Accomplishments tab.]

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

Impact Comment

Comment Response

HHS/HRSA Instructions A commenter from the Maternal Child Health Bureau noted the section on “Impact” is very broad and requests
information that is beyond the scope of most Maternal Child Health(MCH) research projects. Currently MCH
research grantees are required to report on “Evaluation/Impact” that describes the potential impact of the study on
the health care of individuals being served and potential impact at the local, state, regional and/or national levels.
HHS/HRSA Other
A commenter noted on page 8 of the document “Draft Format” states that the information provided in the optional
section “impact of the project” makes the case for Federal funding of research and education. If this is true, then
this section should not be optional, it should be required.

Notes

Agencies may pursue developing agency specific
requirements through OMB. Additionally, the agency may
consider using the PPR instead of the RPPR.
Only one section is mandatory, while the other sections are
optional. This combination of mandatory and optional
sections gives agencies the maximum flexibility to collect
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs.

HHS/HRSA Instructions Bullets related to Impact and Changes in Practice may need to focus on educational evaluation outcomes, such as Agencies may pursue developing agency specific
the impact of the intervention on targeted groups, especially targeted minority groups or be replaced by the
requirements through OMB.
questions under the category “What is the impact on society beyond science and technology?”
HHS/HRSA Instructions Bullets related to how the research benefits the nation may need to be worded to capture the future outcome, since The report currently addresses this concern.
some outcomes, such as organ donation often occurs at a later date.

NSF

Impact
Page 35

Page 9, under "Impact on the Development of the Principal Discipline(s) of the project," the respondent is told "How Keeping an updated list would be extremely time consuming
the field or discipline is defined is not as important as covering the impact the work has..." We STRONGLY object and difficult. When a final taxonomy has been developed,
to that. A standardized taxonomy should be provided. SRS is working to harmonize our internal taxonomies and the work group will consider including it as an update to the
format.
we are especially concerned about the development of new and emerging fields. If projects from the funding
agencies which help foster both new and emerging projects as well as interdisciplinary projects are not coded, then
the value of this data is severely limited. SRS could provide an interim taxonomy to be utilized and we will be
revising our taxonomies in the future.

source.xlsx

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

DoC/NIST

Instructions Extramural: This section is critical to managing cooperative agreements and needs to be in the mandatory section. Only one section is mandatory, while the other sections are
optional. This combination of mandatory and optional
We strongly suggest expanding to include OPPORTUNITIES, that may not have been evident at the time the
sections gives agencies the maximum flexibility to collect
proposal was submitted, and capture them here.
only the information required, without overburdening others
with unnecessary requirements. Agencies can select the
information needed to perform its reviews for a specific
program. Information required can vary between agencies
and programs. Agencies may choose which sections they
require a grantee to complete. Agencies may also pursue
developing agency specific requirements through OMB.
Instructions Extramural: Also make clear that this is not the process to use for asking for prior approval of something that
Based on the comment, the work group will update the
requires advance approval or is a major problem, or addresses a special award condition. This is not at all clear in section to clarify its purpose.
the instructions.
Instructions Extramural: This is the section we mean: CHANGES/OPPORTUNITIES/PROBLEMS/SPECIAL REPORTING
Agencies may pursue developing agency specific
REQUIREMENTS If not previously reported in writing, provide the following additional information, if applicable:
requirements through OMB.
Changes in approach and reasons for change; Actual or anticipated problems or delays and actions or plans to
resolve them; Changes that have a significant impact on expenditures; Significant changes in use or care of
animals, human subjects, and/or bio hazards; Special reporting requirements specified in award terms and
conditions; and As stated in the regulations, include any adverse conditions which materially impair the
ability to meet the objectives of the award.

DoC/NIST
DoC/NIST

Changes/Problems Comment

Comment Response

COGR

Other

ED

Instructions Regarding changes to care of animals, human subjects, and/or biohazards, we recommend putting human subjects The work group will update the section based on the
before animals in the list. Also, in matters relating to human subjects, the specific term of art for the approving
comments concerns.
entity is “institutional review board” or “IRB.” We do not believe that asking whether the change was approved by
the “institution” is sufficiently precise. For example, a PI may desire to change some aspect of the research that
involves human subjects. If the PI goes to the department chair and obtains approval, the researcher still must
obtain approval from the IRB. We recommend changing the conditional statement “if required” to make it more
specific. For example, the phrase might state, “If required by the IRB approval, 45 CFR part 46, or the human
subjects assurance or policy of the institution, …”

Notes

Thank you for your comment.
We endorse the shift of the Changes/Problems/Special Reporting Requirements from mandatory to optional and
appreciate the changes in the reporting of changes that have a significant impact on expenditures. As currently
proposed, investigators are prompted to discuss events or situations that will affect expenditures without attempting
to assign rates of expenditures

Also, not all changes have to be reported to the funding agency. However, if the change is the result of an IRB
conclusion that there was a deficiency in compliance with protection of human subject requirements, that change
must be reported to the agency. We recommend, at minimum, changing the final sentence to say “or” reported to
the agency, instead of “and” reported to the agency.
ED

Instructions Generally, this Department does not do research involving animals, so we can’t speak to issues related to
The work group feels no change is needed.
approvals regarding the use or care of animals, however, we recommend that the form address each of these areas
of concern separately (i.e., human subjects, use or care of animals, and biohazards). By addressing each area as
a separate subset of the category, the question won’t be so general that the instructions are not helpful or too
confusing by mixing up the different requirements in the same question.

HHS

Data
Element

HHS/CMS

Instructions Under Actual or anticipated problems or delays and actions or plans to resolve them--change sentence to
read: Describe problems or delays encountered during the reporting period and corrective action planned to
resolve implementation problems and state the effect these problems had on achieving the project goals during
remaining schedule or plans to resolve them.
Instructions Under Changes that have a significant impact on expenditures--add the following second sentence: Also
indicate if carryover of unobligated funds is anticipated.

HHS/CMS

Are there other elements that should be included under the reporting categories? Changes/Problems/Special
Reporting Requirements: does not request information on changes to key personnel.

HHS/HRSA Instructions It was further noted that the section on “Changes/Problems/Special Reporting requirements” does not request
information on any changes in key personnel. MCH Research grantees are required to provide information on
changes of key personnel and to provide biographical sketches for any new key personnel.
Changes/Problems/Special RR
Page 36

source.xlsx

This concern has been addressed in response to a previous
comment
The work group feels the language currently used is
appropriate.
The work group feels this type of data is not appropriate for
this section.
The work group feels this type of data is not appropriate for
this section.
10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

NSF

Instructions As with the current NSF version, there is a request for information regarding "Significant changes in use or care of This concern has been addressed in response to a previous
animals, human subjects, and/or biohazards." The last sentence of this section (page 11) says; "If required, were comment.
these changes approved by the institution and reported to the agency?" Technically, this is a reasonable question but PIs often do not realize that changes to protocols require IRB approval and therefore do not obtain the requisite
approval. I assume that this is also the case for IACUC and biohazards So, it would not be amiss to insert a
reminder to the PI here e.g. "Changes in approved protocols for human subjects research or research governed by
an IACUC must be reported to the institutional governing body. Has this been done and approved?"
Other
We do not agree that this category should be optional. Instead, we believe that this category should be mandatory Only one section is mandatory, while the other sections are
because documenting the changes or challenges that occur during research work is an important way to
optional. This combination of mandatory and optional
communicate the actual work and progress of federally-funded research. This documentation provides agency staff sections gives agencies the maximum flexibility to collect
with the information it needs to conduct proper oversight of research awards and address any problems. In
only the information required, without overburdening others
addition, the information provides a historical "paper trail" of what was planned and what actually occurred. This is with unnecessary requirements. Agencies can select the
especially useful when agency staff is re-assigned to other projects or leave the agency, and historical knowledge information needed to perform its reviews for a specific
about a project may be lost.
program. Information required can vary between agencies
and programs.

NSF

Changes/Problems/Special RR
Page 37

Changes/Problems Comment

Comment Response

source.xlsx

Notes

10/17/2026

Comment
Source

Comment
Type

HHS

Data
Element

Special Reporting Requirements Comment

Comment Response

Are there other elements that should be included under the reporting categories?
Changes/Problems/Special Reporting Requirements: does not request information on estimated
unobligated balance.

This concern has been addressed in response to a
previous comment.

HHS/NIH

Instructions Augment the question on “Significant changes in use or care of animals etc…” to also include
specific fields for IACUC approval date & IRB approval date. (Or if all the structured data fields
will be in the Cover, add these there), Regardless of location, agencies do have a requirement to
monitor compliance of these approvals as part of the annual progress report.

The work group will update the form based on the
comment.

NSF

Other

This concern has been addressed in response to a
previous comment.

There is no place in the proposed document for the PI to indicate the percentage of funds
expected to remain at the end of the reporting period. How will the Program Directors know if
residual funds are larger than 20%?

Notes

RPPR Comment Tracker
Comment
Source
ASU

Comment
Type

Final Project Report Comment

Comment Response

Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.
Other
Most responses indicated that this format with minor modifications would be appropriate for a final report.
Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.
Other
It was felt that using the same format for final reports will provide consistent information across the life of a project. Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.
Instructions Some respondents indicated that as a matter of public policy, PIs should be required to report on the entire project Thank you for your comment. The Working Group will
in a final report, although from the perspective of a PI reporting for just the last year would be easier.
consider this comment after development of the interim
research performance progress report effort has been
completed.
Instructions Others indicated that the PI should provide information for both the final period and a brief summary statement for Thank you for your comment. The Working Group will
the entire project period of the overall scientific and/or scholarly accomplishments. The other subcategories could consider this comment after development of the interim
just be completed for the last reporting period. Repeating information in these subcategories that was submitted in research performance progress report effort has been
prior reports is redundant and should not be required in the final report.
completed.
Other

A similar format is desired for both interim and final reports.

DoC/NIST

Other

Lab: The proposed standardized format is for interim reporting only, not final reports. Why not standardize all
reporting formats at the same time?

DoC/NIST

Other

DoC/NIST

Other

COGR

Instructions With regard to the creation of a final reporting format, we believe this format with minor modifications could serve as Thank you for your comment. The Working Group will
a useful model. For final reporting, recipients can be expected to provide a final statement of scientific and/or
consider this comment after development of the interim
scholarly accomplishments including if appropriate training and professional development activities. But other
research performance progress report effort has been
categories, particularly the optional categories of products/outcomes and participants should only add information completed.
for the last reporting period. Repeating publication information, the names of participants, etc., submitted in prior
reports should not be required in the final report.

DoD

Other

ASU

ASU

ASU

ASU

Notes

Final Project Report
Page 39

Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.
Extramural: The basic information requested is not all that different from that we already require from our awardees Thank you for your comment. The Working Group will
in the quarterlies. What it will do is standardize the type of information supplied by all awardees regardless of PMT consider this comment after development of the interim
outlook. Having said that, I don't believe that the format being proposed is appropriate for a final report. We should research performance progress report effort has been
continue to have a final quarterly and a final overall technical report at the conclusion. However, the final technical completed.
report should summarize the entire project where did it succeed; where did it fail; how does the failure impede the
impact goals; company's future intentions as to goals of project. The company's final technical report should be
only one arm of the projects closing documents. This must be accompanied by a report from the PMT covering the
same points as the company's report and giving its own evaluation of the project and its future.

Extramural: It is also not a good template for a final report. We would not want to collect any of the diversity
information for example, because that will really complicate things in terms of keeping personal identifiable
information (PII) around.

Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.

An important distinction between an interim and final report is that for many agencies: The interim report is a
Thank you for your comment. The Working Group will
relatively informal communication between a principal investigator and federal program manager; while the final
consider this comment after development of the interim
report serves as an archival scientific or technical report that documents the purpose, methodology, results and
research performance progress report effort has been
conclusions of the research project and will be available, as appropriate, to other researchers, technologists
completed.
interested in applying research results, and the public. Thus, the final report may be deposited in a repository such
as the Defense Technical Information Center or National Technical Information Service. Some agencies require a
grantee or contractor to submit that final report using a Standard Form 298 cover sheet that conforms with ANSI
Standard 239.18, a requirement that often does not apply to interim reports. Notwithstanding the distinction
between interim and final performance reports, it would be desirable for agencies and recipients to be able to use
the same format for them.

source.xlsx

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

Final Project Report Comment

Comment Response

Notes

RECOMMENDATION II: The interagency team should seek to finalize the interim performance reporting format in
a way that maintains the format’s usability for final reports also. Ideally, we should avoid unnecessary duplication
by minimizing the information contained both in the cover sheet of the format and in the SF‑298 cover sheet for a
final report.

ED

Other

Regarding using this format for final reports, the developers of the format should consider using one system and
Thank you for your comment. The Working Group will
format that collects data about the grant, about progress, about performance data, and narrative interim and final
consider this comment after development of the interim
report information. For example, demographic data about the grantee and the discussion of interim progress
research performance progress report effort has been
provide needed background materials for interpreting the final outcomes. Separate formats for interim and final
completed.
reports are likely to create duplication, both in the submission of data by grantees and in the review of data by
Federal agencies. Grantees should not be required to provide data in the final report that they have provided
previously in interim reports since this data should already be stored by the agency in an electronic format. It
would, however, be useful for grantees to provide data in the final report on their final budget period, as well as any
summary information and conclusions they have drawn regarding the overall success or impact of the project.

ED

Other

We also note that if the draft format is used for final reports, these are permanent records for ED. If the final report
is created and maintained in electronic format, then these records must meet the standards contained in the
National Archives and Records Administration (NARA) guidance concerning the creation, maintenance, and
transfer to NARA custody of permanent electronic records.

HHS

Other

HHS

Other

HHS

Other

A majority of HHS awarding agencies provided comments that with some modifications the proposed interim format Thank you for your comment. The Working Group will
consider this comment after development of the interim
could be appropriate for a final report. A minority of comments reflected an opinion that many of the categories
research performance progress report effort has been
would not be relevant to a final report.
completed.
If so, should recipients be directed to provide summary information for the entire project period, or just for the last
Thank you for your comment. The Working Group will
period? There was no consensus among commenters regarding this question, however a majority of the responses consider this comment after development of the interim
received indicated that a reporting of the entire project period is necessary. It is important to note, however, some research performance progress report effort has been
of these responses stated that information specific to the last period should also be included. Alternatively, some of completed.
the comments requested the final report address the last period but added that a summary of the entire project
period would be helpful.
Thank you for your comment. The Working Group will
If not, what information should be included in a final report? OGPOE received little feedback regarding this
consider this comment after development of the interim
question.
research performance progress report effort has been
completed.

HHS/AoA

Other

HHS/AoA

Instructions If so, should recipients be directed to provide summary information for the project period, or just the last period?
Entire project period.

HHS/AHRQ

Other

HHS/AHRQ

Instructions If so, should recipients be directed to provide summary information for the project period, or just the last period?
The entire project period would be satisfactory. Everything would be in one report. I think a section should be
dedicated to the last budget period then describe the project period as a whole.

HHS/CDC

Other

Final Project Report
Page 40

Is the proposed format appropriate for a final report? Yes

Is the proposed format appropriate for a final report? Modifications and editing would have to take place for the
final report but could be used.

It is stated that this document is used for the interim progress report only, and may be adopted for the final report.
As such, an interim progress report will not be required during the last budget period of the project period. If
assessment of progress has been evaluated for each continuing period within the project, the last and final report
could provide accomplishments during the final budget period and a summary of the overall accomplishments and
success of the project.
source.xlsx

Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.

Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.
Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.
Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.
Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.
Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.

10/17/2026

RPPR Comment Tracker
Comment
Source

Comment
Type

Final Project Report Comment

Comment Response

HHS/CDC

Other

HHS/CDC

Other

HHS/CDC

Other

HHS/HRSA

Other

HHS/HRSA

Other

HHS/HRSA

Other

HHS/HRSA

Other

HHS/HRSA

Other

HHS/NIH

Other

Is the proposed format appropriate for a final report? With the suggested edits noted throughout, yes, this would be Thank you for your comment. The Working Group will
adequate for a final report.
consider this comment after development of the interim
research performance progress report effort has been
completed.

NSF

Other

NSF

Other

We believe that the RPPR provides an appropriate starting point for developing a format for final project reports.
Thank you for your comment. The Working Group will
Except for the "Participants" category, all other categories proposed for the RPPR should be mandatory for the final consider this comment after development of the interim
project report format. These categories provide important information for documenting the work conducted and the research performance progress report effort has been
results and impact of that work.
completed.
In addition, the final project report format should include a requirement for some type of brief summary of the results Thank you for your comment. The Working Group will
of research that, in turn, could then be made available to the public. Recent federal audits and surveys indicate the consider this comment after development of the interim
research performance progress report effort has been
public is interested in obtaining the results of federally-funded research, including publication citations and brief
summaries. Requiring a brief summary in a final report would aid agencies in collecting information that they could, completed.
in turn, disseminate to the public

Final Project Report
Page 41

Notes

Is the proposed format appropriate for a final report? Yes. A complete summary of the entire project by year
should be required.

Thank you for your comment. The Working Group will
consider this comment after development of the interim
research performance progress report effort has been
completed.
Recipients should be directed to provide a summary for the last project period that should emphasize final
Thank you for your comment. The Working Group will
outcomes, impacts, and products. A brief synopsis of the information presented in previous progress reports would consider this comment after development of the interim
be useful as well. If the NC/I/CO wants any additional information in the final report they should be directed to
research performance progress report effort has been
specify that in the FOA.
completed.
Thank you for your comment. The Working Group will
Appropriate for a final report? No, not in its present form. A final progress form needs to include an overall
consider this comment after development of the interim
summary and accomplishments of the entire project period-more like an executive summary. Many of the listed
research performance progress report effort has been
categories are not relevant a final progress report. If so, should recipients be directed to provide summary
completed.
information for the entire project period, or just for the last period? Just the last period. If not, what information
should be included in a final report? A final progress form needs to include an overall summary and
accomplishments of the entire project period-more like an executive summary. Many of the listed categories do not
relate to the final progress report.
Format appropriate for a final report? One office asked how will agencies integrate existing OMB approved
Thank you for your comment. The Working Group will
progress reports with agency and program specific elements into this proposed format? If agencies still have to
consider this comment after development of the interim
maintain their separate OMB approved reports, there will be a duplication of information since respondents will
research performance progress report effort has been
have to provide the cover page elements for this proposed standard form and most of the same information when completed.
reporting using the agency form. Unless there is an integrated government-wide portal or system that collects the
cover page information and then permit respondents access to the agency specific form, there will be duplication of
effort and burden.
Format appropriate for a final report? One commenter indicated “NO” noting further that for a final report, some of Thank you for your comment. The Working Group will
the categories in the RPPR would require too much detail. It appears that the RPPR would require too much detail consider this comment after development of the interim
on some information including personnel, changes/problems rather than focusing on the outcomes/findings of the research performance progress report effort has been
research project. To minimize reporting burden for grantees submitting final reports, MCH Research grantees are completed.
required to submit a concise final report that addresses the following categories: Introduction (nature of research,
purpose and methods, nature of findings); Literature review; Study design and methods; detailed findings;
Discussion and Interpretation of Findings; and List of products. Also, a final report is submitted in narrative and no
forms need to be completed.
Format appropriate for a final report? Another commenter, indicated yes, and once the RPPR is final it should be Thank you for your comment. The Working Group will
used for both progress and final reporting to provide comparison information and minimize reporting burden.
consider this comment after development of the interim
research performance progress report effort has been
-If so, should recipients be directed to provide summary information for the entire project period, or just for the last Thank you for your comment. The Working Group will
completed.
period? Several commenters recommended the inclusion of a summary for the entire project period, being mindful consider this comment after development of the interim
research performance progress report effort has been
of any reporting burden to the grantees.
completed.
-If not, what information should be included in a final report? One commenter noted that although the format is
Thank you for your comment. The Working Group will
appropriate, some additional information may be useful. The final report could include information about how the
consider this comment after development of the interim
project builds on previously funded agency grants, lessons learned, suggestions for continued study; plans for
research performance progress report effort has been
dissemination locally and nationally; and sustainability of the program in the targeted region/population in the
completed.
absence of federal funding. One (copy) of the products resulting from the project should be included with interim
and final reports.

source.xlsx

10/17/2026

SRS Comments - 10-24-08

Comment Source
SRS

Comment Type
SRS Comment
Other
For SRS purposes, we suspect that the
type of information requested would be
more useful in project final reports than in a
series of interim reports. What is the final
progress report/how will it differ from the
interim report (or what do you envision the
final progress report to be?)

SRS

Other

SRS

Other

SRS

Instructions

SRS

Other

SRS

Instructions

SRS

Instructions

What is the frequency or timing or reporting
period required of university PI reporting for
interim progress reports (twice a year?;
three times during the life cycle of an
individual grant? etc).
For example, asking for what the project
produced (publications, technologies,
inventions, and patent applications) seems
burdensome for an interim progress report
especially given that these are the same
sorts of reporting metrics required of
universities to provide i-Edison at the
completion of the research activity
Suggest providing clarification that this
report is only for grants and cooperative
agreements not contracts. Research is
done under contracts and these
requirements do not apply to contracts.
Uniform wording is used to clarify this
project. Please see wording on page 1 first
paragraph.
To be consistent with the above point,
suggest replacing “award” or “research
grants” with “research award” throughout
the document.
SRS has a specific need for data related to
postdocs. To ensure that postdocs are
included when completing the form, we
suggest providing an example that uses
postdocs. Please see the example
“Postdocs who started out as and was
previously reports as a Graduate Student”
on page 6 under the "What individuals have
worked on the project?”
Suggest collecting the demographic
information immediately following the list of
“What individuals have worked on the
project?”

SRS Comments - 10-24-08

SRS

Other

Although above we have suggested that the
demographic information on page 7 is
reported with the list of individuals working
on the project on page 6, we also want to
point out that given that the voluntary nature
of the demographic information and its
sensitivity, requesting aggregate counts
may be less burdensome and thus easier
than the current request. However, if
aggregate counts are requested, a separate
form would facilitate standardization.

SRS

Instructions

SRS

Other

SRS

Instructions

SRS

Instructions

Please clarify the following demographic
information instruction on page 8,
“Submission of such demographic
information is voluntary and need not be
provided if previously submitted.”
Please clarify – what’s the relationship
between the PPR and the RPPR
As with the draft report RPPR, we suggest
providing clarification that this report is only
for grants and cooperative agreements not
contracts
Please provide clarification for “full body of
your comments in the text of the message
and as an attachment.” Are submissions
requested as text as well as electronic files?

SRS

Instructions

SRS

Instructions

SRS

Other

Please clarify the meaning of “person
month” – is it intended to mean “FTE”?
How is “significantly” defined? Is it defined
as the “nearest person month” as before
(which needs clarification)?
Just to point out that none of the types
disabilities originally listed include cognitive,
mental or emotional disabilities.

SRS Comments - 10-24-08

Comment Response
This format is intended only for use in
submission of interim reports. The
working group plans to look at the
contents of the final progress report
after development of the interim research
performance progress report effort has
been completed. This is clearly stated in
both the federal register notice.
For the minimum reporting frequency
requirements, please refer to OMB
Circular A-110. However, agencies may
specify their own reporting frequencies,
so long as it is in compliance with A-110.
The working group noted that not every
agency reports to I-Edison. Additionally,
the format allows agencies to choose
which information they collect, which will
reduce duplication of data requests.
Finally, this format has been designed for
use by Program Officials, which is a
different audience than those who use IEdison.
This distinction has been clarified in the
most current version of the format.
However, the working group notes that
agencies who feel this is appropriate for
use on certain contracts may do so.

We believe this is accomodated by
changes in the most recent version of the
format.
This is an agency specific issue. As
necessary, agencies can provide specific
instructions with the format. The
examples provided in the report are not
meant to be limiting.

The working group discussed this issue in
great detail and believes that it is best to
have the information in separate
components to maximize use of the
format by the agencies supporting
research and research-related activities.

SRS Comments - 10-24-08

The working group fully understands the
voluntary nature of the demographic
information, and, its sensitivity. However,
as included, the format can be
implemented to permit an individual to
respond. Using composite data would
push the burden of collection on the
institution, and, they have voiced strong
oppostiion to this. Additionally, some
agencies' mandates would not be
satisfied by the collection of aggregate
data.
The working group has modified the
language to clarify the intent of this
sentence.
The latest version of the format clarifies
this point.
The latest version of the format clarifies
this point.
The working group has clarified the
instructions.

The working group believes that the
current language is clear.
This is an agency specific issue.
Agencies may provide clarification if they
feel it is necessary.
The types of disabilities in the current
format are being kept as is to remain
consistent with the R&R application
forms.

#

Action Item for RPPR Finalization

1
2
3

8

Clarify concept of "optional" and "mandatory" sections
Consider adding an abstract section to the final format
Consider how to clarify the RPPR format when in paper
form
Change "activity" to "project" under first bullet of
"Accomplishments and under the first sentence of the
instructions.
Where appropriate, change “none” and “no change” to
“nothing to report”
Check the document for language consistency
Create a "Budget" section. Use R and R budget section
as a model. Add this section at the very end.
Add a "Special Reporting Requirements" section

9

Add "Signature" blocks including name, and title

10

Add a "Submission Date" block

11

Add a "Name of Submitter, if other than PDPI" block

12

Add blocks for "Submitter email and telephone #"

13

Consider adding a "Change in Primary Performance
Site" data element
Develop language for mandatory accomplishments
section re: significant changes
Add "(Include a discussion of stated goals not
Accomplishments tab
accomplished during this reporting period.)" to the
#6
instructions.
Move the last sentence of the second paragraph of the
Accomplishments tab
"major goals of the activity" section up to the first
# 18
paragraph.
Delete parentheticial that starts "e.g., undergraduate…"
Accomplishments tab
from the "opportunities for training and professional
# 20
development" section
Add"(both positive and negative)" after "conclusions" in Accomplishments tab
# 41
item 3 of the "what accomplished" section.
Add the following language: "Agencies will determine if
reports are available to the public, if they determine they
General tab # 205
are, agencies will be expected to develop specific search
and report tools.
Change the title of the "Products/Outcomes" section to "ProductsOutcomes"
tab # 6
"Products"
"ProductsOutcomes"
Add "copyrightable works" as an example within the
tab # 7
"Products" section
"ProductsOutcomes"
Add "A short description of each site should be
tab # 21
provided." to the instructions regarding websites
Add an example list under the "Other" category. Use :cell "ProductsOutcomes"
tab # 23
lines, DNA probes, animal models as examples
In the instructions add "This is not a substitute for any
"ProductsOutcomes"
other invention reporting required under the terms and
tab # 24
conditions of the award."

4
5
6
7

14
15
16
17
18
19

20
21
22
23
24

Comment

Date
Completed

“General” tab # 92
“General” tab #108
“General” tab #116
“General” tab #122

March 27, 2008

“General” tab #123

March 27, 2008

“General” tab #122
Other Elements tab #
5, 9
Other Elements tab #
18
Data Elements Cover
Page tab # 6, 12
Data Elements Cover
Page tab # 14
Data Elements Cover
Page tab # 16
Data Elements Cover
Page tab # 16
Data Elements Cover
Page tab # 18
Accomplishments tab
#3

May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 7, 2008
May 20, 2008

May 20, 2008
May 20, 2008
May 20, 2008

25
26
27

28
29
30
31
32
33
34
35

36
37
38
39
40
41
42
43
44
45

In the "Publications" data element add language "Not
necessary to include publications already referenced
above."
Add a data element requesting the status of the
publication
Separate the sentence beginning "Please provide
optional demographic…" into a new paragraph to
emphasize it.

"ProductsOutcomes"
tab # 28

May 20, 2008

"ProductsOutcomes"
tab # 29

May 20, 2008

"Participants" tab # 3

May 20, 2008

Include the sentence notifying grantees that responses in
"Participants" tab # 3
this section are optional in instructions section.
Change the title to "Participants and other collaborating
"Participants" tab # 4
organizations"
Add "Do not Wish to Provide" as one of the data values. "Participants" tab # 7
Add a blank space for users to list additional disabilities. "Participants" tab #
18
Reorganize the text in "Demographics" section to clarify "Participants" tab #
23
the purpose of the section
"Participants" tab #
Clarify that the data on funding support is for funding
25
from awards other than the one being reported on
"Participants" tab #
Create a "Demographics" section
33
Change 1st sentence in paragraph to read: If a person
"Participants" tab #
has worked at least one person month on the project
during the reporting period, provide name, role in project, 41
and major activities performed.
Add clarification that that participants do not include
"Participants" tab #
those people who have participated in focus groups, trial
44
subjects, etc.
Move "Those who have worked on the project" sentence
Participants tab # 44
to the beginning of the paragraph
Remove the request for collaboration data from the
products section.
Change "non-formal collaboration" to "Collaboration".

"Participants" tab #
53
"Participants" tab #
56

Add "if appropriate" after "department" in the "Impact"
"Impact" tab # 11
section
Reorganize the text in "Impact" section to clarify the
"Impact" tab # 13
purpose of the section
Clarify the instructions to clarify the section's intended
"Changes" tab # 4
use ("prior approval" language).
"Changes" tab # 11
List human subjects before animals.
Change language to read "Approval by the applicable
"Changes" tab # 11
institutional committee"
Add "Also specify the IACUC and IRB approval dates" to "Special Reporting
Requirements" tab #
the question beginning "Signicant changes to…"
5

May 20, 2008
May 20, 2008
May 20, 2008
May 20, 2008
June 3, 2008
June 3, 2008
June 3, 2008
June 3, 2008

June 3, 2008
June 3, 2008
June 3, 2008
June 3, 2008
June 16, 2008
June 16, 2008
June 16, 2008
June 16, 2008