PAPPG Comment Summary

Number

1

Comment Source

Penn State University

2

Penn State University

3

Penn State University

Topic & PAPPG Section

Facilitation Awards for Scientists and Engineers with Disabilities provide funding for special assistance or equipment to
enable persons with disabilities to work on NSF-supported projects. See Chapter II.E.7 for instructions regarding Comment incorporated.
preparation of these types of proposals. We believe the above should reference Chapter II. E. 6

Introduction Section B

Part II of the NSF Proposal & Award Policies & Procedures Guide sets forth NSF policies regarding the award, and
administration, and monitoring of grants and cooperative agreements. Coverage includes the NSF award process,
from issuance and administration of an NSF award through closeout. Guidance regarding other grant
requirements or considerations that either is not universally applicable or which do not follow the award cycle also is
provided. Part II also implements other Public Laws, Executive Orders (E.O.) and other directives insofar as they apply
to grants, and is issued pursuant to the authority of Section 11(a) of the NSF Act (42 USC §1870). When NSF Grant
General Conditions or an award notice reference a particular section of the PAPPG, then that section becomes
part of the award requirements through incorporation by reference. If the intent of this edit is to incorporate NSF
FAQ’s in the award terms and conditions, we would recommend further clarification to spell this out in greater detail.

It is not NSF’s intent to incorporate NSF FAQs into
the award terms and conditions. OMB has stated
that their FAQs on 2 CFR § 200 have the full force
and effect of the Uniform Guidance, but this has
no impact on the PAPPG.

We propose an overall change to the LOI process (for the purpose/sake of consistency), to make all LOI submission’s
mandatory from an AOR (not the PI).

Given the variance in the types of proposals that
use the LOI mechanism, a change in this process
would not be appropriate.

Chapter I.D.1

Who May Submit Proposals
Penn State University
Chapter I.E.1 (Universities and Colleges)

When to Submit Proposals
5

NSF Response/Resolution

Introduction Section A

Letter of Intent

4

Comment

Penn State University
Chapter I.F (Special Exceptions)

While there is a standard definition of what
constitutes a college or university, the PAPPG is
indeed silent on how multi-campus locations
should be addressed. Various NSF program
solicitations do address this issue and vary
Recommend an inclusion statement to address Universities and Colleges with multi-campus locations and academic
according to programmatic intent regarding how
focus. ie. Main campus as PhD awarding institution, while branch campus as PUI. This clarification would be useful for such satellite campuses should be treated. As
program solicitations with submission limitations.
such, a statement in the PAPPG would not be able
to capture these variances. The PAPPG however
does address the vast majority of the programs at
NSF. For those programs that limit such eligibility,
there are definitions provided in the applicable
Program Solicitation.

Include guidance that the name of the NSF Program Officer that granted the special exception to the deadline date
policy. Either with a new fill in the blank box on the NSF Cover Sheet or as a Single Copy Documents in FastLane.

Thank you for your comment. The PAPPG states
that if written approval is available, it should be
uploaded. The email should contain the name of
the cognizant Program Officer, so an additional
space for this information on the Cover Sheet is
not necessary. Additional guidance, however,
regarding this process has been provided.

Format of the Proposal
6

Penn State University
Chapter II.B

7

Penn State University

Collaborators & Other Affiliations
Information
Chapter II.C.1.e

We believe references 6-10 need to be updated as follows: 9. Center Proposal (see Chapter II.E.10 and relevant
funding opportunity); 10. Major Research Equipment and Facility Construction Proposal (see Chapter II.E.11 and
relevant funding opportunity)

References were accurate, as stated.

Instructions to order the list alphabetically by last
Please add that this section must be alphabetical order by last name. In general, it should be clarified if this list should
name have been included. No format for the list is
be set up much like the templates provided by NSF (columns), or if a running list like the biosketch format is
specified in the PAPPG, although some programs
acceptable. Our hope is that one day the file upload can be an excel sheet template that lists this information and
may specify a specific format in the applicable
becomes sortable for NSF.
program solicitation.

Sections of the Proposal
8

Penn State University

Please add "k. Single Copy Documents - Collaborators & Other Affiliations."

Comment incorporated.

Chapter II.C.2
Cover Sheet
9

Penn State University
Chapter II.C.2.a
Project Summary

10

Penn State University
Chapter II.C.2.b
Cover Sheet

11

Penn State University
Chapter II.C.2.a (Footnotes)

References Cited
12

Penn State University
Chapter II.C.2.e

Senior Personnel Salaries and Wages
13

Penn State University
Chapter II.C.2.g.(i)(a)

Part I of the PAPPG provides policy and procedural
guidance for preparation of proposals. Issues such
Please add clarification that the title is limited to 180 characters, per the FastLane system.
as field length should be articulated in the relevant
NSF system.
This was a known defect in FastLane that has now
"Each proposal must contain a summary of the proposed project not more than one page in length." This requirement
been addressed. The Project Summary is limited to
is not just one page in length BUT 4,600 characters. Please clarify that the on-line text boxes only permit this count.
1 page as stated in the PAPPG.
If the proposal includes use of vertebrate animals, supplemental information is required. See GPG Chapter II.D.7 for
additional information. If the proposal includes use of human subjects, supplemental information is required. See
References were accurate, as stated.
GPG Chapter II.D.8 for additional information. We believe the above should reference Chapter II. D. 4 and Chapter
II.D.5
Thank you for your comment. The norms of the
We request clarification be added for references of large collaborative group, ie. CREAM and ICE CUBE. There are
discipline should be followed when preparing the
hundreds of authors and collaborators to list. Should these be listed in their entirety or are et. al’s acceptable? Should References Cited. Given that each discipline may
a full list be loaded into supplemental documents or single documents?
have different practices, it is not appropriate to
include additional instructions in this section.
As a general policy, NSF limits the salary compensation requested in the proposal budget for senior personnel to no
more than two months of their regular salary in any one year. This limit includes salary compensation received from
all NSF-funded grants. This effort must be documented in accordance with 2 CFR § 200, Subpart E. If anticipated, any
compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the
budget justification, and must be specifically approved by NSF in the award notice budget.12 Under normal
rebudgeting authority, as described in AAG CChapters VII and XV, a recipient awardee can internally approve an
increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary
support for senior personnel exceeding the two month salary policy. No prior approval from NSF is necessary as long
as that change would not cause the objectives or scope of the project to change. NSF prior approval is necessary if the
objectives or scope of the project change. We ask that the 2 month rule described above be removed from the
proposal budget requirements. Given that rebudgeting authority can allow for internal approvals of increased or
decreases, we do not understand why this requirement is still part of the NSF PAPPG.

NSF concurs with the portion of the comment
regarding the ability to rebudget. However, this
policy relates to budgeting salary for senior
personnel in both the budget preparation and
award phases of the process. NSF plans to
maintain its long-standing policy regarding senior
personnel salaries and wages in these phases of
the process, reflecting the assistance relationship
between NSF and grantee institutions.

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15

Penn State University

Penn State University

This budget category refers to direct costs for items such as stipends or subsistence allowances, travel allowances, and
registration fees paid to or on behalf of participants or trainees (but not employees) in connection with NSF-sponsored
conferences or training projects. Any additional categories of participant support costs other than those described in 2
Participant Support (Line F on the Proposal CFR § 200.75 (such as incentives, gifts, souvenirs, t-shirts and memorabilia), must be justified in the budget
Budget)
justification, and such costs will be closely scrutinized by NSF. (See also GPG Chapter II.E.10D.9) For some educational Reference should be Chapter II.E.7. Comment
projects conducted at local school districts, however, the participants being trained are employees. In such cases, the incorporated.
Chapter II.C.2.g.(v)
costs must be classified as participant support if payment is made through a stipend or training allowance method.
The school district must have an accounting mechanism in place (i.e., sub-account code) to differentiate between
regular salary and stipend payments. We believe the above should reference is pointing to the incorrect area but we’re
not sure what reference to suggest in its place.

Voluntary Committed and Uncommitted
Cost Sharing
Chapter II.C.2.g.(xii)

Collaborative Proposals
16

Penn State University
Chapter II.D.3
GOALI

17

Penn State University
Chapter II.E.4.b
Conference Proposals

18

Penn State University
Chapter II.E.7
Travel Proposals

19

Penn State University
Chapter II.E.9
Proposal Preparation Checklist

20

Penn State University
Exhibit II-1 (Project Description)

A description of the resources provided in the
Facilities, Equipment and Other Resources
document are reviewable, however, per NSF
instructions, these resources should not be
While voluntary uncommitted costs share is not auditable by NSF, if included in the Facilities and Other Resources
quantified. A reviewer needs to be able to assess
section of a proposal, will it be REVIEWABLE by NSF and external reviews? Our concern is that this sort of institutional
all resources available to the project in order to
contribution will still impact reviewers and application that are selected.
consider whether sufficient resources are available
to carry out the project as proposed. NSF's cost
sharing policy was not directed at voluntary
uncommitted cost sharing.
Table of Documents for Lead and Non-Lead Organization documents: Please add the Collaborators & Other Affiliations
Comment incorporated.
Information under each Organizations column. This will clarify where it belongs in a Collaborative proposal.
We believe the sentence should read: “Supplemental funding to add GOALI elements to a currently funded NSF
research project should be submitted by using the “Supplemental Funding Request” function in FastLane.”

Comment incorporated.

We believe the sentence should read: “A conference proposal will be supported only if equivalent results cannot be
obtained by attendance at regular meetings of professional societies. Although requests for support of a conference
Comment incorporated.
proposal ordinarily originates with educational institutions or scientific and engineering societies, they also may come
from other groups.”
We believe the sentence should read: “A proposal for travel, either domestic and/or international, support for
participation in scientific and engineering meetings are handled by the NSF organization unit with program
Comment incorporated.
responsibility for the area of interest.”
We believe the sentence should read: “Results from Prior NSF Support have been provided for PIs and co-PIs who have
received NSF support within the last five years. Results related to Intellectual Merit and Broader Impacts are described Comment incorporated.
under two separate, distinct headings and are limited to five pages of the project description.”

Senior Personnel Salaries and Wages
21

Caltech
Chapter II.C.2.g.(i)(a)

22

Caltech

Voluntary Committed and Uncommitted
Cost Sharing
Chapter II.C.2.g.(xii)
High Performance Computing

23

Caltech
Chapter II.D.7
Indirect Costs, NSF Policy

24

Caltech
Chapter X.D.1

25

University of Louisiana at
Lafayette

Definitions of Categories of Personnel
Exhibit II-7

26

University of Arkansas at
NSF-NIH/OLAW MOU
Little Rock

27

Kansas State University

Project Summary
Chapter II.C.2.b

The PAPPG states that "NSF limits the salary compensation requested in the proposal budget for senior personnel to
no more than two months of their regular salary in any one year." (emphasis added). The policy is very clear that the
focus is on compensation requested, and not on salary expenditures. We agree with and are supportive of that
distinction. Our concern here is largely a mechanical one. When we submit a proposal to NSF, how should we
determine whether the amount of salary support being requested is "more than two months of their regular salary in
any one year?" The answer is very simple if we are dealing with an investigator who has only one NSF grant. It gets
much more complicated for investigators with multiple NSF grants, with widely overlapping performance periods.
Should we be looking at currently active NSF awards and trying to determine that if the current proposal is funded, will
there be a one-year period in which the amount of salary requested will exceed two months of salary? Should we look
at currently funded NSF proposals or also take into account pending proposals, as well?
we are seeking guidance in the PAPPG that provides some concrete steps to be followed to meet the policy
requirement. In the absence of this guidance, we are never quite sure if the approach we are taking is or is not
consistent with the policy.

Much like guidance contained in the Uniform
Guidance, NSF policies are written to allow
awardees maximum flexibility in the development
of their internal controls to ensure compliance
with NSF and federal requirements. As a result the
NSF policy on senior personnel salaries and wages
requires awardees to determine for themselves
the best approach for ensuring compliance.

The discussion of voluntary committed and uncommitted cost sharing is very clear. The revisions to this section of the
Thank you for your comment.
PAPPG have definitely improved the clarity.
The information in this section is helpful for investigators who require high-performance computing resources, etc. It is
Thank you for your comment.
good that the PAPPG has identified specific facilities that can provide advanced computational and data resources.
The statement that continuing increments and supplements will be funded using the negotiated indirect cost rate in
effect at the time of the initial award is improved over the previous edition of the PAPPG. That clarity is very helpful
and should reduce any confusion or misunderstanding about the intentions of NSF in these situations.

Thank you for your comment.

Our office has reviewed the proposed changes to the PAPPG and all seem to add clarity and better organization to the
document. We do have a comment regarding:
Section II-61: Definition of senior personnel
Faculty Associate (Faculty member) (or equivalent): Defined as an individual other than the Principal Investigator
Comment incorporated.
considered by the performing institution to be a member of its Faculty (or equivalent) or who holds an appointment as
a Faculty member at another institution and who will participate in the project being supported.
We recommend adding ‘or equivalent’ to the definition (see red text above) for clarity, since certain Center staff across
our campus are not Faculty members but are eligible to submit proposals.
Relevant to the complications posed by the NSF-NIH/OLAW MOU regarding animal oversight, the latest revision of the
Guidelines of the American Society of Mammologists for the use of wild mammals in research and education has just
been published and is available at http://www.mammalsociety.org/uploads/committee_files/CurrentGuidelines.pdf.
This document does a good job of explaining the enormous gulf that exists between effective and appropriate
Updated link has been incorporated.
oversight of activities involving wild vertebrates and those using typical laboratory animals. Additionally, the ASM and
Oxford University Press have collaborated on and are advertising a collection of papers that that address these same
concerns. That collection is available at http://jmammal.oxfordjournals.org/page/Guidelines.
The GPG really needs to be updated with the same information that is contained in Fastlane on the Project Summary
instructions. Specifically, the GPG doesn’t tell the faculty the 4600 character limit.

This was a known defect in FastLane that has now
been addressed. The Project Summary is limited to
1 page as stated in the PAPPG.

Cancelling Appropriations
28

Cornell University
Chapter VIII.E.6

29

Boise State University

Collaborators & Other Affiliations
Information
Chapter II.C.1.e

Thanks for making the draft FY17 PAPPG available. I noted the additional clarity surrounding cancelled funds, and
appreciate things being made clearer. My understanding – but please correct me if I am wrong – is that the period of Your understanding is accurate. FastLane or other
performance can never go beyond the life of the underlying appropriation. The question has been raised as to how mechanisms will prevent an NCE that goes beyond
one knows what year’s funds were used for an award, and whether FASTLANE or other mechanisms will prevent a
the appropriation's life.
grantee-approved NCE that goes beyond the appropriation’s life.
NSF currently requires "Collaborators & Other Affiliations" as a single-copy document. It is not
unusual for specific RFPs to require a second collaborators document in various formats. This is a
time-consuming process for what is essentially duplicate information. My comment/request is that
NSF have a single "Collaborators & Other Affiliations" document that is in the same format for all
RFPs.

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NSF Office of Inspector
General

Introduction Section B

“When NSF Grant General Conditions or an award notice reference a particular section of the PAPPG, then that section
becomes part of the award requirements through incorporation by reference.” This sentence is confusing in light of
the preceding sentences, which state, “Part II of the NSF Proposal & Award Policies & Procedures Guide sets forth NSF
policies regarding the award, administration, and monitoring of grants and cooperative agreements. Coverage includes
the NSF award process, from issuance and administration of an NSF award through closeout. Guidance regarding other
grant requirements or considerations that either is not universally applicable or which do not follow the award cycle
also is provided.” NSF General Grant Conditions require recipients to comply with NSF policies (NSF General Grant
Conditions, Article 1.d.2), which are set forth in this document. The sentence in question could wrongly lead one to
believe that only sections of the PAPPG specifically mentioned in award terms and conditions need to be followed. We
strongly suggest that this sentence be removed.

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NSF Office of Inspector
General

Introduction Section B

“The PAPPG does not apply to NSF contracts.” We suggest expanding this to include language that appeared in prior
versions of the AAG: “The PAPPG is applicable to NSF grants and cooperative agreements, unless noted otherwise in
the award instrument. This Guide does not apply to NSF contracts.”

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NSF Office of Inspector
General

Special Exceptions to NSF's Deadline Date
Policy
Chapter I.F.2

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NSF Office of Inspector
General

NSF Office of Inspector
General

Contingency and Management Fees
Chapter II
Senior Personnel Salaries and Wages
Chapter II.C.2.g.(i)(a)

Additional scrutiny will be given in the review of
NSF Program Solicitations to ensure that: 1) any
requirements that are supplemental to the COI
requirements specified in the PAPPG receive an
additional level of review; and 2) that the COI
information is provided only once in a given
proposal.
In large part, the PAPPG provides guidance and
explanatory material to proposers and awardees.
Therefore, it would be inappropriate to impose on
NSF awardee organizations the requirement to
comply with all such guidance and explanatory
material as terms and conditions of an NSF award.
NSF strongly believes that the articles specified in
the General Conditions clearly articulate the parts
of the PAPPG that are indeed requirements
imposed on a recipient, and, for which they will be
held responsible.

Language has been revised to address issue.

The ability to receive verbal approval only is
absolutely vital in cases of natural or
anthropogenic events. We have received
“If available, written approval from the cognizant NSF Program Officer should be uploaded with the proposal as a
numerous complaints from PIs who did not even
Single Copy Document in FastLane. Proposers should then follow the written or verbal guidance provided by the
have access to a computer during the natural
cognizant NSF Program Officer.” We suggest that approval for exceptions to the deadline date policy only be provided event, but wanted NSF to be aware that their
in writing rather than also allowing for the option of verbal approval.
proposal would not be able to be submitted on
time. We believe that it is vital to retain such
flexibility in cases of natural or anthropogenic
events.
General comment: we suggest that an explicit reference be made to the appropriate NSF guides and/or manuals that
contain information related to the proper budgeting and expenditure of management fees and contingency funds.

A reference to the Large Facilities Manual has been
incorporated into the opening of the budget
section.

“This effort must be documented in accordance with 2 CFR § 200, Subpart E.” We suggest that the third sentence of
the second paragraph be modified to add references to specific sections of the Uniform Guidance, as follows (new text Section 2 CFR 200.430(i) is specifically relevant to
in red): “This effort must be documented in accordance with 2 CFR § 200, Subpart E, including §§ 200.430 and
documentation of personnel expenses. This
200.431.” Adding a reference to specific sections of the Uniform Guidance will allow users to more easily identify and reference has been incorporated.
understand the regulations that govern their awards.

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NSF Office of Inspector
General

NSF Office of Inspector
General

Senior Personnel Salaries and Wages
Chapter II.C.2.g.(i)(a)

Administrative and Clerical Salaries and
Wages Policy
Chapter II.C.2.g.(i)(b)

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NSF Office of Inspector
General

NSF Office of Inspector
General

NSF Office of Inspector
General

Equipment
Chapter II.C.2.g.(iii)(d)

Entertainment
Chapter II.C.2.g.(xiii)(a)

NSF Award Conditions
Chapter VI.C

“Under normal rebudgeting authority, as described in Chapters VII and X, a recipient can internally approve an
increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary
support for senior personnel exceeding the two month salary policy. No prior approval from NSF is necessary as long
as that change would not cause the objectives or scope of the project to change" We suggest that the indicated
sentences be removed. Allowing awardees to exceed the general two month salary limit without NSF approval
contradicts the prior paragraph in section II.C.2.g.(i)(a) that states, “NSF regards research as one of the normal
functions of faculty members at institutions of higher education. Compensation for time normally spent on research
within the term of appointment is deemed to be included within the faculty member’s regular organizational salary.”
By allowing awardees to unilaterally rebudget salary above the two-month limit, NSF runs the risk of reimbursing the
very compensation costs that it deems “to be included within the faculty member’s regular organizational salary.”

In accordance with final decisions issued by the
NSF Audit Followup Official on this audit matter,
by the nature of assistance awards, awardees have
the responsibility to determine how best to
achieve stated goals within project objective or
scope. Research often requires adjustments, and
NSF permits post-award re-budgeting of faculty
compensation. NSF is aligned with federal
guidelines and regulations in allowing re-budgeting
of such compensation without prior Agency
approval, unless it results in changes to objectives
or scope.

“Conditions (i) (ii) and (iv) above are particularly relevant for consideration at the budget preparation stage.” As
revised, the last sentence of this page highlights 3 of the 4 conditions as “particularly relevant.” The fourth condition,
which is not highlighted as “particularly relevant,” is the requirement that such costs be included in the approved
budget or have prior written approval of the cognizant NSF Grants Officer—a requirement that is explicitly stated in
Chapter X, § A.3.b.2 of the proposed PAPPG. We suggest deleting the sentence, “Conditions (i) (ii) and (iv) above are
particularly relevant for consideration at the budget preparation stage." If desired, an alternative sentence such as the
following could replace it: "These conditions are particularly relevant for consideration at the budget preparation
stage."

NSF does not find this language confusing as (i), (ii)
and (iv) are the only conditions that are relevant at
the proposal preparation stage. That is why a
similar sentence is not included in Chapter X.b.2. of
the PAPPG.

“Any request to support such items must be clearly disclosed in the proposal budget, justified in the budget
justification, and be included in the NSF award budget.” We suggest including the following sentence at the end of the
section on Equipment: “See 2 CFR §§ 200.310 and 200.313 for additional information.” Adding a reference to specific 2 CFR 200.313 will be incorporated.
sections of the Uniform Guidance will allow users to more easily identify and understand the regulations that govern
their awards.
“Costs of entertainment, amusement, diversion and social activities, and any costs directly associated with such
activities (such as tickets to shows or sporting events, meals, lodging, rentals, transportation and gratuities) are
unallowable. Travel, meal and hotel expenses of grantee employees who are not on travel status are unallowable.
Costs of employees on travel status are limited to those specifically authorized by 2 CFR § 200.474.” We suggest
keeping the two sentences that are proposed to be stricken at the end of this section (in addition to having this text
also included in Chapter II.C.2.g.(iv)), as it is useful and applicable guidance to grantees looking up the rules in both
sections. We also recommend adding an explicit reference to 2 CFR § 200.438 at the end of the Entertainment
paragraph so the last three sentences read: “Travel, meal and hotel expenses of grantee employees who are not on
travel status are unallowable. Costs of employees on travel status are limited to those specifically authorized by 2 CFR
§ 200.474. See 2 CFR § 200.438 for additional information about entertainment costs.” Adding a reference to specific
section of the Uniform Guidance will allow users to more easily identify and understand the regulations that govern
their awards.

A reference to the relevant Uniform Guidance
section will be added and the first stricken
sentence identified will be kept. However, the
second sentence will be removed to ensure clarity
on the intended topic which is "Entertainment
Costs". NSF believes that the search tools/options
available in the PAPPG are sufficient to provide
awardees quick and direct access to specific topics
on items of costs, including travel and
entertainment costs.

“When these conditions reference a particular
PAPPG section, that section becomes part of the award requirements through incorporation by reference.” Please see See NSF Response to Comment 30.
our suggestions outlined in comment number 1.

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NSF Office of Inspector
General

NSF Office of Inspector
General

NSF Office of Inspector
General

NSF-Approved Extension
Chapter VI.D.3.c(ii)(a)

Changes in Objectives or Scope
Chapter VII.B.1(a)

Award Financial Reporting Requirements
and Final Disbursements
Chapter VIII.E.6

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NSF Office of Inspector
General

Conflict of Interest Policies
Chapter IX.A

NSF believes that the revised language is
appropriate. Requests must be submitted at least
“The request should be submitted to NSF at least 45 days prior to the end date of the grant.” We believe that this
45 days prior to the end date of the grant. If
alteration fully changes the guidance rather than simply updating it for clarity. We suggest returning the sentence back submitted late, the request must include a strong
to the way it was originally written to state, “The request must be submitted to NSF at least 45 days prior to the end
justification as to why it was not submitted earlier.
date of the grant.” This will allow responsible NSF officials adequate time to fully review the request.
That provides the necessary ability for the
Foundation to appropriately respond to situations
where a compelling rationale is provided.
“The objectives or scope of the project may not be changed without prior NSF approval. Such change requests must be
signed and submitted by the AOR via use of NSF’s electronic systems.” We suggest adopting similar guidance to the
National Institutes of Health that defines change of scope and provides potential indicators. This guidance can be
found in section 8.1.2.5 of the NIH Grants Policy Statement. Alternatively, we suggest adding a list of circumstances
that could be considered a change of scope. For example, significant increase/decrease in a PI’s effort allocated to the
project, a significant decrease in research opportunities for graduate and undergraduate students, and significant (>
25%) rebudgeting of costs among budget categories, which indicates a material change in the research methodology.

Rather than develop a listing of potential
"indicators" of a change in scope, NSF prefers to
continue use of Article 2 to identify areas that
require NSF prior approval.

“NSF will notify grantees of any canceling appropriations on open awards in order for grantees to properly expend and
draw down funds before the end of the fiscal year.” We suggest adding a sentence that reminds awardees that funds
A reference to the section on grantee payments
must still be used on allowable, allocable, and reasonable costs, and that the drawdown must be related to expenses
has been incorporated into the paragraph on
that have already been incurred or will be incurred within 3 days of the drawdown, per NSF policy. In the past,
cancelling appropriations.
awardees have misconstrued NSF’s guidance and have drawn down funds for expenditures that had not been incurred
and were not anticipated to be incurred within 3 days.
“Guidance for development of such polices has been issued by university associations and scientific societies. In
addition to the stated language, we suggest that NSF also provide examples of key components of an effective policy.

NSF defers to grantee organizations regarding the
provision of examples in their policies that are
most applicable to their organization.

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NSF Office of Inspector
General

NSF Office of Inspector
General

NSF Office of Inspector
General

NSF Office of Inspector
General

Conflict of Interest Policies
Chapter IX.A

Conflict of Interest Policies
Chapter IX.A

Allowability of Costs
Chapter X
Pre-Award (Pre-Start Date) Costs
Chapter X.A.2.b

NSF believes that there is value in having a
consistent SBIR exclusion between NSF and NIH.
Excluding SBIR awards from NSF’s policy reflects
the fact that limited amounts of funding are
provided for SBIR Phase I awards and an ownership
interest in an SBIR institution at this phase is not
likely to create a bias in the outcome of the
research. This exclusion takes into consideration
the fact that potentially biasing financial interests
“significant financial interest” does not include “any ownership in the organization, if the organization is an applicant
will be assessed during submission of SBIR Phase II
under the [SBIR/STTR programs]?” What is intended regarding IX.A.2.b, that the term “significant financial interest”
proposals. Moreover, in order for an institution to
does not include “any ownership in the organization, if the organization is an applicant under the [SBIR/STTR
receive the designation as being eligible for the
programs]?” In the instance of a professor being proposed as co-PI for a university for a subcontract through an SBIR
SBIR program, this information is collected through
award, where that professor is also an owner of an SBIR applicant, this section may be interpreted to mean that
the SBIR Company Registry by the Small Business
professor does not have to disclose her ownership interest in the SBIR company. We suggest adding language to make
Administration and identified in the supplemental
this more clear and to remove any potential loop holes.
SBIR document provided by SBA. Further, we note
that the OMB Uniform Administrative
Requirements, Cost Principles, and Audit
Requirements for Federal Awards (September 10,
2015), require a Federal awarding agency to have
an awardee conflict of interest policy and require
the awardee to report conflicts of interest to the
Federal awarding agency. ( 2 CFR 200.112 ) NSF’s
policy complies with the uniform standards.

“an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children,
meets both of the following tests: (i) does not exceed $10,000 in value as determined through reference to public
prices or other reasonable measures of fair market value; and (ii) does not represent more than a 5% ownership
interest in any single entity;” How were the thresholds of $10,000 or a 5% ownership interest in IX.A.2.e determined?
How is 5% ownership interest defined and how is an individual supposed to determine if he/she has a 5% ownership
interest? It may require knowledge outside of their control, for instance, knowledge of all owners and the total assets
of the company in order to calculate their share. We suggest erring on the side of more disclosure as opposed to less,
and simply requiring individuals with ownership interests to make disclosures so that it is more clear.

NSF’s thresholds reflect language agreed upon in
1995, as a result of close coordination between
NSF and NIH. At the time, both agencies’ policies
went through extensive public comment periods.

General comment: we suggest that any references to 2 CFR § 200 include a hyperlink directly to the regulation to help A hypertext link to 2 CFR § 200 already appears in
facilitate better understanding by the user.
the html version of the PAPPG.
We suggest language reinforcing the policy in Chapter VI, § E.2. that costs incurred under an “old grant cannot be
transferred to the new grant” in the case of a renewal grant. The 90-day preaward cost allowability provision should
Comment incorporated.
not apply to renewal grants, even if the “old” award has been fully expended. This would constitute a transfer of a loss
on the “old” grant to the “new” grant, which is unallowable under 2 CFR § 200.451.

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49

NSF Office of Inspector
General

NSF Office of Inspector
General

Salaries and Wages
Chapter X.B.1.a

Administrative and Clerical Salaries and
Wages
Chapter X.B.2

50

NSF Office of Inspector
General

Intra-University (IHE) Consulting
Chapter X.B.3

“Compensation paid or accrued by the organization for employees working on the NSF-supported project during the
grant period is allowable, in accordance with 2 CFR § 200.430” We suggest including additional narrative here
summarizing the requirements that are specified in 2 CFR § 200.430 (similar to what is included at Chapter II.C.2.g.(i))
as opposed to relying solely on awardees pulling up the reference to the Uniform Guidance. This will allow users to
better understand the guidance and regulations applicable to their awards.

NSF believes that incorporation of the entire
Uniform Guidance into the PAPPG is not prudent.
The PAPPG would then become incredibly lengthy
and unhelpful to users. Rather, a hypertext link is
provided to each of the applicable references in
the Uniform Guidance.

This recommendation is inconsistent with the
approach established in 2 CFR § 200. Throughout
“Such costs are explicitly included in the approved budget or have the prior written approval of the cognizant NSF
the document, regular reference is made to "are
Grants Officer;” We suggest that for direct charging of administrative/clerical salaries and wages to be allowable, they
explicitly included in the budget." Such inclusion in
must be explicitly approved in the award notice. This is consistent with section X.A.3.b.2, which states that salaries of
the budget serves to explicitly document agency
administrative and clerical staff must receive written prior approval from the Grants and Agreements Officer.
approval of specific cost categories at the time of
the award.
“If anticipated, any compensation for such consulting services should be disclosed in the proposal budget, justified in
the budget justification, and included in the NSF award budget.” We suggest including the following sentence at the
end of this section: “See 2 CFR § 200.430(h)(3) for additional information.” Adding a reference to specific section of the Comment incorporated.
Uniform Guidance will allow users to more easily identify
and understand the regulations that govern their awards.