Table of Comments received in response to the FR notice

Number

Comment Source

Topic

PAPPG Reference PAPPG Page Numbers

Comment

The current requirement to have IRB Approval in place before a proposal can be recommended for funding is creating
administrative burden for investigators and IRB Offices. In many cases, all human subject research components have
not been created at the time of award consideration. By requiring investigators to have an IRB approved human
subject research project in place before all components have been prepared, the policy throws a wrench in the
established policies and procedures that many institutions have developed and follow when reviewing and processing
approval for human subject research projects.

1

University of
Maryland

Human Subjects Research

Chapter II.D.5

II-30-31

Pennsylvania State
University

Typographical Error

Introduction B.
Forward

x

Pennsylvania State
University

Formatting

Introduction C.
Acronym List

xi

Categories of Funding
Opportunities

Chapter I.C.4

I-2

Types of Submissions

Chapter I.D.1

I-3

Division of Research

2

3
4
5

6

Pennsylvania State
University
Pennsylvania State
University

Pennsylvania State
University

Format of the Proposal

Chapter II.B.1

NSF Response/Resolution

In consideration of this comment, NSF in the last revision of the PAPPG (NSF 17-1), included new guidance regarding
Section 45 CFR 690.118. In this context, “Incomplete” IRB submissions would seem to indicate “indefinite plans for the
involvement of human subjects.” If the plans were definite, the PI should be able to submit a protocol for review.
When 45 CFR 690.118 is invoked, that is exactly the process used by NSF, adding a statement in the award letter that IRB
Approval must be in place before any human subject research activities may take place would be less burdensome for
investigators and research support offices.

In order to meet this policy, investigators must generate an incomplete IRB Application to submit to the IRB Office and
submit Amendments later once the project is ready for implementation. This creates two review instances for the IRB NSF does recognize however, that it can be challenging to address just in time issues at the end of the fiscal year. That said,
Office, where one would be sufficient.
NSF does not have the regulatory charge to monitor researchers to see if they have obtained the appropriate approvals.
When other Federal agencies make awards to institutions, there is much more post-award monitoring of those institutions
The rationale for this requirement is unclear. (My apologies if I have missed it when reviewing the NSF Policy website.) (not just in the realm of human subjects, but in many other areas). Since our charge as a Foundation is to make awards and
It seems that adding a statement in the award letter that IRB Approval must be in place before any human subject
not regulate research, we do not have the resources and FTEs devoted to monitoring human subjects research. Also, in
research activities may take place would be less burdensome for investigators and research support offices. In our
practical terms, NSF makes awards not just to research intensive institutions, but to smaller institutions as well, that may
case, UMCP has checks in place through our Office of Research Administration to ensure that no award money is
not have as much staff in place to ensure proper monitoring of an individual award. However, we will continue to explore
granted until all requisite approvals are in place.
ways in which we can address this issue in future issuances of the PAPPG.

The word, "referenced" in the below should be "reference":
Comment incorporated.
The PAPPG, in conjunction with the applicable standard award conditions incorporated by referenced in the award...

II-2

The Acronyms for Co-Project Director and Co-Principal Investigator are listed as Co-PD and Co-PI in Section C.
Throughout the PAPPG, the acronyms are listed as co-PD and co-PI. For consistency, we request that the lower case
“co-PD” and “co-PI” references match the acronym list and be capitalized.
Since the DCLs do not typically generate full proposals or funding opportunities, we would recommend moving them to
Section B – NSF Programs and Funding Opportunities.
We propose an overall change to the LOI process (for the purpose/sake of consistency), to make all LOI submissions
mandatory from an AOR (not the PI).
Proposal Pagination Instructions. Proposers are advised that FastLane does not automatically paginate a proposal.
Each section of the proposal that is uploaded as a file should be individually paginated prior to being uploaded to the
electronic system.
We request the highlighted word “should” be updated to “must”. This correction will align the PAPPG and the
FastLane system and send a consistent requirement to the community and remove the ambiguous nature of the
paragraph.

Comment incorporated.
This is not accurate in that DCLs may be used for RAPIDs, EAGERs and other types of proposals included in the PAPPG.
Thank you for your comment, however, NSF believes this approach is appropriate. We also believe this would add
unnecessary burden to sponsored project offices.

Comment incorporated.

NOTE: When you print out an application from FastLane, there is a statement at the bottom of the Table of Contents
that says: “Proposers may select any numbering mechanism for the proposal. The entire proposal however, must be
paginated.”

7

Pennsylvania State
University

Collaborators and Other
Affiliations

Chapter II.C.1e

II-6

8

Pennsylvania State
University

Collaborators and Other
Affiliations

Chapter II.C.1e

II-7

9

Pennsylvania State
University

Title of Proposed Project

Chapter
II.C.2a(4)(a)

II-9

Our recommendation would be to update the PAPPG so it agrees with the FastLane statement.
We appreciate and support the COA template pilot that provides a consistent excel sheet template to list the
information and remains sortable for NSF. However, we believe the five separate Tables are too burdensome to the
The separate tables are easier for users to complete and the information is easier to use when separated by tables.
senior project personnel and research administrative support offices. It would streamline the process to have one
Table in which to provide all the names, with selection options (a drop down list) to delineate each potential conflict
and/or relationship.
Under COA template Table 5: List editorial board, editor-in chief and co-editors with whom the individual interacts. An
editor-in-chief must list the entire editorial board.
• Editorial Board: List name(s) of editor-in-chief and journal in the past 24 months; and
• Other co-Editors of journal or collections with whom the individual has directly interacted with in the last 24
months.
We believe the highlighted “with” can be removed from the sentence.
Title of the proposed project: Please add clarification that the title is limited to 180 characters, per the FastLane
system.

Comment incorporated.

NSF has opted to retain this instruction in NSF's electronic systems.

A small business must be organized for profit, independently owned and operated (not a subsidiary of or controlled by
another firm), have no more than 500 employees, and not be dominant in its field.
10

Pennsylvania State
University

Awardee Organization
Information

Chapter
II.C.2a(4)(g)

II-10

We believe the sentence is missing some punctuation and should read: A small business must be organized for profit,
independently owned and operated (not a subsidiary of, or controlled by, another firm), have no more than 500
employees, and not be dominant in its field.
Each proposal must contain a summary of the proposed project not more than one page in length. The Project
Summary consists of an overview, a statement on the intellectual merit of the proposed activity, and a statement on
the broader impacts of the proposed activity.

Comment incorporated.

This requirement is not just one page in length, but appears to have a character limit. We request that the current
character limit be added to the text.
11

12

13

14

Pennsylvania State
University

Pennsylvania State
University

Pennsylvania State
University

Pennsylvania State
University

Project Summary

Project Summary

References Cited

Chapter II.C.2b

Chapter II.C.2b

Chapter
II.C.2d(vi)(e)

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

II-11

II-11

II-13

II-16

The 4600 character limit has been removed in FastLane. The current standard is now 1 page.
When the proposal team prepares draft text, they often perform this editing phase outside of the FastLane system
with a word processor such as MS Word. Once the project summary has been finalized and pasted into the text boxes,
faculty are often surprised that their “1 page” Word summary doesn’t fit into the defined space within FastLane. This
results in many iterations as the faculty work to reduce the amount of text to fit the FastLane allotted space. Listing
the characters limit would eliminate this confusion.
Another alternative would be to eliminate the requirement to past into text boxes entirely and allow a 1-page
uploaded document for all project summaries.
The Project Summary should be written in the third person, informative to other persons working in the same or
related fields, and, insofar as possible, understandable to a broad audience. It should not be an abstract of the
proposal.

Noted.

We request the highlighted word “should” be updated to “must” to eliminate confusion.
Reference information is required. Each reference must include the names of all authors (in the same sequence in
which they appear in the publication), the article and journal title, book title, volume number, page numbers, and year
of publication. (See also Chapter II.C.2.d.(iii)(d)) If the proposer has a website address readily available, that
information should be included in the citation. It is not NSF's intent, however, to place an undue burden on proposers
to search for the URL of every referenced publication. Therefore, inclusion of a website address is optional. A proposal
For these types of large collaborations, the solicitation dictates the specific requirements.
that includes reference citation(s) that do not specify a URL is not considered to be in violation of NSF proposal
preparation guidelines and the proposal will still be reviewed.
We request clarification be added for references of large collaborative groups, ie. CREAM and ICE CUBE. There are
hundreds of authors and collaborators to list. Should these be listed in their entirety or are et. al’s acceptable? Should
a full list be loaded into supplemental documents or single documents?
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. It is the organization’s responsibility to define and
consistently apply the term “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, including 2 CFR § 200.430(i). 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.19 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
NSF has determined that the existing policy is appropriate.
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 our
rebudgeting authority can allow for internal approvals of increased or decreased effort/person months, we do not
understand why this requirement is still part of the NSF PAPPG.

15

Pennsylvania State
University

Senior Personnel Salaries &
Chapter II.C.2g(i)(c)
Wages

II-16

The names of the PI(s), faculty, and other senior personnel and the estimated number of full-time-equivalent personmonths for which NSF funding is requested, and the total amount of salaries requested per year, must be listed. For
consistency with the NSF cost sharing policy, if person months will be requested for senior personnel, a corresponding
salary amount must be entered on the budget. If no person months and no salary are being requested for senior
personnel, they should be removed from Section A of the budget. Their name(s) will remain on the Cover Sheet and
the individual(s) role on the project should be described in the Facilities, Equipment and Other Resources section of the Noted.
proposal.
We request a revision to how the FastLane Budget Page collects and sorts the names listed under Section A. Senior
Personnel. It would be preferred to always have the PI show as the first person in Section A, with the remaining Senior
Personnel falling into alphabetical order.

16

Pennsylvania State
University

Cost Sharing

Chapter II.C.2g(xii)

II-22

In order for NSF, and its reviewers, to assess the scope of a proposed project, all organizational resources necessary
for, and available to, a project must be described in the Facilities, Equipment and Other Resources section of the
proposal (see Chapter II.C.2.i for further information). While not required by NSF, awardee organizations may, at their
own discretion, continue to contribute voluntary uncommitted cost sharing to NSF-sponsored projects. As noted above,
however, these resources are not auditable by NSF and should not be included in the proposal budget or budget justification .

The Facilities, Equipment and Other Resources section is a vital part of the proposal that must be reviewed. Reviewers will
not be able to assess the full scope of the project without this section of the proposal.

While voluntary uncommitted cost share is not auditable by NSF, if included in the Facilities and Other Resources
section of a proposal, will it be REVIEWABLE by NSF and external reviewers? Our concern is that this sort of
institutional contribution will still impact reviewers and applications that are selected.

17

Pennsylvania State
University

Data Management Plan

Chapter II.C.2(j)

II-25

18

Pennsylvania State
University

Vertebrate Animals
Research

Chapter II.D.4

II-29

19

Pennsylvania State
University

Human Subjects Research

Chapter II.D.5

II-30

20

Pennsylvania State
University

Proposal Checklist

Exhibit II-1

II-46

21

Pennsylvania State
University

Proposal Checklist

Exhibit II-1

II-46

22

NSF Office of the
Inspector General

Typographical Error

Introduction B.
Forward

x

Simultaneously submitted collaborative proposals and proposals that include subawards are a single unified project
and should include only one supplemental combined Data Management Plan, regardless of the number of non-lead
collaborative proposals or subawards included. In such collaborative proposals, the data management plan should
discuss the relevant data issues in the context of the collaboration.

NSF has opted to retain the language proposed for inclusion in the management plan for collaborative proposals.

We would propose to further clarify this sentence such as, “In such collaborative proposals, the data management plan
should discuss the relevant data issues in the context of the collaboration and include a separate section that specifies
how data will be shared, managed, and stored at the various sites.”
We appreciate the resource links and clarifications provided in the new PAPPG. Our comment is not meant to request
a rewrite of this section; rather our goal is to advocate for a separate proposal section to be created within the
FastLane structure which will allow adequate space to document protocols and compliance practices. Removing “the
Noted.
sufficient information” out of the 15-page Project Description and permitting proposal teams a “page limitless” section
to document this important components is critical. Such a change would align with current proposal practices at the
National Institutes of Health.
Our comment is not meant to request a rewrite of this section; rather our goal is to advocate for a separate proposal
section to be created within the FastLane structure which will allow adequate space to document protocols and
Noted.
compliance practices. Removing “sufficient information” out of the 15-page Project Description and permitting
proposal teams a “page limitless” section to document this important components is critical. Such a change would
align with current proposal practices at the National Institutes of Health.
The Project Summary should be written in the third person
Noted.
IF the highlighted word “should” is updated to “must” on page II-11, Section b. Project Summary; please update the
text in the checklist.
Request that an additional check section be added, “Project Description contains, as a separate section within the
narrative, a section labeled “Intellectual Merit”. This would be consistent with having a check section for the “Broader Comment incorporated.
Impacts”.
We suggest removing “d” from referenced so this phrase says, “The PAPPG, in conjunction with the applicable
Comment incorporated.
standard award conditions incorporated by reference in the award…”
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.

23

NSF Office of the
Inspector General

General Edits

Introduction B.
Forward

x

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
This sentence is consistent with the overall intent of NSF. NSF distinguishes between policies and procedures and terms
cooperative agreements. Coverage includes the NSF award process, from issuance and administration of an NSF award
and conditions of the award.
through closeout. Guidance is provided regarding other grant requirements or considerations that either are not
universally applicable or do not follow the award cycle.” 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.

The PAPPG does not apply to NSF contracts.
24

NSF Office of the
Inspector General

General Edits

Introduction B.
Forward

x

25

NSF Office of the
Inspector General

General Edits

Introdcution E. NSF
Organizations

xvii

26

NSF Office of the
Inspector General

Deadline Date

Chapter I.F.2

I-7

27

NSF Office of the
Inspector General

Collaborators and Other
Affiliations

Chapter II.C.1e

II-6-7

28

NSF Office of the
Inspector General

Budget

Chapter II.C.2g

II-15

We suggest expanding this to include language that appeared in prior versions of the AAG: “The PAPPG is applicable to We believe that this concept is adequately covered in the first sentence of the second bullet.
NSF grants and cooperative agreements, unless noted otherwise in the award instrument. This Guide does not apply to
NSF contracts.”
Anyone, including grant recipients, administrators, and NSF personnel, should contact the OIG (1-800-428- 2189 or
[email protected]) to report instances of possible misconduct, fraud, waste, or abuse.
We believe this is appropriately addressed in Article 43 of the NSF Grant General Conditions.
We suggest that a note be added referencing the Whistleblower Protection Act and that a brief description be added
outlining protections for reporting instances of misconduct, fraud, waste, or abuse.
We suggest that approval for exceptions to the deadline date policy only be provided in writing rather than also
NSF believes it is appropriate to provide flexibility in cases of natural or anthropogenic events.
allowing for the option of verbal approval.
Regarding collaborators and other affiliations (COA), a footnote states that the new COA template does not include
disclosure of graduate advisors.“ 13 Note that graduate advisors are no longer required to be reported.”
Some information requested in prior versions of the PAPPG is no longer required. This is purposeful and we no longer
require the individual to report this information.
We suggest keeping the requirement to disclose graduate advisors. Like PhD advisors, such individuals are likely to
have a close personal relationship with the individual filling out the COA template and it would be useful to know who
these individuals are, just as NSF requests disclosure of PhD advisors.
Each proposal must contain a budget for each year of support requested. The budget justification must be no more
than three pages per proposal.
Comment incorporated.
We suggest increasing the page limit for the budget justification to five pages. This will allow for a more thorough
review and understanding of the nuances of each award’s budget.
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.
The purpose of this “general policy” appears to be to implement the preceding paragraph: “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.”

29

NSF Office of the
Inspector General

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

II-16

1. Noted. This would seem to suggest that no salary compensation would be possible for researchers working on NSFfunded projects. 2. As previously determined by the NSF Audit Follow-up Official in memoranda dated April 16, 2015,
(Virginia Tech) and September 2, 2015, (Michigan State University and University of Florida) “NSF and its awardees are
partners in the research enterprise as acknowledged via the assistance award funding mechanism. By the nature of
1. We suggest strengthening the last sentence quoted above by adding, “NSF funds are not intended to subsidize
assistance awards, awardees have the responsibility to determine how best to achieve stated goals within project objective
normal functions already required of faculty members and included in faculty salaries.”
or scope. Given this need for flexibility, proposed project budgets with personnel compensation in excess of two months
must be approved by NSF and included in the award notice. However, research often requires adjustments, and NSF
2. Although NSF states its “general policy” for senior personnel compensation as a limit, awardees are allowed to
permits post award re-budgeting of faculty compensation. NSF is aligned with federal guidelines and regulations in
exceed this limit “(u)nder normal rebudgeting authority.” We suggest that NSF should either (a) move away from the 2- allowing re-budgeting of such compensation without prior Agency approval, unless it results in changes to objectives or
month salary limit and develop a new means to implement its position that faculty members’ institutional salaries
scope.” 3a. Comment regarding senior personnel incorporated. 3b. As determined during resolution of several OIG audit
include compensation for research, or (b) enforce the limit by requiring specific NSF approval for senior personnel
reports, all classifications for employees eligible to serve as senior personnel on NSF projects do not include research as a
salaries in excess of two months per year.
normal function for which they are compensated. As a result, it is possible that individuals listed as senior personnel may be
eligible to have more than two months of salary reimbursed by NSF. Therefore, NSF has determined that it is not feasible to
3. We suggest editing this section to refer to the definition of senior personnel contained in Exhibit II-7. In addition, we affirm that the applicability of the senior salary policy to all employees , regardless of their job classification”. In addition,
suggest that NSF should affirmatively state that the senior personnel salary policy applies to all employees included in NSF’s faculty compensation policy already permits requesting more than two months on the budget where appropriate for
the senior personnel section of the proposal budget, regardless of their job classification within the institution. This
the research to be conducted. 4. What constituites a change in objective or scope is dependant upon the research being
unwritten definition was stated by several NSF officials at the Spring Grants Conference (June 2017).
conducted, and is best determined by the researcher and the organization.
4.The policy states that “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 NSF provide guidance to assist awardees in determining whether a
proposed change would result in a change of project scope or objectives.
It is the organization’s responsibility to define and consistently apply the term “year”.

30

NSF Office of the
Inspector General

31

NSF Office of the
Inspector General

Senior Personnel Salaries &
Wages

Chapter II.C.2g(i)

Other Direct Costs

Chapter
II.C.2g(vi)(f)

II-16

We suggest inserting some parameters here, such as upper or lower limits (i.e., “Organizations can define a year as any
12 month period,”) so it is clear the definition must be reasonable and consistent year-to-year.

Noted.

Any other direct costs not specified in Lines G1 through G5 must be identified on Line G6. Such costs must be itemized
and detailed in the budget justification
II-20

This change would be inappropriate for the PAPPG. This is already appropriately addressed in the Large Facilities Manual.
We suggest adding a reference that any contingency funds relating to large facility projects should be included in this
category, and that more information can be found on page 4.2.2-9 of the Large Facility Manual.

32

NSF Office of the
Inspector General

Indirect Costs

Chapter II.C.2g(viii)

II-21

We suggest that the budget justification include a description of how the base for the indirect costs was calculated in
the proposed budget, especially for organizations with multiple indirect cost rates. This requirement would help
reviewers ensure that the proposed indirect costs were calculated correctly using the correct rates and bases.

Comment incorporated.

Proposers should include an aggregated description of the internal and external resources (both physical and
personnel) that the organization and its collaborators will provide to the project, should it be funded.
33

NSF Office of the
Inspector General

Facilities Equipment & Other
Resources

Chapter II.C.2i

II-23

34

NSF Office of the
Inspector General

Dual Use Research of
Concern

Chapter II.D.6

II-32-33

35

NSF Office of the
Inspector General

General Edits

Chapter VI.C

VI-2

36

NSF Office of the
Inspector General

Fixed Amount Awards

Chapter VI.D.2a

VI-2

37

NSF Office of the
Inspector General

Grant Periods

Chapter IV.D.3c(i)

VI-2

We suggest instructing applicants to distinguish which facilities, equipment, and resources are coming from which
Facilities, Equipment and Other Resources is directed at the project, not the organization.
project participants so it is clear what is coming from the grantee versus subawardees versus collaborators. Facilities,
and which facilities are the grantee’s versus collaborator’s, have been at issue in a number of OIG cases and requiring
this information to be disclosed up front would increase transparency, decrease the likelihood for misrepresentations,
and increase OIG’s ability to pursue these cases.
For increased readability, and to be consistent with how the policy is referred to in the last sentence of this section, we
suggest changing “hereafter referred to as the ‘Policy’” to state “hereafter referred to as the ‘US Government Policy on Noted.
DURC.’”
When these conditions reference a particular PAPPG section, that section becomes part of the award requirements
through incorporation by reference.
This sentence is consistent with the overall intent of NSF. NSF distinguishes between policies and procedures and terms
and conditions of the award.
Please see our suggestions outlined in comment number 23.
Except in fixed amount awards, an NSF grant gives authority to the grantee to commit and expend funds for allowable
costs (see Chapter X) in support of the project up to the grant amount specified in the award notice at any time during
the grant period.
NSF's language is consistent with the definition of fixed amount award in 2 CFR 200.45.
We suggest removing “Except in fixed amount awards” from this sentence. As written, this sentence removes fixed
amount awards from the requirement of spending funds during the grant period when this requirement should apply
to all NSF grants (subject to exceptions for certain pre-award expenses).
Grantees are not authorized to extend an award that contains a zero balance.
1.We suggest that “zero balance” be clearly defined. It is unclear if a zero balance refers to all funds being disbursed
through ACM$ or when costs incurred meet or exceed the approved funding amount.

1. An automatic check is performed by the NSF system to determine if there is a zero balance. 2. This is already addressed
in the existing language.

2.We suggest that NSF affirmatively state it will reject grantee requests for no-cost extensions that appear “merely for
the purpose of using the unliquidated balances.”
Special NSF programs such as Research Experiences for Undergraduates may provide their funding through
supplements to other NSF grants. In such instances, the guidance in this section may not be applicable.
38

NSF Office of the
Inspector General

Supplemental Support

Chapter VI.E4.e

VI-5

For greater clarity, we suggest adding a sentence to the end of this subsection to the effect of: “For such programs,
please refer to the requirements in the applicable Dear Colleague letter.” Without such language, this section says
what rules may not apply, but does not provide guidance as to what rules do apply in such circumstances.

Comment incorporated.

Guidance regarding prior approval requirements is covered in Chapter X.A.3.

39

NSF Office of the
Inspector General

We suggest replacing this text with the following: “Certain actions require prior approval from NSF. Guidance regarding
prior approval requirements is covered in Chapter X.A.3 and the NSF column of the Research Terms and Conditions,
Appendix A.”
Prior Approval

Chapter VII.A.2

VII-1

Comment incorporated.
In addition to adding an explicit statement that clarifies there are some actions that require prior NSF approval, we
suggest linking directly to the RTC, Appendix A matrix here, in addition to Chapter X.A.3., since Chapter X.A.3 does not
include much detail and primarily just refers the reader to RTC Appendix A. This is more efficient for the reader as it
cuts out one additional mouse click between them and the relevant information. It also helps to provide experienced
grantees with this information where it used to be conveyed in Chapter VII and the related exhibit.

1.“The objectives or scope of the project may not be changed without prior NSF approval.”
2.“Prior written NSF approval also is required for changes to the Facilities, Equipment and Other Resources section of
the approved proposal that would constitute changes in objectives or scope.”
40

NSF Office of the
Inspector General

Changes in Objective or
Scope

Chapter VII.B.1a

VII-2

41

NSF Office of the
Inspector General

Changes in Objective or
Scope

Chapter VII.B.1b

VII-2

We suggest adopting similar guidance to the National Institutes of Health that defines change of scope and provides
See response to comment 30.4.
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.
We suggest that NSF provide guidance to awardees to determine whether a proposed action is “significant” enough to
warrant NSF notification. For instance, does an alteration to the number of students funded by the award constitute a
See response to comment 30.4.
significant change? Do equipment expenditures on a project that had no budgeted equipment because the awardee’s
existing facilities and equipment were sufficient indicate a “significant change in methods or procedures?”
In cases where a former employee or IPA is being reappointed as PI or co-PI to an award they were previously involved
with, the grantee must submit a "Change of PI" request using the FastLane Notifications and Requests module.…

42

43
44

NSF Office of the
Inspector General

NSF Office of the
Inspector General
NSF Office of the
Inspector General

Substitute (Change) PI or coPI

Chapter VII.B.23

VII-3

Special Payment Grantees

Chapter VIII.C.4

VIII-4

Erroneous Payments

Chapter VIII.D.2

VIII-4

We suggest inserting “NSF,” as follows, for clarity: “In cases where a former NSF employee or IPA is being reappointed
as PI or co-PI to an award they were previously involved with, the grantee must submit a ‘Change of PI’ request using
the FastLane Notifications and Requests module”
We suggest updating this address to reflect NSF’s relocation (consistent with updated address for NSF Cost Analysis
and Pre-Award Review Branch on page X-6 (PDF pg. 136)).
We suggest updating this address to reflect NSF’s relocation (consistent with updated address for NSF Cost Analysis
and Pre-Award Review Branch on page X-6 (PDF pg. 136)).

Comment incorporated.

Comment incorporated.
Comment incorporated.

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.
45

NSF Office of the
Inspector General

Award Financial Reporting
Requirements and Final
Disbursements

Chapter VIII.E.6

VIII-8

46

NSF Office of the
Inspector General

Accountability and
Recordkeeping

Chapter IX.D.5i(ii)

IX-9

We suggest updating this address to reflect NSF’s relocation (consistent with updated address for NSF Cost Analysis
and Pre-Award Review Branch on page X-6 (PDF pg. 136)).

47

NSF Office of the
Inspector General

Pre-Award (Pre-Start Date)
Costs

X-9

We suggest language reinforcing the policy in Chapter VI, Sec. 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
NSF treats renewal proposals as "new", therefore 90-day preaward costs are allowable.
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.

Chapter X.A.2b

We suggest highlighting the word “properly” in bold and/or italics. We also suggest adding language to the effect:
“Grantees should not interpret NSF’s notification of canceling appropriations as direction to draw down NSF funds for
which there is no associated expenditure need. The timing and amount of advance payments must be as close as is
administratively practicable to the actual disbursements by the grantee for direct program or project costs and the
proportionate share of any allowable indirect costs (F&A). (See Chapter VIII.C.2.a.)”

Language has been added to address this issue.

Comment incorporated.

Coverage on Administrative and Clerical Costs has been deleted as it is redundant to coverage articulated in the
Uniform Guidance.”
48

NSF Office of the
Inspector General

Other Direct Costs

Chapter X.B

X-3

We suggest keeping in previous language on “Administrative and Clerical Salaries and Wages,” to parallel the section This is clearly articulated in the Uniform Guidance without any added NSF verbiage, therefore we do not believe this
redundancy is helpful.
that was kept about this topic in Chapter 2. There are a number of items in the PAPPG that set forth the same rules
articulated in the Uniform Guidance. This seems like an important rule that is worth emphasizing here, even if it is also
included in the Uniform Guidance. At a minimum, we suggest keeping a reference to the applicable Uniform Guidance
provision here on this topic.
Comment box: Guidance regarding inclusion in the proposal budget has been deleted as it is redundant to coverage in
the PAPPG Part I, Chapter II.

49

NSF Office of the
Inspector General

Other Direct Costs

Chapter X.B

X-3

This is clearly articulated in the Uniform Guidance without any added NSF verbiage, therefore we do not believe this
We suggest keeping in previous language regarding the requirement to include this information in the proposal for
redundancy is helpful.
emphasis and to ensure that the awardees know the rules if they look up the issue and are pointed this section of the
PAPPG instead of Chapter 2. At a minimum, we suggest inserting a reference to the applicable subsection of Chapter II.

Comment boxes: (1) Coverage on Rental or Lease of Facilities or Special Purpose Equipment has been deleted as it is
redundant to coverage articulated in the Uniform Guidance.” and (2)"Coverage on Relocation Costs has been deleted
as it is redundant to coverage articulated in the Uniform Guidance.”

NSF Office of the
Inspector General

Other Direct Costs

NSF Office of the
Inspector General
NSF Office of the
Inspector General

Non-Discrimination Statutes
and Regulations
Non-Discrimination Statutes
and Regulations

53

NSF Office of the
Inspector General

54
55

50

51
52

56
57

Chapter X.C

X-4
We suggest keeping in previous language and references to applicable Uniform Guidance Provisions. There are a
number of items in the PAPPG that set forth the same rules articulated in the Uniform Guidance. At a minimum, we
suggest keeping a reference to the applicable Uniform Guidance provision here on this topic.
We suggest updating this address to reflect NSF’s relocation (consistent with updated address for NSF Cost Analysis
and Pre-Award Review Branch on page X-6 (PDF pg. 136)).
We suggest updating this address to reflect NSF’s relocation (consistent with updated address for NSF Cost Analysis
and Pre-Award Review Branch on page X-6 (PDF pg. 136)).
For increased readability, and consistent with comment 49 regarding Chapter II, Section D.6, above, and how the policy
is referred to in the last sentence of that section, we suggest changing “hereafter referred to as the ‘Policy’” to state
“hereafter referred to as the ‘US Government Policy on DURC.’
We suggest updating this address to reflect NSF’s relocation (consistent with updated address for NSF Cost Analysis
and Pre-Award Review Branch on page X-6 (PDF pg. 136)).

This is clearly articulated in the Uniform Guidance without any added NSF verbiage, therefore we do not believe this
redundancy is helpful.

Chapter XI.A.1b

XI-1

Comment incorporated.

Chapter XI.A.8b

XI-4

Dual Use Research of
Concern

Chapter XI.B.5

XI-7-8

NSF Office of the
Inspector General

Electronic Invention
Handling

Chapter XI.D.1d

XI-10

NSF Office of the
Inspector General

Informal Resolution of Grant
Administration Disputes

Chapter XII.B.3

XII-3

We suggest updating this address to reflect NSF’s relocation (consistent with updated address for NSF Cost Analysis
and Pre-Award Review Branch on page X-6 (PDF pg. 136)).

Comment incorporated.

NSF Office of the
Inspector General
National Radio
Astronomy
Observatory

Reporting Possible
Misconduct

Chapter XII.C.3

XII-6

We suggest updating this address to reflect NSF’s relocation (consistent with updated address for NSF Cost Analysis
and Pre-Award Review Branch on page X-6 (PDF pg. 136)).

Comment incorporated.

NSF Address Information

entire document

various

I noticed that both the future and present addresses for NSF appear in the updated policy.

Comment incorporated.

Comment incorporated.
Noted.
Comment incorporated.