The National Science Foundation (NSF) has released version 15-1 of their Proposal & Award Policies & Procedures Guide (PAPPG). The PAPPG implements 2 CFR § 200 (Uniform Guidance). Below are some, but not all, of the clarifications that you may find helpful.
See the complete Grant Proposal Guide listing at
http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/gpg_index.jsp?org=NSF or search by subject at http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/gpg_subindex.jsp.
See the complete Award & Administrative Guide listing at http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/aag_index.jsp or search by subject at http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/aag_subindex.jsp.
Please contact me if you have any questions.
Sincerely,
Craig
Proposal Content and Related Items
Clarifies that the project description must now contain, as a separate section within the narrative, a section labeled "Broader Impacts of the Proposed Work".
Clarifies that biographical sketch(es) should not include personal information since it is not appropriate nor is it relevant to the merits of the proposal.
· New information is being requested related to Professional Preparation. A list of the individual’s undergraduate and graduate education and postdoctoral training now includes a request for the location of the individual's institution(s).
· Clarifies that the total number of collaborators and co-editors, and graduate advisors and postdoctoral sponsors, must be identified in the appropriate areas in the Collaborators & Other Affiliations section.
· Clarifies that where applicable, information on "Other Personnel" biographical information should be clearly identified and uploaded in the Biosketches section of the proposal.
Clarifies that the listing of publications resulting from an NSF award must provide a complete bibliographic citation for each publication in either the Results from Prior NSF Support section or in the References Cited section of the proposal.
Clarifies that DUNS and SAM numbers will be validate as active prior to allowing submission of a proposal to NSF. Additionally, the section clarifies that subrecipients named in the proposal are required to obtain a DUNS number and register in FastLane but do not need to be registered in SAM.
Budget Items
Clarifies that the applicable cost principles may be now found in 2 CFR § 200, Subpart E. For-profit entities are subject to the cost principles contained in the Federal Acquisition Regulation, Part 31.
Clarifies that inclusion of administrative and clerical staff salaries may be appropriate in a proposal budget.
Senior Personnel Salaries and Wages Policy has been supplemented to address the NSF senior personnel two-months guideline:
· Per the GPG: 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.
Under normal rebudgeting authority, as described in AAG Chapters II and V, an 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 objective or scope of the project to change. NSF prior approval is necessary if the objective or scope of the project changes.
Clarifies that all travel (both domestic and international) must now be justified and includes a revised definition of what constitutes domestic travel.
· Clarifies that temporary dependent care costs above and beyond regular dependent care that directly result from travel to conferences are allowable costs provided that the conditions established in 2 CFR § 200.474 are met.
Clarifies that when budgeting for conferences NSF funds are not to be spent for meals and coffee breaks for intramural meetings (e.g. within MSU’s boundaries) of an organization or any of its components as a direct cost. Budgets and budget justifications for conferences should be prepared in accordance with GPG Chapter II.C.2.g. Additionally, a reference to the appropriate AAG section has been added to address program income generated by conferences and Facilities, Equipment and Other Resources information is now required for conference proposals.
Participant Support Costs (PSC), has been clarified to reflect that any additional categories of participant support costs other than those described in 2 CFR § 200.75* (such as incentives, gifts, souvenirs, t-shirts and memorabilia), must be justified in the budget justification, and such costs will be closely scrutinized by NSF.
* Per the CFR: Participant support costs means 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 conferences, or training projects.
Computers that are considered a supply is allowable for devices that are essential and allocable even though they may or may not be solely dedicated to the performance of the NSF award.
Professional and consultant services are allowable when reasonable in relation to the services rendered (see 2 CFR § 200.459). All contracts made under an NSF award must contain the applicable provisions identified in 2 CFR § 200 Appendix II.
Clarifies that subawards are made on a case-by-case determination regarding the role of a subrecipient versus consultant/contractor for each agreement per 2 CFR § 200.330. However, inclusion of a subaward or contract in the proposal budget or submission of a request after issuance of an NSF award to add a subaward or contract will document the organizational determination required.
· The section also clarifies NSF’s expectations regarding indirect cost rate recovery under subawards per CFR § 200.414 (i.e. If no such rate exists, the NSF awardee may either negotiate a rate or use a de minimus indirect cost rate recovery of 10% of modified total direct costs.)
Updated guidance on NSF’s expectations regarding indirect cost rate recovery. For example:
· Indirect cost recovery for colleges, universities, and other organizations of higher education are additionally restricted by 2 CFR § 200, Appendix III, paragraph C.7. which specifies Federal agencies are required to use the negotiated F&A rate that is in effect at the time of the initial award throughout the life of the sponsored agreement.
· No supporting documentation is required for proposed rates of 10% or less of modified total direct costs.
· NSF does not negotiate rates for organizations that are not direct recipients of NSF funding (e.g., subrecipients). The prime recipient (e.g. MSU) is responsible for ensuring that proposed subrecipient costs, including indirect costs, are reasonable and appropriate.
· Non-U.S. organizations that do not have a current U.S. federally negotiated indirect cost rate(s) are limited to a de minimus indirect cost rate recovery of 10% of modified total direct costs. Non-U.S. grantees that have a U.S. federally negotiated indirect cost rate(s) may recover indirect costs at the current negotiated rate.
Budget Reminders
Clarifies that the budget justification for the proposing organization must be no more than three pages. For proposals that contain a subaward(s), each subaward must include a separate budget justification of no more than three pages.
Award Setup Items
Clarifies when NSF Grant General Conditions or an award notice reference a particular Award & Administration Guide (AAG) section, that section becomes a condition of the award requirements through incorporation by reference. The AAG, in conjunction with the award terms and conditions, implements 2 CFR § 200, for NSF grants and cooperative agreements. If the AAG is silent on a specific area covered by 2 CFR § 200, the requirements specified in 2 CFR § 200 must be followed.
AAG prior approvals has been updated. AAG now has three new requests that require NSF approval including salaries of administrative or clerical staff, travel costs for dependents, and additional categories of participant support costs other than those described in 2 CFR § 200.75.
· If a grantee rebudgets funds to support a postdoctoral researcher and the original proposal included a mentoring plan, no further documentation is necessary. If the original proposal did not include a mentoring plan, then the grantee should send the cognizant NSF Program Officer the requisite mentoring plan.
· In addition, the list of situations when written prior approval from the cognizant NSF Grants and Agreements Officer is required has been revised.
AAG has been revised to state that if it becomes necessary to subaward, transfer or contract out part of an NSF award after a grant has been made, the grantee shall submit the documentation outlined in the related section.
Program income language has been clarified to show that registration fees collected under NSF-supported conferences are considered program income (see applicable portions of 2 CFR § 200.307). Grantees have no obligation to NSF with respect to program income earned from license fees and royalties for copyrighted material, patents, patent applications, trademarks, and inventions produced under an award. However, Patent and Trademark Amendments (35 USC 18) shall apply to inventions made under an award.
AAG has been revised to state that payment of fees (profit) are allowable only if expressly authorized by the terms and conditions of the NSF award.
AAG has been revised to remove the requirement to notify NSF of the short-term absence of the PI/PD or co-PI/co-PD. This requirement has been eliminated as it goes beyond what is stipulated in the Uniform Guidance, which addresses PI disengagements of 90 days or longer.
AAG has been updated in relationship to Supplemental Support which now includes guidance on submission of mentoring plans at the post-award stage. If supplemental funding is requested to support a postdoctoral researcher and the original proposal did not include a mentoring plan, then the supplemental funding request must include the requisite mentoring plan.
Award Financial Reporting and Close-out Items
AAG clarifies that grants will be financially closed out on the first day of each month for all awards with expirations 90 or more days prior to the financial closeout day.
The AAG financial reporting section also has been clarified to show that grantees must liquidate all obligations incurred under their awards not later than 90 calendar days after the award end date. NSF will financially close awards 90 days after the award end date and the award will be removed from the ACM$ payment screen for active awards. The section also delineates the time limits within which NSF will make settlements for any upward or downward adjustments to the Federal share of costs after the award financial closeout.
System Items
A new section called the "NSF Electronic Capabilities Modernization Status" has been added to the PAPPG Introduction. It was developed to assist the community as NSF transitions our electronic capabilities to Research.gov. The referenced matrix will be updated as appropriate, independent of the annual release of the PAPPG revision cycle. The current version is located at:
http://www.nsf.gov/bfa/dias/policy/estatus_matrix/dec14.pdf.
