|GPG, Chapter I.F.2. Inclement Weather Policy||Council on Governmental Relations||We encourage NSF to add additional clarification and modification to this section that reflect more accurately the challenges faced in natural and/or anthropogenic events. The ability of a potential applicant to request prior approval for natural or anthropogenic events can be severely affected by the very event that prevents timely submission||The section has been revised to delete “prior” from the approval requirement, given the unanticipated nature of natural or anthropogenic events.|
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|GPG, Chapter I.F.2. Inclement Weather Policy||Council on Governmental Relations||We request that NSF modify this section to include a provision for: (1) Notification by the potential applicant as soon as possible but no later than five (5) days after the event and, based on that notification; (2) a determination and authorization, as appropriate, by the program officer for a late submission. NSF could alleviate the anxiety associated with unanticipated institutional closings by providing a standard exception for situations of short duration. Campuses can be closed for a variety of reasons including natural or anthropogenic events, which can require several days to return to normal operations. The recommendation above can help address that situation. Recently, however, campuses have been closed for a day for “man-made” events including sightings of armed assailants and other health and safety issues. We ask NSF to consider a standard exception of one day (next business day) for applicants whose campus is closed for an unanticipated event. The application could be submitted with documentation from the authorized institutional official or the official's designee Similarly, we suggest that NSF consider a standard provision for late submission in those cases where NSF is unable to operate because of natural, anthropogenic, and weather related or other events. Such a provision could set a specific number of days after the event for a new submission deadline. For example, in the case of closures because of inclement weather, the deadline could be set as the day following reopening of federal offices. Any deviations from this standard could be announced on the NSF Web site||The section has been updated to specifically address the closure of NSF. Additionally, the revised language developed by NSF provides greater flexibility than the language proposed by the commenter. NSF believes that such flexibility is important given the nature of the deviation request.|
|GPG, Chapter I.F.2. Inclement Weather Policy||Cold Spring Harbor Laboratory||Recommend that this policy provide additional flexibility for “after the fact approval”, for circumstances such as unforeseen natural disasters that may not have allowed an investigator or institution to seek and obtain NSF approval prior to the deadline||Comment has been addressed by the inclusion of a new change which authorizes an after the fact approval.|
|GPG, Chapter II.C.2.d.(ii) Use of URLs outside the Project Description||Massachusetts Institute of Technology||Can the NSF policy on URLs in other documents be clarified? In the Project description, we understand that these are discouraged per GPG II.C.2.d.ii. At MIT, we have had a couple of funding divisions ask for proposal file updates to remove links from the references biographical sketches whereas other divisions do not require this. The GPG states that appropriate citations for references cited (II.C.2.e) or Biosketch “products” (II.C.2.f) may include URLs, so it's unclear how to treat this as many PDF generating programs automatically treat URLs as links||NSF believes the existing language on inclusion of URLs is clearly articulated and further action is neither necessary nor appropriate.|
|GPG, Chapter II.C.2.f.(i)(e) Biographical Sketches: Collaborators & Other Affiliations||Massachusetts Institute of Technology||Biosketch section (e) adds “the total number of collaborators and co-editors also must be identified”. Should this change versus 14-1 be highlighted?||This change will be highlighted in the Summary of Significant Changes.|
|GPG, Chapter II.C.2.f.(ii) Biographical Sketches: Other Personnel||Massachusetts Institute of Technology||This section suggests that information on the qualifications other personnel may be included, but it is unclear where this should be included. FastLane does not include a place to upload biosketches for non-senior personnel. Can the correct place to include non-senior bio information be specified?||New language has been added to the Biographical Sketch(es) instructions which states: “Such information should be clearly identified as `Other Personnel' biographical information and uploaded along with the Biosketches for Senior Personnel in the Biosketches section of the proposal.”|
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|GPG, Chapter II.C.2.g.(ii); AAG, Chapter V.B.1.b. Fringe Benefits||University of Wisconsin||Both of these sections describe the ability of the grantee to charge fringe benefits as direct costs, given that charges are made in accordance with usual accounting practices and/or with approval of the cognizant federal agency. Reference also is made to 2 CFR § 200.431, within which part (b)(3)(i) states that, “Payments for unused leave when an employee retires or terminates employment are allowable as indirect costs in the year of payment.” We want to confirm our understanding that NSF policy does not preclude costs of unused leave at retirement and termination from being directly charged to NSF awards. We recognize that NSF policy indicates that such payments may be subject to reasonableness determination. Additionally, we seek affirmation that 2 CFR § 200.431 is incorporated into NSF policy to acknowledge that such unused leave also may be allowable as indirect costs and is not a directive to institutions to charge such costs as indirect costs||This issue will be addressed in the latest version of the Frequently Asked Questions that are being developed by the Office of Management and Budget. As such, it would not be appropriate for the issue to be resolved by NSF.|
|GPG, Chapter II.C.2.g.(vi) Other Direct Costs||Trish Lowney||“Examples include . . . And construction of equipment or systems not available off-the shelf.” Confusing: Doesn't fabricated equipment (construction of equipment or systems not available off-the-shelf) that meets the institution's capitalization threshold (e.g., $5,000) ought to be included in the equipment budget line (e.g., MRI development options awards)?||Language has now been modified to help eliminate confusion regarding where equipment should be addressed in the budget.|
|GPG, Chapter II.C.2.g.(vi)(a) Materials & Supplies, including Costs of Computing Devices||University of Alabama||The University appreciates the clarification that a computing device is a supply as long as it does not meet the lesser of institution's capitalization level or $5,000. It would be helpful if the PAPPG also included in this section the following statement found at 200.453(c) in the Uniform Guidance: “In the specific case of computing devices, charging as direct costs is allowable for devices that are essential and allocable, but not solely dedicated, to the performance of a Federal Award.”||Language has been incorporated as requested.|
|GPG, Chapter II.C.2.g.(vi)(c) Consultant Services||Trish Lowney||“. . . services rendered by persons who are members of a particular profession. . . And who are not officers or employees of the proposing institution. . .” Clarify whether or not “persons” include organizations/entities that meet definition of contractor and should be managed by a contract for provision of consultant services.
Clarify whether that the contracting vehicle to be used must comply with Appendix II of the UG.||NSF has implemented consultant services consistent with 2 CFR 200.459 which states: “Costs of professional and consultant services rendered by persons who are members of a particular profession or possess a special skill, and who are not officers or employees of the non-Federal entity, are allowable, subject to paragraphs (b) and (c) when reasonable in relation to the services rendered and when not contingent upon recovery of the costs from the Federal government. In addition, legal and related services are limited under § 200.435 Defense and prosecution of criminal and civil proceedings, claims, appeals and patent infringements.” As such, it would not be appropriate to deviate from this language. Additional language has been added to the consultant services section to address compliance with Appendix II of the Uniform Guidance.|
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|GPG, Chapter II.C.2.g.(vi)(d) Computer Services||Council on Governmental Relations||We appreciate that NSF has acknowledged that computing devices below an institution's equipment threshold are allowable. However, per Chapter II.2C.g.(vi)(d), the reference to “computer equipment” may create confusion in the community by suggesting that computing devices are unallowable. Per this section: “As noted in Chapter II.C.2.g.(iii) above, general purpose (such as word processing, spreadsheets, communication) computer equipment should not be requested.” We request that you consider deleting this reference, since most such devices do not rise to the level of equipment. Or, alternatively, reinforcement that computing devices below an institution's equipment threshold are allowable would be a helpful footnote to include and would be an important reminder to auditors of the differentiation between supplies and equipment.||Additional language has been added to point users to the appropriate section of the budget preparation instructions for guidance on the acquisition of computing devices.|
|GPG, Chapter II.C.2.g.(vi)(e) Subawards, Foreign Subrecipients||Massachusetts Institute of Technology||In GPG II.C.2.g.vi.e, the old policy that foreign subawardees are not eligible for indirect costs is mentioned. However, GPG II.C.2.g.viii references 2 CFR 200.414, which indicates a 10% de minimus rate is allowable for foreign grantees. Should this also apply to foreign subawardees?||Language in both the subaward and indirect cost sections of the Grant Proposal Guide has been revised to clarify application of a de minimus rate.|
|GPG, Chapter II.C.2.g.(vi)(e) Subawards, Foreign Subrecipients||University of Minnesota||The phrase is inconsistent with the Uniform Guidance's section 200.331, which allows for a 10% MTDC de minimus rate. The ability to apply the 10% MTDC de minimus rate is correctly spelled out on the following page (II-18) in the indirect cost section. It would be helpful to have the first reference corrected to avoid confusion.||Language in both the subaward and indirect cost sections of the Grant Proposal Guide has been revised to clarify application of a de minimus rate.|
|GPG, Chapter II.C.2.g.(vi)(e) Subawards, Budgets||University of Wisconsin||NSF recently clarified that each proposal's budget justification is limited to three pages, including a collaborative proposal from a single organization that contains a subaward(s). However, if a subaward is requested post-award, a proposer may submit up to a three-page budget justification for each subaward. This creates an inconsistency regarding what is submitted to obtain a subaward approval. A subaward budget justification may contain critical information regarding proposed costs, and we recommend that all subawards be allowed to include a budget justification of up to three pages, regardless of whether they are submitted with a new proposal or as a post-award action.||This request has been incorporated and language has now been revised to read as follows: “Each proposal must contain a budget for each year of support requested, unless a particular program solicitation stipulates otherwise. The budget justification must be no more than three pages per proposal. . . For proposals that contain a subaward(s), each subaward must include a separate budget justification of no more than three pages.”|
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|GPG, Chapter II.C.2.g.(viii) Indirect Cost||Council on Governmental Relations||The first two sections referenced above state: “Foreign grantees that have never had a negotiated indirect cost rate are limited to an indirect cost rate recovery of 10% of modified total direct costs. Foreign grantees that have a negotiated rate agreement with a U.S. federal agency may recover indirect costs at the current negotiated rate.” This seems to suggest that this rule would not be applicable to domestic grantees; we request that this section be clarified to state these rules apply to all grantees. The third reference above states: “Foreign subrecipients are not eligible for indirect cost recovery unless the subrecipient has a previously negotiated rate agreement with a U.S. Federal agency that has a practice of negotiating rates with foreign entities.” This seems to be inconsistent with the previously referenced sections and the Uniform Guidance; we request that this section be updated, accordingly.||Language in both the subaward and indirect cost sections of the Grant Proposal Guide has been revised to clarify application of a de minimus rate.|
|GPG, Chapter II.C.2.g.(viii) Indirect Cost||Trish Lowney||Foreign Grantees that have never had negotiated IDC are limited to 10% MTDC. Seems to conflicts with II-17/(e) Subawards: foreign subrecipients not eligible for IDC.
Consistency needed or otherwise explain why handled differently D14.||Language in both the subaward and indirect cost sections of the Grant Proposal Guide has been revised to clarify application of a de minimus rate.|
|GPG, Chapter II.C.2.g.(viii). Indirect Cost||University of Minnesota||We would like to take this opportunity to thank NSF for its clear and unambiguous statement in its proposed implementation plan about the need for pass-through entities to honor their subrecipient's negotiated F&A rate. NSF's well-articulated position on this supports full cost recovery.||Thank-you. No NSF response required.|
|GPG, Chapter II.D.3.. Ideas Lab||Council on Governmental Relations||It is not clear what the nature and extent of support from NSF will be for participants in Stage 3 of the Ideas Lab. If a participant is expected to travel and/or contribute substantial portions of their time—substantial enough to re-allocate their institutional responsibilities—we believe the institution should be a party to any agreement to participate. If, as indicated, the Stage 2 selection process uses the preliminary proposal format in Fastlane with the required submission through the Sponsored Program Office, our concerns about notification are alleviated. If there are costs associated with participation that will be provided by NSF, we assume that participant support would be allocated as a grant through the institution with the usual budgetary considerations related to participant support. Because of the collaborative nature of the Ideas Lab, we assume any Stage 4 invited full proposals will be submitted according to the Special Guidelines described at GPG Ch. II d. 5. This approach raises some questions concerning the submission process and we encourage NSF to clarify the submission process either in the Funding Opportunity Announcement or in the PAPPG.
Will the participating institutions have the option to submit either a single proposal or simultaneous proposals from all participating organizations?
Will renewal proposals require a preliminary proposal or submission of a full proposal within a regular funding cycle?||Language has now been added to specify the anticipated length of the Ideas Lab. The funding opportunity will clearly instruct the selected teams on how the full proposal should be prepared, and will address whether it should be submitted either as a single proposal or as simultaneous proposals from all participating organizations.
Unless otherwise specified in the funding opportunity, renewal proposals will be submitted as standard research proposals following the guidance provided in the Grant Proposal Guide.|
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|GPG, Chapter II.D.6. Proposals for Equipment||Trish Lowney||Notes that equipment to be purchased, modified or constructed must be described . . . Seems to conflict with II-16 other direct costs presented above? That is, constructed equipment—equipment if > capitalization threshold and in equipment budget line (with associated alteration and modification costs) and *not* in other direct costs?||Language has been revised in the Equipment Proposal preparation instructions in GPG, Chapter II.C.2.g.(iii) to address the issue.|
|GPG, Chapter II.D.8. Dual Use Research of Concern||Council on Governmental Relations||We appreciate that the provisions for meeting the US Government Policy for Oversight of Life Sciences Dual Use Research of Concern and the proposed US Government Policy for Institutional Oversight of Life Sciences Dual Use Research of Concern have been described as contingent on the publication of the final US Government Policy for Institutional Oversight of Life Sciences Dual Use Research of Concern. However, we understand that these are two separate but linked policies and that the agencies are expected to meet the requirements of the US Government Policy for Oversight of Life Sciences Dual Use Research of Concern. We agree with the observation at AAG Ch. VI B 5 b. that it is unlikely that NSF sponsored research will fall under these policy requirements. Nonetheless, it may be helpful to offer more direction at GPG Ch. II D. 9 to the grantee concerning the implementation of the policy for agencies. An indication of how NSF will engage in the development of plans with grantee organizations to mitigate the risks associated with DURC may be helpful. Such a statement or provision could outline the path for communications with NSF as in the AAG and the process for reporting by the PI/PD described in the agency policy.||Dual Use Research of Concern will now not be implemented in this version of the PAPPG and all DURC-related language has been removed.|
|GPG, Chapter II.D.8. Dual Use Research of Concern||Massachusetts Institute of Technology||Dual Use Research of concern is at II.D.9, not II.D.8.||Dual Use Research of Concern will now not be implemented in this version of the PAPPG and all DURC-related language has been removed.|
|GPG, Chapter II.D.10. Proposals for Conferences||Boise State||Requiring an estimated total budget is inconsistent with NSF's prohibition of voluntary committed cost share. The prohibition of voluntary committed cost share is also referenced in the AAG, page II-5, NSF 15_1 draft.||Language has been revised to read as follows: “Proposal Budget: A budget for the conference that is prepared in accordance with GPG Chapter II.C.2g. The budget may include participant support for transportation (when appropriate), per diem costs, stipends, publication and other conference-related costs. Note: Participant support costs must be excluded from the indirect cost base; see GPG Chapter II.C.2g(v). For additional information on Program Income associated with conferences, see AAG Chapter III.D.4.”|
|GPG, Chapter II.D.10. Proposals for Conferences||Stanford University||Chapter II.D.10 of NSF's PAPPG be clarified to indicate that it only applies to direct costs, if indeed that is the intent. It currently says “NSF funds are not to be spent for meals and coffee breaks for intramural meetings of an organization or any of its components, but not limited to laboratories, departments and centers either as direct or indirect costs.”||Language has been revised to read: “NSF funds are not to be spent for meals and coffee breaks for intramural meetings of an organization or any of its components, including, but not limited to, laboratories, departments and centers, as a direct cost.”|
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|GPG, Chapter III.F. Use of the Term Proposer||Council on Governmental Relations||We encourage NSF to standardize the language throughout this section with the terms used throughout the PAPPG. The use of the term “proposer” has created some confusion in the community particularly at grantee institutions with multiple investigators. We request that “proposer” be replaced with “grantee” because we understand that all new grantee institutions may be evaluated under the Risk Management Framework.||NSF does not concur with this recommendation. There are significant differences in terms of process, including with respect to requirements imposed on proposers versus awardees. The terms “proposer” and “grantee” are not interchangeable.|
|GPG, Chapter III.F. NSF Risk Management Framework||Cold Spring Harbor Laboratory||It is unclear what defines “all new proposers” that will be subjected to additional pre-award financial and administrative review. Recommend that NSF provide additional clarification whether this additional scrutiny will be limited to institutions that have never received NSF funding. If this is the intent, then the text should be modified to reflect this.||The language regarding the conduct of pre-award financial and administrative review has been modified to only include: “. . . all proposers recommended for award that have not received NSF funding in the last five years, with particular focus on proposers whose cumulative NSF funding would amount to $200,000 or more.”|
|GPG, Exhibit III-1 NSF Proposal & Award Process Timeline||University of Wisconsin||The NSF Proposal and Award Process & Timeline does not capture the new process in which DGA or DACS may decide to decline an award after financial or administrative review. The graphic seems to indicate that declines occur only at the Division Director level, which is no longer accurate. Updating the graphic may prevent confusion regarding the declination process||The Proposal and Award lifecycle graphic will be modified to incorporate declinations made by DGA or DACS.|
|GPG, Chapter IV.D.1.b. Reconsideration||Trish Lowney||If a proposal has been declined by the NSB, only an explanation will be available Unclear; the Board's role or involvement in the declination process seems not well defined||NSF does not believe that further information on NSB declinations, beyond that provided, is necessary.|