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NSF Updates PAPPG to Implement Uniform Guidance

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NSF (National Science Foundation) updated the Proposal and Award Policies and Procedures Guide (PAPPG) to implement the Uniform Guidance that became effective on Friday, December 26, 2014. The Uniform Guidance is now a consolidated set of guidance in the Code of Federal Regulations (CFR). Some of the significant changes to the PAPPG include:

  • Section B, Forwardcontains NSF’s implementation statement for the Uniform Guidance. This section also has been supplemented with language to make it clear that when NSF Grant General Conditions or an award notice reference a particular Award and Administration Guide (AAG) section, that section becomes a condition of the award requirements through incorporation by reference.
  • Section D, Definitions and NSF-Grantee Relationships – has  been updated to be consistent with the terminology used in the Uniform Guidance definitions.
  • Section F, NSF Electronic Capabilities Modernization Status – is an entirely new section of the PAPPG Introduction. It was developed to assist the community as NSF transitions electronic capabilities to Research.gov.
  • Chapter II.C.2.g, Budget and Budget Justification – has been modified to reflect that the applicable cost principles can be found in 2 CFR 200, Subpart E. For-profit entities are subject to the cost principles contained in the Federal Acquisition Regulation (FAR), Part 31.
  • Chapter II.C.2.g(i)(b), Administrative and Clerical Salaries and Wages Policy – has been revised to reflect the conditions under which inclusion of administrative and clerical staff salaries may be appropriate on a proposal budget.
  • Chapter II.C.2.g(iv), Travelhas been revised to state that all travel (both domestic and foreign) must now be justified. Additionally, 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. Finally, the definition of what constitutes domestic travel has been revised.
  • Chapter II.C.2.g(v), Participant Support – 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.
  • Chapter II.C.2.g(vi)(e), Subawards – references 2 CFR 200.330 and the requirement of proposing organizations to make a case-by-case determination regarding the role of a subrecipient versus contractor for each agreement.
  • Chapter III.F, NSF’s Risk Management Framework and Decision to Award or Decline Proposals – is a completely new section which describes the framework that NSF uses to evaluate the risks posed by proposers prior to issuance of an NSF award, consistent with 2 CFR 200.205. The section also outlines the appeal process that a proposer may utilize if NSF declined their proposal for financial or administrative reasons.
  • Chapter II.C.2.d, Project Description – has been updated to reflect that the project description must now contain, as a separate section within the narrative, a section labeled “Broader Impacts of the Proposed Work”.
  • Chapter II.C.2.g, Budget and Budget Justificationhas been revised to reflect 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.
  • Chapter II.D.3, Ideas Lab – is an entirely new section which details the four-stage process used with this funding mechanism, which is designed to support the development and implementation of creative and innovative project ideas that have the potential to transform research paradigms and/or solve intractable problems. In addition to Ideas Lab, NSF has launched another new funding mechanism titled Integrated NSF Support Promoting Interdisciplinary Research and Education (INSPIRE) that is being piloted.
  • Chapter I.G.3, Requirements Relating to DUNS Numbers and Registration for SAM – informs proposers that NSF will now validate that each proposer’s DUNS number and SAM registration are active and valid prior to allowing submission of a proposal to NSF.
  • Chapter II.D.8, Proposals Involving Human Subjectshas been supplemented to clarify that the only acceptable Institutional Review Board (IRB) approval documents are those that approve a human subjects research protocol and approvals “in concept” or conditional IRB documents are not acceptable. Guidance also is provided on the procedure to follow if IRB approval cannot be obtained at the time of the award action because the development of a human subjects research protocol requires preliminary or other conceptual work to take place.
  • Chapter II.D.9, Proposals for Conferenceshas been modified to specify that NSF funds are not to be spent for meals and coffee breaks for intramural meetings of an organization or any of its components as a direct cost.
  • Chapter III.E., Funding Recommendationhas been updated to include coverage on abstracts, which serve to describe the project and justify the expenditure of NSF funds. The cognizant NSF Program Officer may contact the PI, should their proposal be recommended for award, for assistance in preparing the public award abstract and its title.
  • Chapter II.C., Cost Sharingnow requires that awards with any mandatory cost sharing must document such cost sharing (on an annual and final basis), the Authorized Organizational Representative must certify that the amount is correct, and the cost sharing must be reported to NSF via use of NSF’s electronic systems.
  • Chapter V.C., Other Direct Costscontains a new section (V.C.5) that has been added to address temporary dependent care travel costs.

NSF is hosting a webinar on the updates to the PAPPG on Thursday, January 15, 2015 at 2:00pm EST. Registration is required. For more information, click on http://www.nsf.gov/events/event_summ.jsp?cntn_id=133616&org=NSF


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