Grant Policy Breakout Session NSF Regional Grants Conference October 4 - 5, 2004 St. Louis, MO Hosted by: Washington University
Ask Us Early, Ask Us Often!! Jean Feldman § Head, Policy Office § Division of Institution & Award Support § jfeldman@nsf. gov § (703) 292 -8243 Karen Tiplady § Chief, Cost Analysis & Audit Resolution Branch § Division of Institution & Award Support § ktiplady@nsf. gov § (703) 292 -5016
Coverage Grant Proposal Guide: Highlights and Recent Changes SF 424 (R&R) – What is it? Award Monitoring
Grant Proposal Guide Describes content and formatting requirements for all parts of an NSF proposal Identifies overall Foundation eligibility categories and guidelines Describes types of NSF due dates: Target dates; § Deadline dates; and § Submission Windows (MPS, ENG) § Specifies process for deviations including: individual program solicitations; § by written approval of cognizant Assistant Director or designee; or § procedure to follow for those proposers unable to submit electronically. §
Grant Proposal Guide Details process for submission of collaborative proposals Provides policy requirements for specific Fast. Lane capabilities Describes process -- and criteria -- by which proposals will be reviewed Includes highlights of NSF award and administration processes Contains information on potentially disqualifying conflicts of interest for use in the proposal process
GPG (04 -23) - Significant Changes Provides a description of the various categories of funding opportunities to generate proposals, as well as the appropriate scenarios in which each are used: Program Descriptions; § Program Announcements; and § Program Solicitations. § Incorporates new descriptive information on the types of submissions that may be required under NSF program solicitations: Letters of Intent; § Preliminary Proposals; and § Full Proposals §
GPG (04 -23) Significant Changes (cont’d) Implements enhanced capabilities in Fast. Lane for submission of proposal file updates. Requests for proposal file update are automatically accepted if submitted prior to: The deadline date in a program solicitation; § Initiation of external peer review in cases when a target date is used; and § Initiation of external peer review for an unsolicited proposal. § Detailed instructions can be found at: https: //www. fastlane. nsf. gov/documents/pfu. jsp
GPG (04 -23) Significant Changes (cont’d) With declinations, once a proposal has received the concurrence of the cognizant NSF Division Director and all review information released, PIs and co-PIs may access reviews via Fast. Lane.
GPG (04 -23) Significant Changes (cont’d) “Grantee Responsibilities & Federal Requirements” § New section to remind grantees that they have full responsibility for the conduct of the project or activity supported under an NSF award § Submission of annual and final reports via Fast. Lane constitutes certification by the PI that the contents of the report are accurate and complete
GPG Implementation Effective for proposals submitted on or after September 1, 2004 GPG § http: //www. nsf. gov/pubsys/ods/getpub. cfm? gpg FAQs § http: //www. nsf. gov/pubs/gpg/faqs. pdf
R&R Application – Background Information There was early recognition that the SF 424, as a standalone package, will not work for research and related applications; The effort started with the data elements contained in the 194 TS, § Since that time just about all of the data elements have been tweaked, enhanced, etc. Combining the Cover SF 424 with research specific elements made the most sense;
R&R Application – Background Information (Cont’d) Application consists of: the data elements, § forms, and § associated instructions for completion of each data element; § Was designed with the concept of autopopulating and auto-calculating in mind; this has turned out to be a significant challenge for the Grants. gov PMO;
R&R Application – Background Information (Cont’d) Rule imposed was two or more agencies required element for inclusion in the dataset; and Issuance of the package does not negate an agency’s obligation to put out agency specific guidance to applicants. § Utilizes announcement or agency specific instructions in several areas to guide or instruct applicant.
Issues to Address Conversion of files to PDF When is a proposal really considered submitted? And, what does that mean for compliance checking? ? Data quality is of extreme importance § Want to avoid excessive numbers of return without review § Submission of collaborative proposals NSF supplementation of proposals
Issues to Address (Cont’d) Submit versus “sign on behalf of” Subaward proposals How to handle Directorate specific forms, i. e. , BIO classification form CCR – Institutions should register now, if they have not already Agency specific instructions are in progress
NSF Award Monitoring -- Our Vision Institutions Common Approach § Develop a host mentoring Program -- institution to institution § Tailor outreach to address specific concerns § NSF IBM Business Consultant Services study and recommendations § Expanded and enhanced partnership with Programs §
Award Monitoring – Background and Context Government Wide Focus on Increased Accountability Impact on Government: CFO Act, GPRA, FMFIA, IG Act, Improper Payment Act Impact on Awardees: A-133 Reviews, GPRA Reporting Requirements § Increased Organizational Scrutiny § Multi-level Government Reviews §
Recent Emphasis on Post Award Management Growth of Agency, $, and Responsibility Changing Nature of Awards Assistance to Non-traditional Awardees Changing Nature and Complexity of Core Business Processes
Stewardship in Practice/Implementation IG – Agency Audit Responsibility Oversight of A-133 Audits NSF Agency Audit Resolution § Business Assistance § ¡ Risk Based System Focus
Listing of Significant Findings Cost sharing documentation, cost accounting documentation (time and effort certification) Low dollar of questioned cost suggests appropriate systems and reviews in place in end to end award management
BFA Conclusions Based on Audit Finding Results Activities require appropriate systems in place at awardee institutions § High risk, non-traditional awardees most vulnerable Questioned and sustained costs suggest appropriate systems are in place § Clearer policies will make things better
NSF Award Monitoring – Our Vision Other Agencies § Partnering with other agencies to reduce burden on community § Research Business Models (3 working groups) § Aim to reduce burden on experienced, well managed organizations § Goal - to institute a certificate program that other agencies buy into
What Else Would You Like To Know… Collaborative proposals Grants. gov Indirect costs Human Academic year salary subjects Award Monitoring Change in objective or scope Proposal resubmission participant support costs Foreign flag air carrier PI Transfers Equipment No-cost extensions program income Subawards withdrawals Notifications Audits Preaward Costs New grantees & Requests Return without review Allowability of Costs subawards Cost sharing reconsideration project reports Budget changes Proposal preparation Proposal File Updates rebudgeting travel NSF Fast. Lane
www. nsf. gov/bfa/dias/policy/start. htm
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