Grant Policy Breakout Session

1. Grant Policy Breakout Session NSF Regional Grants Conference October 4 - 5, 2004 St. Louis, MO Hosted by: Washington University

2. 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 Ask Us Early, Ask Us Often!!

3. Coverage • Grant Proposal Guide: Highlights and Recent Changes • SF 424 (R&R) – What is it? • Award Monitoring

4. 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.

5. Grant Proposal Guide • Details process for submission of collaborative proposals • Provides policy requirements for specific FastLane 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

6. 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

7. GPG (04-23) Significant Changes (cont’d) • Implements enhanced capabilities in FastLane 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/pfu.jsp

8. 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 FastLane.

9. 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 FastLane constitutes certification by the PI that the contents of the report are accurate and complete

10. 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

11. 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;

12. 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 auto-populating and auto-calculating in mind; this has turned out to be a significant challenge for the Grants.gov PMO;

13. 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.

15. 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

16. 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

17. 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

18. 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

19. 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

20. Stewardship in Practice/Implementation • IG – Agency Audit Responsibility Oversight of A-133 Audits • NSF • Agency Audit Resolution • Business Assistance • Risk Based System Focus

21. 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

22. 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

23. 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

24. Collaborative proposals What Else Would You Like To Know… Grants.gov Human subjects Academic year salary Indirect costs Award Monitoring Change in objective or scope Proposal resubmission participant support costs Foreign flag air carrier No-cost extensions PI Transfers programincome Equipment Subawards withdrawals Notifications & Requests Audits Preaward Costs New grantees Return without review Allowability of Costs subawards Cost sharing Proposal File Updates reconsideration projectreports rebudgeting Budget changes travel NSF FastLane Proposal preparation

25. www.nsf.gov/bfa/dias/policy/start.htm