CLASP TOPICS OF INTEREST: Q&A DOCUMENT March 2015

Transcription

1 1 CLASP TOPICS OF INTEREST: Q&A DOCUMENT March 2015 SUBJECT: NATIONAL SCIENCE FOUNDATION POLICY & GUIDELINES NSF Cost-Sharing Policy Compensation vs. Time Commitment 1. PIs may be required to reduce or eliminate summer salary in their proposed budgets. This occurs either as a result of hearing from the PO that certain programs do not wish to fund full summer salary or in cases where a budget revision (reduction) is requested by the PO during the award negotiation process. The PI has already stated the time commitment, and will commit that amount of time regardless of compensation in order to complete the proposed project activities. This situation seems to conflict with NSF s policy prohibiting voluntary committed cost-sharing. From the NSF Grant Proposal Guide (GPG) Chapter II.C.2.g.i.(a): NSF regards research as one of the normal functions of faculty members at institutions of higher education. Compensation for time normally spent on research within the term of appointment is deemed to be included within the faculty member s regular organizational salary. 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. Principal Investigators should submit a proposal with a budget request with the appropriate amount of time requested for the work described in the proposal, keeping in mind NSF s salary policy and any specifications of Program Solicitations. If, during negotiations, a PI/institution is asked to reduce the budget by 10% or more, a corresponding reduction in scope should also be made. Since the grantee institution is responsible for complying with Federal, State and Institutional policies, they should be comfortable that the costs are appropriately budgeted. In addition to having a cognizant Program Officer, each award also has a Grants and Agreements Officer assigned to it. If there are questions during the negotiation stage, it would be possible to contact NSF s Division of Grants and Agreements to receive guidance from a cognizant Grants Officer for the Division to which the proposer is applying. If, during the negotiation process, an issue arises that has policy implications or questions, inquiring with the Policy Office also could be appropriate. Information regarding cost sharing can be found in the GPG Chapter II.C.2.g.(xi) and the NSF Award and Administration Guide (AAG) Chapter II.C. Regarding the distinction between voluntary committed cost sharing and voluntary uncommitted cost sharing, the

2 2 definition of cost sharing is found in 2 CFR One of the aspects of cost sharing is that it must be included on the approved budget from the Federal awarding agency. If a contribution is not included on the budget, it is not considered to be voluntary committed cost sharing. Voluntary committed cost sharing is any cost sharing offered by the proposer that is not mandatory and that is captured in the budget or budget justification. Current and Pending Support 2. The Current and Pending Support Form must include information about the proposed project and all other projects or activities requiring a portion of time of the PI and other senior personnel, even if they receive no salary support from the project(s). There are implied costsharing concerns with this, although an FAQ document states that information provided in this section of the proposal does not violate the no-cost-share rule (see FAQ #7: Given the form is not meant to be part of the review process, other than to flag potential effort or funding conflicts, why isn't this form a "Single Copy Document" or even requested later in the review cycle (as with NIH's "Just in Time" information)? While the Current and Pending Support Form is meant to be informational, it is used as part of the review process. It is another element that assists program officers and reviewers in determining that a PI/team has the capacity to do what they are proposing. As FAQ #7 indicates, the purpose of the current and pending support section is to assess possible PI and other senior personnel commitments and get a general sense of what other projects require a portion of their time. Thus, the current and pending support section is used for pre-award purposes, does not have to align with the budget/budget narrative, and is just used to assess possible commitments. While the form can be useful for the preaward process, after an award is made, institutions are not held to the information that is submitted in the Current and Pending Support section. The National Science Board (NSB) recently produced the report Reducing Investigators Administrative Workload for Federally Funded Research. The report does make some recommendations that include decreasing administrative workload of both proposers and reviewers through the use of preliminary proposals, broadening the use of Just in Time and the use of simplified budgets. The Task Force did not specifically recommend the use of just-in-time for current and pending support as there was quite a debate among members as to the usefulness of the document at the pre-award stage. Some members were adamant that their scientific community needed it as part of the decision-making process, while others could see the benefit of postponing it. NSF has talked informally about piloting current and pending support as just-in-time, but has not pursued it further. NSF is in the process of developing a formal response to the NSB report.

3 3 Research in Undergraduate Institutions (RUI) Proposals Cover Sheet: Program Solicitation Number and Unit of Consideration 1. The RUI guidelines state, "For a RUI proposal from a PUI, select only the number for this RUI/ROA solicitation; do not select another solicitation number." There are circumstances where this is not possible. For example, upon selecting the RUI Program Announcement (NSF ) on the FastLane Proposal Cover Sheet, the NSF program (e.g., MEP) was not listed under Unit of Consideration. We reached out to the PO who advised us to select the MEP solicitation number, not the RUI PA number, and to include "RUI:" at the beginning of the project title which would identify the proposal as a RUI. This direction conflicts with the RUI guidelines, but given the fact that all programs are not listed in the Unit of Consideration drop-down menu, there is no other choice but to go against the RUI guidelines. How can we be sure our proposal will not be returned without review or not considered as a RUI, for failure to follow the RUI guidelines? In July 2014 there was an updated program solicitation for NSF , Facilitating Research at Primarily Undergraduate Institutions: Research in Undergraduate Institutions (RUI) and Research Opportunity Awards (ROA). Hopefully this solicitation did help clarify some questions regarding the program. As NSF indicates, that is the solicitation number that should be used for RUI/ROA submissions. That said, NSF also makes it clear that Prospective PIs should contact disciplinary program officers to identify specific NSF programs and to determine the feasibility and timing of RUI/ROA requests. If a program officer or Program Solicitation instructs a proposer to use a different solicitation number then it is wholly appropriate to notate that in the proposal and use the solicitation number as instructed. If there are discrepancies with FastLane, then the FastLane Help Desk and the cognizant program officer should be contacted immediately. 2. In some solicitations there is specific language about RUI and submission with the solicitation number rather than the RUI number. Unfortunately, it is rather cryptic and might be overlooked. Given the inconsistencies between the RUI guidelines, some program solicitations, and the FastLane Cover Sheet modules options, how might we be able to better identify the appropriate choice for our RUI proposals? Program Solicitations, by their nature, in some way constitute a deviation from the normal GPG rules. Therefore, it is important to follow everything that is asked of in the solicitation. Again, the RUI solicitation is clear that RUI proposals should be submitted under NSF RUI/ROA. If an individual program solicitation states otherwise then the proposer should follow that specific solicitation. Again, NSF also makes it clear that proposers should contact their appropriate cognizant program officer prior to submission.

4 4 Certification of Eligibility 3. The Certification (signed by the institution s Authorized Organizational Representative) must be uploaded as a Supplementary Document for each RUI proposal submitted. Since this certification cannot be generated by the PI, coupled with the fact that the FastLane system does not check for this document during the submission process, a RUI proposal could be submitted without the certification, which would result in Return without Review. We wonder if there is a way the FastLane system could help with this administrative requirement. For example, could the Certification be part of the institution s permanent record or organizational profile? Or perhaps it could be a Cover Page check box, so that the AOR signature satisfies the requirement? Or in the Forms list, under Supplementary Documents (RUI, if applicable) just like the Postdoc Mentoring Plans requirement? NSF is working on upgrading its electronic submission and compliance checking systems. It is a process, however, and is very slowly moving into how to do more compliance checking with program solicitations. Because of the program-specific nature of the RUI program, all of the examples above would require significant upgrades to FastLane that are not currently on the upgrade schedule but, if the majority of the CLASP membership does see this as presenting undue burden and a priority for them, then it is something that the membership could collectively request that NSF review. Project Reports Overdue Reports and Pending Proposals 1. If the PI/co-PI has an outstanding annual report, and it's within the submission window (not overdue), does it affect the review of the pending proposal? Or should all outstanding reports be submitted by the PI/co-PI prior to submitting any pending proposal? It likely would not affect the review of the pending proposal, but it possibly could. NSF policy is that, unless otherwise specified in the award, annual reports are due and should be submitted at least 90 days prior to the end of the budget period. From the NSF Grant General Conditions (GC-1) Article 15: Unless otherwise specified in the grant, annual project reports should be submitted electronically at least 90 days prior to the end of the current budget period to allow adequate time for the cognizant NSF Program Officer to review and approve the report. 2. If the report is a final report but it's within the overdue submission window which falls after the submission of the pending proposal, will it affect the review differently from an outstanding annual report or must the PI/co-PI have all types of reports submitted prior? It should not affect review of a pending proposal if the final project report is due but not overdue. NSF policy is that, unless otherwise specified in the award, final project reports should be submitted within 90 days following expiration of the grant.

5 5 3. If Professor A has an outstanding report, does that affect the review of Professor B s proposal if they are not on the same proposal? (The professors are at the same institution.) While it is possibility down the line, at this point Professor A s overdue report should not impact the review of Professor B s proposal. In an ideal world, the institution should not have any overdue reports and then it would be a non-issue. 4. If a faculty member submits a proposal during the time period immediately after his/her current grant expired or if the new proposal has been reviewed and recommended for funding, does the faculty member still have the allocated time to submit the report for the grant that just expired? (A program officer ed one of my faculty members that, if he did not immediately submit his final report for a grant that had just ended, his new grant would not be awarded.) NSF policy is that, unless otherwise specified in the award, final project reports should be submitted within 90 days following expiration of the grant. Thus, a faculty member should have that amount of time to submit a final project report for an award that has just expired. That said, it is possible that there could be some extenuating circumstances that prompted the situation describe in the parentheses such as the new award is for a continuing grant and the program officer feels they need to see the progress of the first project prior to finalizing an award or the PO has had previous experience with a specific PI regarding reports that are submitted very late (or not at all) so they feel this is a way to ensure that a report for the previous project gets submitted in a more timely manner. Overdue Reports and Active Award Funding 5. When NSF announced that it was cracking-down on overdue reports, I saw an article that stated that NSF could/would withhold funding from the institution if it had overdue reports. I have not seen reference to that since simply that funding would not be awarded for any new grants that the faculty member was involved with. Please clarify NSF s procedures/policy on this matter. For continuing grants an annual report does need to be submitted before the next funding increment will be released. AAG Chapter II.D.1 makes clear: As reflected in the Project Report System, the report is considered due during the 90 day period. The report becomes overdue the day after the 90 day period ends. Failure to submit timely reports will delay processing of additional funding and administrative actions, including, but not limited to, no cost extensions. In the case of continuing grants, failure to submit timely reports may delay processing of funding increments. For new awards, overdue reports definitely have the ability to impact the review of proposals from the person or team submitting them. If there are proposals that have overdue reports (including any named member of a collaborative proposal) then it is not unusual for the submitting PI to receive a message from FastLane indicating that an overdue report might delay processing.

6 6 At this point, there is no policy to withhold funding from an institution that has overdue reports. However, there could be some extremely rare cases where an institution has been deemed to be seriously out of compliance with NSF project reporting rules and NSF may have to consider taking such action. Proposal Preparation and Review Project Budgets 1. A faculty member who recently returned from reviewing proposals bemoaned the gamesmanship that he felt was occurring with the budgets, especially faculty salary, and wondered if it would make sense to cap the PI/Co-PI salaries at a specific dollar amount, say, $20,000 or two months summer salary, whichever is less. For a senior faculty member $20,000 might be one month of salary; for a junior faculty member, two months of summer salary is likely to be less. Cap the amount for the faculty to end or, at least, reduce the game playing and re-direct funds to students who often cannot forego support in order to work on research projects. While we note this is more of a comment than a question, at this point, we are not aware of any plans or discussions to cap salaries at a specific dollar amount. Again, 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. Principal Investigators should submit a proposal with a budget request with the appropriate amount of time requested for the work described in the proposal, keeping in mind NSF s salary policy. 2. Would you please explain the reasoning behind not listing the names of PI/Co-PIs on the budget sheets if they are not receiving salaries? Some program officers have requested that the names be listed (which is possible if the proposals are submitted through grants.gov; in Fastlane, you plug in $1 for each person). There are instances where a person key to the research may not be requesting salary (and since NSF regards research as one of the normal functions of faculty members of higher education, this is not surprising), but it is still important to acknowledge their role in the project. They should not be listed on the budget sheet with no salary requested because that would be considered voluntary cost sharing, which would be in violation of NSF s cost share policy. See the question regarding Compensation vs. Time Commitment for more information. 3. Could you respond to the work-around of listing senior personnel on the budget with only $1 for salary? It sounds like that could be construed by NSF auditors as voluntary cost-share. What do you advise PIs and SROs to do when program officer tell us that all senior personnel should be listed on the budget? Would it be appropriate to include a list of all senior personnel at the beginning for the Narrative?

7 7 It is possible that listing senior personnel on a budget with only $1 for salary could be construed as voluntary cost-share unless institutions feel they have a way to realistically document $1 time/effort in the post award process. The NSF policy does provide a way for institutions NOT to request salary for senior personnel. If PIs or SPOs believe they are being asked by NSF to do something that conflicts with NSF policy, then they can ask for clarification from the individual who is making the request as well as from the Policy Office. Again, in the Grant Proposal Guide Chapter II.C.2.g.i.(c) it clearly states: If no person months and no salary are being requested for senior personnel, they should be removed from Section A of the budget. Their name(s) will remain on the Cover Sheet and the individual(s) role on the project should be described in the Facilities, Equipment and other Resources section of the proposal. Criteria for Reviewing and Rejecting Proposals 4. Some of us have compared notes recently with each other and/or members of our faculty who have been reviewers and there is an increasing uneasiness that proposals from schools like ours (primarily liberal arts colleges) are being held to different standards (proposals tossed without review because someone forgot to include the RUI certification; the faculty member listed ten products but did not separate them into five most closely related and five other products, etc.) or to research university standards (criticized because the PI/Co-PIs do not have a sufficient number of current/pending grants listed). I worked on a project with a major research university and only one of their eight Bio Sketches followed the NSF template. In short, my concern is that reviewers (the majority of whom are from research universities) and possibly even program officers (the majority of whom I m guessing are from research universities) are, during these difficult economic times, looking at funding for research university faculty as a necessity and funding for CLASP schools as a nicety. While I appreciate the pressure that research university faculty may feel to keep their labs running ( necessity ), it s also been documented over the years that many of the schools within CLASP educate a disproportionate number of students who earn PhDs in STEM fields in many cases, we could not do that or do it as well and/or for as many students if our faculty did not receive funding from NSF. Any thoughts or advice? NSF does strive for consistency across its review process and tries to address any seeming inconsistencies if it becomes evident. Program Officers are also expected to have a balanced portfolio from a variety of different institution types. If there is evidence of PUIs being held to different standards than other proposers then, as appropriate, that should definitely be brought to the attention of the program officers or division directors. The NSF program offices do review proposals for compliance on issues such as following the GPG when preparing products in bio sketches, including appropriate certifications, etc. We are not aware of PUIs being treated differently than

8 8 research universities by the program offices. Again, if there are concerns regarding this, they should be brought to the attention of NSF. Regarding advice, encourage your faculty to be reviewers and don t be afraid to ask questions if something seems inconsistent. 5. I had a PI s proposal get rejected because he used et al. a couple of times. Given that some papers can have dozens of authors and given NSF s strict page # limitations, it seems this is in conflict. There MUST be circumstances where et al. is acceptable. Can these be spelled out a little clearer? There are instances when NSF is asking for full citation information and, if it is not provided, it is possible a proposal will be considered non-compliant and returned without review. The Results from Prior NSF Support, Biographical Sketch(es), and References Cited sections do require full citations. We do try to be as clear as possible in the Grant Proposal Guide and also review and update language as appropriate to further clarify. From the GPG: Results from Prior NSF Support (Chapter II.C.2.d.iii(d)): a listing of the publications resulting from the NSF award (a complete bibliographic citation for each publication must be provided either in this section or in the References Cited section of the proposal). References Cited (Chapter II.C.2.e): Each reference must include the names of all authors (in the same sequence in which they appear in the publication), the article and journal title, book title, volume number, page numbers, and year of publication. If the document is available electronically, the website address also should be identified. Biographical Sketch(es) (Chapter II.C.2.f.(c)): Each product must include full citation information including (where applicable and practicable) names of all authors, date of publication or release, title, title of enclosing work such as journal or book, volume, issue, pages, website and URL or other Persistent Identifier. All sections do need to comply with the listed page limits. If all avenues to condense the information have been exhausted and the required information still exceeds page limits, a Program Officer in the area to which the PI is applying should be contacted for advice on how to address the issue. The PO may authorize the PI to include the additional information as a supplementary document. Communicating with Program Officers 6. What do you do when program officers within the same program are giving conflicting instructions?

9 9 Request clarification from the division director of the program, Policy Office (if it is a policy issue), the Division of Grants and Agreements or other appropriate office. 7. What is the correct procedure to follow when a Program Officer is non-responsive to PI and SRO s/phone calls? And if reached by phone, he/she indicates "I can't talk now but will get back to you in a couple of days" but never does. What is the correct protocol to follow, to maintain a good relationship with the PO and not jeopardize the proposal in review? Hopefully this happens rarely. See above for other offices that will always try to assist with questions and concerns. Proposal Submissions and Success Rates Reducing the Workload 1. There was an article in the Report on Research Compliance about a year ago that stated that NSF is proposing strategies for demand management (high volume submissions, low success rates) and that NSF plans a program of enhanced outreach that is tailored to individual institutions. The article indicated that this would be done to reduce the proposal pressure on faculty members and the number of proposals, which, in turn, will reduce the pressure on NSF staff and reviewers. A handful of NSF programs now require preliminary proposals, with a handful of faculty then invited to submit full proposals. Any thoughts on moving more toward required preliminary proposals as a means of reducing everyone s workload? GPG Chapter I.D.2. outlines NSF s use of preliminary proposals: Some NSF program solicitations do require or request submission of a preliminary proposal in advance of submission of a full proposal. The three predominant reasons for requiring submission of a preliminary proposal are to: reduce the proposers' unnecessary effort in proposal preparation when the chance of success is very small. This is particularly true of exploratory initiatives when the community senses that a major new direction is being identified, or competitions that will result in a small number of awards; increase the overall quality of the full submission; and. assist NSF program staff in managing the review process and in the selection of reviewers. With increasing proposal submission rates far surpassing increases in NSF s budget, NSF has been engaging in some pilot projects focused on reducing workload pressures. Two directorates (Computer & Information Science & Engineering and Mathematical and Physical Sciences) are exploring the use of the Asynchronous Panel Process, while two divisions in the Directorate for Biological Sciences (Environmental Biology and Integrative Organismal Systems) have been exploring the increased use of the preliminary proposal process. While NSF is currently not looking to move entirely to these processes, it is interested in continuing to explore ways to decrease workload

10 pressures. More information can be found in the Report to the National Science Board on the National Science Foundation s Merit Review Process as well as the previously mentioned Reducing Investigators Administrative Workload for Federally Funded Research. 10