Changes to NSF and NIH policies and procedures are forthcoming

A researcher holds a bird that will be banded.

Researchers working with vertebrate animals need to be aware of recently increased scrutiny by the NIH.

 

Below is a summary of changes in policy and procedure being implemented at the National Science Foundation (NSF) and the National Institutes of Health (NIH).

National Science Foundation (NSF)

The NSF Policy Office has a long history of being responsive to the grant community. In response to comments from investigators and research administrators, the NSF is making a number of changes in its policies pertaining to preparation and award administration. Full details can be found in the Proposal and Award Policies and Procedures Guide (PAPPG)but the changes that will have the most impact Miami University researchers are summarized below:

New proposal types and clarification on proposal types

  • Letters of Intent, preliminary proposals, full proposals, and invited proposals, oh my! Guidance on what to include in these different types of NSF proposals will now be outlined in the revised PAPPG. Special attention is given to what needs to be included in the new, separate section on Collaborator & Other Affiliation Information.
  • Look for two new proposal types to be implemented:
    • Research Advanced by Interdisciplinary Science (RAIS): RAIS will replace NSF INSPIRES to promote interdisciplinary science and education.
    • Grant Opportunities for Academic Liaison with Industry (GOALI): The GOALI program is expanding beyond Engineering to promote university-industry partnerships focused on solving basic research questions. Look for this cross-cutting program in many of the NSF Directorates.
  • Historically travel grants have supported international travel for students supported by NSF funds, while supplements — such as those for Research Experiences for Undergraduates (REUs) — have been used for domestic travel. Going forward, however, NSF travel grants will cover both foreign and domestic travel for students.

Defining participants

According to NSF policy, it is up to the institution, not the NSF program officer, to classify participant support. At Miami, we use the NSF definition of participant support recently adopted by the Office of Management and Budget (OMB): “Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, symposia or training projects” (PAPPG).

The revised PAPPG will aid in clarifying the difference between an undergraduate participant (such as an REU student) and an undergraduate researcher. However, if you are uncertain how to classify any student, please contact your OARS representative for assistance.

Finally, just a note on food for participants. If a participant receives funds for individual meal compensation, those funds should be budgeted under “Participant Support.” Funds for meals provided for conferences/workshops, should be budgeted under “Other.” Contact your OARS representative if you need assistance making this distinction.

Changes to NSF forms

  • The 4,600 character limit will be removed from the Project Summary. Instead, the Project Summary will be limited to one printed page using appropriate font size and type.
  • Guidance on “Collaborator & Other Affiliation information” will be updated in the revised PAPPG.

Financial considerations

  • NSF has adopted a 10% de minimis facilities and administration (F&A) rate for foreign subcontractors. Domestic subcontractors may used their Federally-negotiated F&A rate or may use the 10% de minimis rate, if they do not have a negotiated rate.
  • Use of an F&A rate less than the institution’s negotiated rate is considered by NSF to be cost share, which is unallowable for a majority of NSF programs. Using the NSF budget template provided by OARS will ensure you are using the correct F&A and fringe benefit rates.
  • NSF guidance on implementation of the Department of Labor’s Fair Labor Standards Act (FLSA) can be found in their list of frequently asked questions (FAQs).

Additional information

A final draft of the revised PAPPG will be posted to the NSF website in October 2016, with changes to be implemented January 2017.

If you’d like to learn more about NSF grant administration and programs, consider registering to attend the upcoming NSF Grants Conference being held November 14-15 in Pittsburgh, PA.

National Institutes of Health (NIH)

A number of changes have recently come out of the NIH Office of Extramural Research. Many of these changes have an impact on post-award accounting and reporting. The most helpful things for grant writers are the new NIH Guide to Grants and Contracts and the General Application Guide for NIH. These new guides offer streamlined overviews of NIH programs, open solicitations, and step-by-step instructions on preparing NIH proposals and reports.

Other changes to NIH policy and programs include:

New funding programs

The Precision Medicine Initiative (PMI) program was announced by President Obama during his 2015 State of the Union address. The focus of this initiative is to take fundamental research and apply it to a specific cohort of individuals to produce individualized care. Funding programs for PMI can be found here.

Form updates

  • The new Forms D are in effect for proposals submitted on or after May 25, 2016. The new forms include:
    • A new section on authentication of key biological and/or chemical resources in order to meet requirements for rigor and reproducibility.
    • New questions regarding enrollment of human participants (enrollment type, dataset source, participant location, etc.)
    • A PHS Assignment Request Form to help determine under which institute or center a proposal should be reviewed
  • Newly specified font types including Arial, Garamond, Georgia, Helvetica, Palatino Linotype, Times New Roman, and Verdana. All font types should be 11 points or larger.

Compliance issues

eRA Commons and technical/financial reporting

  • As of June 12, 2016, eRA Commons usernames are required for primary mentors on Mentored Career Development proposals. If you need to register a PI, co-PI, investigator, sponsor, or mentor with eRA Commons, please contact your OARS representative.
  • While registration is not required for undergraduate students, graduate students, and postdoctoral candidates at the proposal stage,  once a project is funded and work by those personnel is supported by NIH funding, they must be registered with eRA Commons so that PIs can complete technical (annual and close-out) reports. Contact your OARS representative to register individuals with eRA Commons.
  • New guidance on completing the Research Performance Program Report (RPPR) will be published this October. The new guidance will cover completing and submitting the Final Progress Report (FPR), the Final Invention Statement & Certification (FIS), and the Final Federal Financial Report (FFR). Please remember that all financial reports must be submitted by Miami’s Grants & Contracts office, and should not be submitted by the PI.

Additional information

If you’d like to learn more about NIH grant administration and programs, consider registering to attend the upcoming NIH Regional Seminar being held October 26-28 in Chicago, IL.


Written by Tricia Callahan, Director of Proposal Development, Office for the Advancement of Research & Scholarship, Miami University.

Treadmill research photo by Scott Kisssell, Miami University Photo Services. Bird photo also by Miami University Photo Services.

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