Sneak Preview: NSF Still Awaiting OMB Clearance on 2020 PAPPG

(The following was excerpted from a recent article in the Federal Grants Management Handbook.) The National Science Foundation (NSF) is still awaiting clearance from the Office of Management and Budget (OMB) on its annual revisions to its Proposal and Award Policies and Procedures Guide (PAPPG), but a key NSF official told attendees at the recent Federal Demonstration Partnership (FDP) meeting in Washington, D.C., that once it is released, the agency will still provide 90 days for stakeholders to prepare for the new policies before NSF makes the document effective. Until then, NSF grant applicants and recipients are required to continue to follow the January 2019 version of the PAPPG (NSF 19-1).

Jean Feldman, head of the policy office at NSF’s Division of Institution and Award Support, said that the agency received 105 comments in response to the draft 2020 PAPPG when it was released in spring 2019, and about one-third of the comments were related to the issue of current and pending support. The draft version as released contained new language to clarify NSF’s longstanding requirements that all current and pending support, including for a project under consideration, for ongoing projects, and for any proposals currently under consideration, must be provided regardless of whether the support is issued to the proposing organization or directly to the individual.

Language was added to expand examples of current and pending support, and to specify that all projects and activities that require a time commitment must be reported (no minimum was established), even if the support received is only in-kind. New electronic format(s) will be implemented beginning with the 2020 PAPPG to collect this information, as the agency will no longer permit applicants to upload PDFs to satisfy the requirement.

NSF typically revises its PAPPG annually by issuing a draft version in the summer for public comment. The agency then receives submitted comments, incorporates necessary updates into the draft and generally releases a final revised version in October, which becomes effective the following January. Because of the time it took for agency officials to review the numerous comments received on the draft version, NSF did not send its final revised version for clearance to OMB until November 2019. However, Feldman assured the FDP audience that when the final revision is approved, the agency would post the document to its website, provide information on the implementation date and host webinars highlighting significant changes.

At this point, Feldman said she did not know how the delays to the 2020 PAPPG will affect the process and schedule for posting a draft version of the 2021 PAPPG later this year.

(The full version of this story has now been made available to all for a limited time here.)

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