The administration of grants is governed by the actual conditions of the grant. (See Chapter V, Section A, Standard and Continuing Grants) for additional information regarding the contents of an NSF grant.) The following information highlights frequently asked grant administration questions.
For additional information about the award and administration of NSF grants, proposers and grantees may refer to the NSF Grant Policy Manual. Frequently Asked Questions (FAQs) regarding grant administration are available on the Policy Office Website at: http://www.nsf.gov/pubs/gpg/faqs.pdf.
The grantee organization has primary responsibility for general supervision of all grant activities and for notifying NSF of significant problems relating to research misconduct or administrative matters. The PI is responsible for the conduct of the research or educational work, the publication of results, and is expected to provide technical leadership to the project whether or not any salary is provided from grant funds.
Grants for financial assistance are subject to certain statutory and other general requirements, such as compliance with the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, and other laws and regulations prohibiting discrimination; prohibition of research misconduct; Drug-Free Workplace requirements; restrictions on lobbying; patent and copyright requirements; cost sharing; and the use of US-flag carriers for international travel. These are identified in the GPM and are summarized in the NSF Grant Conditions.
B. GRANTEE RESPONSIBILITIES AND FEDERAL REQUIREMENTS
The grantee organization has full responsibility for the conduct of the project or activity supported under the award and for adherence to the grant conditions. Although the grantee is encouraged to seek the advice and opinion of NSF on special problems that may arise, such advice does not diminish the grantee's responsibility for making sound scientific and administrative judgments and should not imply that the responsibility for operating decisions has shifted to NSF. The grantee is responsible for notifying NSF about: (1) any allegation of research misconduct that it concludes has substance and requires an investigation in accordance with NSF research misconduct regulations published at 45 CFR 689; or (2) any significant problems relating to the administrative or financial aspects of the award.
a. OMB Circular A-110 for grantees that are institutions of higher education, hospitals, and non-profit organizations; NSF has determined that OMB Circular A-110 standards also will be applicable to commercial organizations, including small businesses; and
b. 45 CFR 602 (the Common Rule implementing OMB Circular A-102), for units of State and Local Government.
C. PRIOR APPROVAL REQUIREMENTS
During the performance of a project, it may be appropriate for funds to be reallocated to support advancement of the project. Grantees have broad discretion to rebudget within the cost and administrative principles. Unless otherwise stated in the grant or as noted below, the grantee is authorized to transfer funds among various budget categories for allowable expenditures without prior NSF approval.
Prior written authorization from NSF is required only for the following:
transfer of the project effort;
change in objectives or scope;
change in PI or co-PI;
a substantial change in PI effort;
reduction in the cost sharing amount identified on Line M of the grant budget;
reallocation of funds budgeted for participant support; or
renovation/alteration (construction) activities costing $25,000 or more.
Changes in participant support costs require only Program Officer approval; all the other changes listed above require Program Officer and Grants Officer approval. (See also GPM Exhibit III-1, http://www.nsf.gov/publications/2002/nsf02151/ex3_1.pdf, which highlights grantee notifications to, and requests for approval from, NSF.) All requests for prior approval to NSF must be submitted electronically via the NSF FastLane system.
D. TRANSFER OF PI
If a PI plans to leave an organization during the course of a grant, the organization has the prerogative to nominate a replacement PI, request that the grant be terminated, or transfer the grant (via NSF) to the PI's new organization. Replacement PIs are subject to NSF approval. In those cases where a particular PI's participation is integral to a given project and the PI's original and new organizations agree, a grant transfer request shall be submitted via the Notification and Request Module in the FastLane system. 43
The transfer request shall include a:
a brief summary of progress to date;
a description of work yet to be accomplished;
budget, including total estimated disbursements to date (transfer amount will be automatically calculated, based on the amount entered in total estimated disbursements.) The original organization is responsible for including in the total estimated disbursements, any anticipated costs yet to be incurred against the original award. The transfer request cannot be submitted to NSF unless the original organization's Federal Cash Transactions Report (FCTR) for the most recent quarter has been received by NSF and the expenditures posted in the Financial Accounting System. The new organization is responsible for entering the appropriate budget line items prior to submission to NSF, and,
additional information for certain types of proposals, such as those that involve human subjects or vertebrate animals. Such proposals may require supplementary documents be submitted in conjunction with the transfer request. The capability exists within FastLane to provide such additional documents.
Special terms and conditions, as appropriate, cited in the original award automatically will convey to the new grantee organization. Note that if the PI's original award was submitted in response to a program solicitation that required cost sharing as part of the award, this cost sharing requirement also must addressed by the new organization in the budget portion of the transfer request. The cost sharing will be reflected as a condition in the award at the new grantee organization.
In those rare instances where:
the Authorized Organizational Representative of the original award must contact the cognizant Program Officer.
Upon transfer of the grant to the new organization, any monetary discrepancies must be resolved between the original and the new grantee, and NSF will not intervene in any disputes between the two organizations regarding the transferred amount.
See GPM 312.8 for additional information on PI transfers.
Title to equipment purchased or fabricated by an academic institution or other non-profit organization with NSF grant funds normally vests in the grantee organization. Title to equipment acquired through an NSF grant by a small business or other commercial organization normally will vest in the Government. When title to specialized equipment purchased with grant funds vests in the grantee organization and the PI moves to another non-profit organization, NSF encourages transfer of the equipment to the new organization provided it is not required at the organization holding title, the cost of the transfer (shipping charges, freight, etc.) is not excessive, and the PI continues the project at the new location.
F. EXCESS GOVERNMENT PROPERTY
As a means of providing additional support and conserving supply and equipment funds, NSF may sponsor the transfer of a limited quantity of excess Government-owned scientific equipment to an NSF grantee. To learn more about the NSF Grantee Excess Property Program, grantees should refer to GPM Section 546 or write to:
National Science Foundation
Property & Records Section, DAS, Room 295
4201 Wilson Boulevard
Arlington, VA 22230
Before transfer of excess Government equipment can be authorized, justification must be provided to NSF by the grantee that the equipment will further the objectives of an active NSF grant. The NSF grant numbers must be cited.
G. SUSPENSION OR TERMINATION OF GRANTS
NSF grants may be suspended or terminated in accordance with the procedures contained in the Grant General Conditions. 44 Grants may also be terminated by mutual agreement. Termination by mutual agreement shall not affect any commitment of grant funds that, in the judgment of NSF and the grantee, had become firm before the effective date of the termination. (See GPM Section 910)
1. Annual and Final Project Reports
For all multi-year grants (including both standard and continuing grants), the PI must submit an annual project report to the cognizant Program Officer at least 90 days before the end of the current budget period. (Some programs or awards require more frequent project reports).
Within 90 days after expiration of a grant, the PI also is required to submit a final project report. Failure to provide final technical reports delays NSF review and processing of pending proposals for that PI. PIs should examine the formats of the required reports in advance to assure availability of required data.
PIs are required to use NSF's electronic project-reporting system, available through FastLane, for preparation and submission of annual and final project reports. Such reports provide information on project participants (individual and organizational); activities and findings; publications; and, other specific products and contributions. Submission of the report via FastLane constitutes certification by the PI that the contents of the report are accurate and complete.
2. Quarterly and Final Expenditure Reports
Quarterly and final expenditure information is provided by grantees through the Federal Cash Transaction Report, SF 272. The report must be submitted by the grantee's financial officer through the Financial Administration functions in FastLane. Contact the Institutional Ledger Section of the Division of Financial Management for additional information at http://www.nsf.gov/bfa/dfm/cmeab.jsp#il_pers.
I. SHARING OF FINDINGS, DATA AND OTHER RESEARCH PRODUCTS
NSF advocates and encourages open scientific communication. NSF expects significant findings from supported research and educational activities to be promptly submitted for publication with authorship that accurately reflects the contributions of those involved. It expects PIs to share with other researchers, at no more than incremental cost and within a reasonable time, the data, samples, physical collections and other supporting materials created or gathered in the course of the work. It also encourages grantees to share software and inventions, once appropriate protection for them has been secured, and otherwise act to make the innovations they embody widely useful and usable.
NSF program management will implement these policies, in ways appropriate to field and circumstances, through the proposal review process; through award negotiations and conditions; and through appropriate support and incentives for data cleanup, documentation, dissemination, storage and the like. Adjustments and, where essential, exceptions may be allowed to safeguard the rights of individuals and subjects, the validity of results and the integrity of collections, or to accommodate legitimate interests of investigators.
J. ACKNOWLEDGMENT OF SUPPORT AND DISCLAIMER
An acknowledgment of NSF support and a disclaimer must appear in publications (including World Wide Web sites) of any material, whether copyrighted or not, based on or developed under NSF-supported projects:
"This material is based upon work supported by the National Science Foundation under Grant No. (grantee must enter NSF grant number)."
NSF support also must be orally acknowledged during all news media interviews, including popular media such as radio, television and news magazines.
Except for articles or papers published in scientific, technical or professional journals, the following disclaimer must be included:
"Any opinions, findings, and conclusions or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the National Science Foundation."
K. RELEASE OF GRANTEE PROPOSAL INFORMATION
A proposal that results in an NSF award will be available to the public on request, except for privileged information or material that is personal, proprietary or otherwise exempt from disclosure under law. Appropriate labeling in the proposal aids identification of what may be specifically exempt. (See Chapter I, Section D.3, The Full Proposal.) Such information will be withheld from public disclosure to the extent permitted by law, including the Freedom of Information Act. Without assuming any liability for inadvertent disclosure, NSF will seek to limit disclosure of such information to its employees and to outside reviewers when necessary for merit review of the proposal, or as otherwise authorized by law. Portions of proposals resulting in grants that contain descriptions of inventions in which either the Government or the grantee owns a right, title, or interest (including a non-exclusive license) will not normally be made available to the public until a reasonable time has been allowed for filing patent applications. NSF will notify the grantee of receipt of requests for copies of funded proposals so the grantee may advise NSF of such inventions described, or other confidential, commercial or proprietary information contained in the proposal.
A proposal that does not result in an NSF grant will be retained by NSF for a prescribed time (currently five years), but will be released to the public only with the consent of the proposer or to the extent required by law.
L. LEGAL RIGHTS TO INTELLECTUAL PROPERTY
NSF normally allows grantees to retain principal legal rights to intellectual property developed under its grants. This policy provides incentive for development and dissemination of inventions, software and publications that can enhance their usefulness, accessibility and upkeep. It does not, however, reduce the responsibility of researchers and organizations to make results, data and collections available to the research community.
43 Detailed instructions on submission of a grant transfer request are available electronically on the FastLane Website. Back to Text
44 NSF Grant Conditions are available electronically at http://www.nsf.gov/home/grants/grants_gac.jsp. Back to Text
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