Sneak Preview: NSF FAQ Addresses Uniform Guidance Policies

May 14, 2015 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from an article in the Federal Grants Management Handbook.) The National Science Foundation (NSF) recently released a Frequently Asked Questions (FAQ) document that responds to specific concerns among its award recipients regarding the agency’s policies adopting in the Office of Management and Budget’s (OMB’s) uniform grant guidance. In the FAQ, NSF sought to clarify questions about uniform guidance implementation, indirect costs and travel, among other provisions.

Last December, NSF revised its Proposal and Award Policies and Procedures Guide (PAPPG), which contains the Grant Proposal Guide and the Award and Administration Guide, to implement the requirements of the OMB’s uniform grant guidance. Significant changes in the guide included a new risk assessment framework (§200.205) and revised conflict of interest (§§200.112-.113) and cost sharing (§200.306) provisions (see “NSF’s Revised Guide Incorporates Uniform Guidance,” January 2015). Also revised to incorporate the uniform guidance was NSF’s Grant General Conditions.

Implementation

In the new FAQ, NSF clarified that the uniform guidance is effective for awards and funding increments on existing awards made on or after Dec. 26, 2014 (§200.110). For existing awards made prior to Dec. 26, 2014, the terms and conditions referenced in the award notice will continue to apply. However, if the existing award receives a funding increment on or after Dec. 26, 2014, as part of a funding amendment, the updated Grant General Conditions will be incorporated by reference into the funding amendment.

NSF also clarified that when an existing award made prior to Dec. 26, 2014, receives a nonfunding amendment (e.g., a change in the principal investigator), it is not subject to the updated Grant General Conditions. “Nonfunding amendments do not change the terms and conditions of the [existing] award, except as noted in the administrative change,” NSF stated.

Another question asked, in the case of an amended award that now incorporates the Grant General Conditions, whether it was necessary to request a retroactive approval for items that normally require prior approvals. NSF said that once the existing award receives a funding amendment that incorporates the Grant General Conditions, preparation and submission of notifications and requests will follow the requirements specified in the new award conditions. Also, another question referred to a change in NSF’s Grant General Conditions that allows grant recipients up to 120 days to submit final disbursement requests to NSF’s Award Cash Management System. NSF stated that the 120-day standards will apply to all awards, both those awarded before and those awarded after Dec. 26, 2014.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site).

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