NSF Automated Compliance Checking of Proposals and Other Policy Changes

Important Information Regarding Automated Compliance Checking of NSF Proposals and Other Policy-Related Changes
On January 26, 2015, the National Science Foundation (NSF) will implement changes in FastLane to support the revised version of the Proposal and Award Policies and Procedures Guide (PAPPG) and to run additional automated compliance checks on proposals.

Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 15-1)
A revised PAPPG was issued on November 20, 2014, which incorporates OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), as well as other policy updates. The following changes will be made to FastLane to support the revised PAPPG:
• Budget Form Update: The budget form will be updated so that the “Residual Funds” line (Line K) will not be editable for all programs except Small Business Innovation Research/Small Business Technology Transfer (SBIR/STTR). As this field is currently used for the purpose of collecting fees, “Residual Funds” will be renamed to “Small Business Fee.”
• Budget Justification Upload: Budget justification can no longer be entered as text. Awardees will be required to upload a budget justification for each organization added to the budget via an upload screen. Already, 95% of proposers take advantage of the upload option.
• Cost Sharing Notifications Requirement: The existing requirement that only awards with cost sharing of $500,000 or more must submit a cost sharing certificate will be modified to support the revised policy which specifies that cost sharing notifications must be submitted by all awardees with awards that include cost sharing.
• New Funding Mechanism: The FastLane proposal cover sheet will be updated to include the new funding mechanism type, Ideas Lab. Ideas Lab is designed to support the development and implementation of creative and innovative project ideas. These projects will typically be high-risk/high-impact as they represent new and unproven ideas, approaches, and/or technologies.

Automated Compliance Checks
FastLane will begin to run an additional 24 automated compliance checks on proposals to ensure they comply with requirements outlined in the PAPPG, Chapter II.C.2 of the Grants Proposal Guide (GPG). These checks will validate a proposal for compliance with page count, proposal sections per type of funding mechanism and budget related rules for proposals submitted in response to the GPG, Program Announcements and Program Descriptions. At this time, these checks will not be enforced for proposals submitted in response to Program Solicitations.
Page Count: Page count rules will be enforced on the following proposal sections:
o Project Description: 15-page limit [exceptions: 8-page limit for Early-Concept Grants for Exploratory Research (EAGER), and 5-page limit for Rapid Response Research (RAPID)]
o Budget Justification: 3-page limit for the proposing institution and a separate, 3-page limit for each sub-recipient organization
o Mentoring Plan: 1-page limit
o Data Management Plan: 2-page limit
Budget: Budget-related checks will focus primarily on proposal duration and requested amount. For example, the system will enforce a maximum requested amount of $200,000 for a RAPID proposal and $300,000 for an EAGER proposal.
• Proposal Section: Proposal sections will be enforced by their funding mechanism for Program Announcement, Program Description and other GPG-type funding opportunities. For example, an error message will appear if a Project Description was not provided for an EAGER proposal.
The checks detailed above will be triggered when the “Check Proposal,” “Forward to SPO,” or “Submit Proposal” functions are selected by a proposer or proposing organization. Depending on the rule being checked, a warning or error message will display when a proposal is found to be non-compliant. If an error message appears, the organization will not be able to submit the proposal until it is compliant. To view a detailed list of all compliance checks, click here
Please contact policy@nsf.gov for any further questions.

Is it a gift, grant, or contract?

The Ohio State University regularly receives funding from a variety of sources including government agencies, corporations, and private agencies.  Private sector entities (private agencies, professional associations, private foundations, corporate foundations and corporations) may be either donors or sponsors depending on the nature, intent and expectations of the funding they are providing. It’s important to categorize these funds correctly so that they can be recorded, managed and reported in the manner that ensures appropriate stewardship and maximizes the benefits for both donor/sponsor and the university.

Funds generally fall into one of two categories: Sponsored agreements or Philanthropic gifts.

  •  The Ohio State University Office of Sponsored Programs (OSP) is the entity authorized by the university to seek, accept and administer all sponsored agreements.

Sponsored projects fall within several general functional categories. Examples of those categories are: research, training, clinical trials, public service, fellowships, and equipment and travel awards. In general, sponsors of those activities include agencies of the Federal government, state, and local government, foundations, international organizations, research institutes, professional societies, and corporations. These organizations fund sponsored projects through a variety of mechanisms such as contracts, grants, letter agreements, purchase orders, and/or cooperative agreements. The Office of Sponsored Programs (OSP) is solely responsible for the proposing, negotiation, acceptance, and establishing of accounts for all sponsored research grants and contracts issued to the University.

Sponsored agreements are reciprocal, with each party giving and receiving something of relatively equal value in the transaction.

  •  Philanthropic gifts and donations are received through the Ohio State University Foundation and managed by the Office of University Development.

The FAES Office of Development does not negotiate research grants and contracts; it accepts philanthropic gifts which may require reporting, but not receivables.  The FAES Office of Development only accepts gifts, it does not accept non-gift funds generated by University-sponsored, revenue-producing activities, including fee for service or use of University facilities, revenues from ticket sales, registration fees or funds generated by the sale of research by-products or payment of contracts or services provided by the faculty or staff in their roles as University employees.

Philanthropic gifts voluntarily transfer money, services or property from a donor to the university. There is no expectation of direct economic benefit or the provision of goods and services to the donor, although donors can place stipulations on gifts that direct the funds to the donors’ areas of interest. The absence of quid pro quo language helps define the charitable nature of this type of giving. Philanthropic gifts are received as grants or outright gifts.

Since the term Grant can refer to a Sponsored agreement or a Philanthropic gift, it is important to look at both the intent of the funding and the other requirements of the grant to determine how it should be managed.

The following indicators have been developed to help direct specific opportunities to the right university office.

Indicators for Administration by the Office of Sponsored Programs (OSP)

  • Grant is from a governmental or quasi-governmental entity, or is from a private-sector sponsor that provides a subcontract or sub-grant containing federal “flow down” provisions.
  • The sponsor places restrictions on publication of data from studies supported by the agreement. This would include a requirement that the sponsor review manuscripts, talks, etc., before submission for publication or presentation.
  • The sponsor requests proprietary rights to data or inventions resulting from activities conducted under the agreement. This would include any proprietary rights and/or references to licensing arrangements for patents or copyrights developed as a consequence of the activity.
  • Studies are to be conducted on substances/products/processes, etc., owned by the sponsor.
  • The sponsor hopes to gain economic benefits as a result of the activity to be conducted.
  • The sponsor participates in determining the work to be performed or services to be provided on the project.

 Indicators for Administration by the Office of University Development

  • The grant is from a non-governmental source and is either for capital improvements, the university’s endowment or current use funds. Current use funds are used to finance routine operations, including programming, within a college/unit.
  • The grant is from a private foundation and only requires a proposed plan, brief budget and stewardship reporting.
  • The donor specifically intends the grant to be a charitable gift as reflected by the absence of any quid pro quo language.
  • The conditions or stipulations placed on the use of the award are reasonable and serve to direct the funds to areas such as scholarships, programs, infrastructure, or general research support of interest to the donor.
  • The donor makes the gift to the university without expectation of direct economic or other tangible benefit, including the proprietary right to use the results of the study, commensurate with the value of the gift. Indirect benefits such as tax advantages, business or personal goodwill derived from close association with the university, and miscellaneous benefits derived from donor club status are not sufficient to negate gift intent.

Establishing and understanding the donor’s intended use of the funds will usually answer the question as to which of the two university foundations that process private gifts should process the money. If however, there are still questions, contact:

Ohio State University Office of Sponsored Programs, Business and Industry Contracts
Kristy Baker
Assistant Director, Office of Sponsored Programs
614-292-3187
baker.913@osu.edu

 

CFAES Office of Development
Hilary Price
Director, Corporate and Foundation Partnerships
614-292-2957
price.1129@osu.edu

 

CFAES/OARDC Grants and Contracts
Lori Kaser
Grants & Contracts Administrator
330-263-3647
kaser.37@osu.edu

 

 

Welcome

Welcome to the Grant Development Support Unit Blog.

The creation of the GDSU stemmed from the strategic plan of the College of Food, Agricultural, and Environmental Sciences (CFAES) at The Ohio State University. This plan emphasized the desire to support faculty with grant preparation, proposal submissions, and team building. The plan also aimed to increase the competitiveness of CFAES proposals and to increase the number of proposals submitted to federal sponsors.  GDSU proposal development services help faculty find and secure funding for their research. The staff offers guidance to researchers in planning and conceptualizing externally funded research projects, finding funding opportunities, and submitting well-crafted and responsive applications. The GDSU has been successful in obtaining more than $61 million in new extramural funding since its inception in 2010.

The GDSU is a service provided for the College of Food, Agricultural and Environmental Sciences by the OARDC Director’s Office.  We have offices on both the Wooster and Columbus campuses.  Please stop by to see how we can help you submit a successful proposal.