COGR Urges NSF to Delay Some Provisions in Draft PAPPG
Given the already “heavy …burden” faced by small institutions and the National Science Foundation’s (NSF) low award rate, the Council on Governmental Relations (COGR) has asked NSF to delay the use of a biographical template for 12 months and refrain from imposing disclosure requirements at the proposal stage. COGR’s June 13 comments are in response to NSF’s draft Proposal & Award Policies & Procedures Guide (PAPPG), which was published in April. Once finalized, the PAPPG is scheduled to go into effect for funding applications submitted in January. “COGR requests that NSF delay the requirement to use SciENcv exclusively to develop and submit Current and Pending Support for an additional 12 months to provide time for NSF to make further refinements and for recipient institutions to build efficient processes and interfaces to support Current and Pending Support disclosures through SciENcv,” the organization said in comments posted on its website. SciENcv is a system for federal awardees administered by the National Center for Biotechnology Information.
Additionally, COGR took issue with the draft’s provisions on the resubmission of current and pending support before an award is made. “We understand the need for NSF to assess budgetary and scientific overlap before award. However, we see this as an NSF business review and unrelated to scientific peer review of the application. This raises questions about why this information is needed at the time of proposal since the data is often stale within a few months of proposal submission,” COGR said. “Submission should be delayed until the project is selected for funding” to “significantly reduce the administrative burden” on principal investigators. COGR noted that “only about 28% of proposals are selected for funding,” and added that such a change on submissions would be “consistent with the current NIH process.”