Working with NSF

Sponsor-specific tools and resources for working with the National Science Foundation (NSF). The National Science Foundation's (NSF) Proposal & Award Policies & Procedures Guide (PAPPG), is effective for proposals with off-campus or off-site work due on or after January 30, 2023. 

Current and pending support is a term generally used by all other federal sponsors and other types of funding entities to request the submission of information for key personnel's active and pending review or award research funding. It is each investigator’s responsibility to ensure true, complete and accurate reporting of all sources of support for their research activities. While reporting other support has always been expected, a number of federal agencies have published expanded guidance.

Review recent announcements by NSF regarding undue foreign influence at U.S. institutions:

• July 11, 2019, Dear Colleague Letter commented on an increase in undue foreign influence activities and stated NSF would ensure current and pending support requirements were known, understood, and followed
• December 2019, Fundamental Research Security Report identified “problems with respect to research transparency, lack of reciprocity in collaborations and consortia, and reporting of commitment and potential conflicts of interest”

All faculty, staff, students, and postdoctoral researchers supported by NSF-sponsored projects must complete the CITI RCR online course within 60 days of appointment to the project.

In addition to completing the training themselves, the Principal Investigator (PI) is responsible for ensuring that all students and postdocs complete the CITI RCR course and begin a dialogue on the responsible conduct of research. PI’s should not include any specific information on RCR training within proposals. Training records are subject to monitoring by NSF auditors.

NSF requires certification that universities have a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to faculty, staff, undergraduates, graduate students, and postdoctoral researchers who receive NSF support to conduct research. Ohio State’s Institutional Responsible Conduct of Research Plan is available. This certification is completed by an authorized Ohio State representative as part of the institutional proposal approval process (e.g., when a sponsored program officer submits the proposal in FastLane). Chapter IX.B.1 Responsible and Ethical Conduct of Research (RECR) of the NSF Proposal and Award Policies and Procedures Guide.

The CHIPS and Science Act of 2022 requires that faculty and senior personnel paid or supported by NSF funds complete RECR training for grants due or submitted by July 31, 2023. Ohio State meets this requirement via the CITI RCR course.

NSF now requires proposers to certify that they have a plan for creating and maintaining Safe and Inclusive Working Environments for Off-Campus and Off-Site Research for that project. 

NSF recognizes that a community effort is essential to eliminate sexual and other forms of harassment in science and to build inclusive scientific climates where people can learn, grow, and thrive. The Office of Sponsored Programs provided details and resources for compliance at Ohio State.

Grant closeout is the process by which NSF determines that all required work of the grant has been completed. Grants are administratively closed by NSF after receipt of the Final Project Report and after determination that any other administrative requirements in the grant have been met.

PIs must use Research.gov to meet all NSF technical reporting requirements, including submission of annual, final, and project outcomes reports.

Requirements

NSF requires the submission of annual reports and a final report no later than 120 days following the end date of an award. Each report is reviewed by the award's managing Program Officer; the reporting requirement is met only after the Program Officer has reviewed and approved the report. In the case of a "no-cost extension," an annual report is still required for that year.

NSF also requires that PIs submit a non-technical, Project Outcomes Report (POR), for the general public 120 days following the expiration of an award.

Reporting Period

The annual report is due no later than the 90-day period before the end of the current budget period for the award; it is overdue the day after that 90-day period ends. The final report is due no later than 120 days following the expiration of the award; it is overdue after that 120-day period ends. Overdue reports will prevent the release of continuing grant increments (CGI), approval of No-cost Extensions, and the awarding of additional funding to the PI and all co-PIs listed on the award that has the overdue report.

Consequences for Non-Compliance

As stated in Important Notice No. 148: Improving Compliance with NSF Project Reporting Requirements dated 12/10/21:

“Project reports demonstrate result-oriented accountability for grants, enhance stewardship, and ensure that the American people are receiving value for funds spent on grant programs…. 2 CFR §200.344 "Closeout" introduced a new requirement specifying that, "The recipient must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award." Additionally, §200.344 (i) specifies, "If the non-Federal entity does not submit all reports in accordance with this section within one year of the period of performance end date, the Federal awarding agency must report the non-Federal entity's material failure to comply with the terms and conditions of the award with the OMB-designated integrity and performance system (currently Federal Awardee Performance and Integrity Information System (FAPIIS))." NSF takes project reporting compliance seriously and will explore all available mechanisms to ensure compliance up to and including the enforcement actions contained in §200.339.”

Office of Sponsored Programs leadership will review Ohio State’s NSF portfolio for overdue reports on a quarterly basis, and notify investigators if they have an overdue report, escalating notifications to department chairs and the Vice President for Research if necessary.