Reminder! NSF 17-1 Proposal & Award Policies & Procedures Guide (PAPPG) Goes Into Effect 1/30/2017

Please see the information below from NSF regarding the new PAPPG with Frequently Asked Questions and the NSF Prospective New Awardee Guide

 

Original post on NSF Policy Office (Jean Feldman)

The NSF Policy Office in the Division of Institution and Award Support is responsible for developing, implementing and issuing proposal and award policy for the programs of the National Science Foundation and is available to assist you with questions involving policy related issues. Questions related to specific awards should be directed to the Division of Grants and Agreements.

General Application Guide for NIH AND Other PHS Agencies

G.100 – How to Use the Application Instructions

 

For more detailed information visit:

https://grants.nih.gov/grants/how-to-apply-application-guide/forms-d/general/g.100-how-to-use-the-application-instructions.htm

Revised NSF Proposal & Award Policies & Procedures Guide (PAPPG), effective January 30, 2017

Please note the revised NSF Grant Proposal Guidelines ( NSF 17-1) that will go into effect for proposals submitted or due on or after January 30, 2017.

Significant changes to the NSF PAPPG are as follows:

NSF 17-1 January 30, 2017
Significant Changes and Clarifications to the PAPPG

Overall Document

  • The PAPPG has been modified in its entirety, to remove all references to the Grant Proposal Guide (GPG) and Award & Administration Guide (AAG). The document will now be referred to solely as the NSF Proposal & Award Policies & Procedures Guide (PAPPG). The document will be sequentially numbered from Chapter I-XII and all references throughout have been modified to reflect this change. Part I of the document covers NSF’s proposal preparation and submission guidelines, and Part II covers NSF’s award, administration and monitoring guidelines.
  • Editorial changes have been made to either clarify or enhance the intended meaning of a sentence or section or ensure consistency with data contained in NSF systems or other NSF policy documents. Throughout the PAPPG, website references and Division or Office names have been updated to reflect current information.

Significant Changes to the PAPPG Part I

  • Chapter I.D.1, Letters of Intent (LOI), includes additional language regarding the submission of a LOI for collaborative proposals. Proposers that plan to submit a collaborative proposal from multiple organizations should submit a single LOI for the entire project, given that NSF considers a collaborative proposal to be a unified research project.
  • Chapter II.B, Format of the Proposal, has been updated to include two new types of proposals, RAISE and GOALI. These two types of proposals are described in greater detail in Chapter II.E. An additional resource has also been added to this section with information on NSF auto-compliance checks that are conducted during the proposal preparation and submission process.
  • Chapter II.C.1.e, Collaborators & Other Affiliations Information, includes additional instructions for proposers. Each section of the Collaborators & Other Affiliations Information should be listed alphabetically by last name. The text has also been revised to remove the requirement that proposers list postgraduate scholar sponsors in this section of the proposal. Postgraduate scholar sponsor is not a disqualifying relationship for a reviewer, therefore, it was determined that this information is not necessary.
  • Chapter II.C.2, Sections of the Proposal, has been revised to inform proposers that proposal preparation for RAPID, EAGER, RAISE, GOALI, Ideas Lab, FASED, Conference, Equipment, Travel, Center, Research Infrastructure and Fellowship projects may deviate from the content requirements of a full research proposal.
  • Chapter II.C.2.a, Cover Sheet, has been updated to provide instructions that more closely follow the proposal preparation screens in FastLane.
  • Chapter II.C.2.d(iii), Results from Prior NSF Support, includes revised language to clarify NSF’s purpose for collecting this information in the Project Description. The purpose of the Results from Prior NSF Support section is to assist reviewers in assessing the quality of prior work conducted with current or prior NSF support. Additional instructions have also been added regarding the type of information that should be included for projects that have been recently awarded, where no new results exist.
  • Chapter II.C.2.g(vi), Other Direct Costs, has been updated to include information on incentive payments, for example, payments to human subjects or incentives to promote completion of a survey. These costs should be included on line G6 of the NSF Budget and should be proposed in accordance with organizational policies and procedures. Indirect costs should be calculated on incentive payments in accordance with the organization’s approved US Federally negotiated indirect cost rate(s).
  • Chapter II.C.2.g(x), Fees (Line K on the Proposal Budget), has been added to provide instructions for use of the Fee line on the NSF budget, which is available for use only by the SBIR/STTR programs.
  • Chapter II.C.2.j, Special Information and Supplementary Documentation, has been updated to include language that informs submitters of the type of information that may be requested by NSF in order to comply with Federal environmental statutes, including, but not limited to, the National Environmental Policy Act, the National Historic Preservation Act. And the Endangered Species Act.
  • Chapter II.D, Special Processing Instructions, has been revised to address areas where special proposal processing may be required. Information on RAPID, EAGER, Ideas Lab, FASED, Equipment, Conference, and Travel Proposals has been moved to Chapter II.E.
  • Chapter II.D.5, Proposals Involving Human Subjects, has been updated to reflect the Foundation’s implementation of 45 CFR 690.118, applications and proposals lacking definite plans for involvement of human subjects. A hypertext link is provided to an NSF-approved format that may be used to submit such determinations by proposing institutions. Clarification has also been added regarding the IRB documentation that NSF must have in order to make an award when proposals involve human subjects.
  • Chapter II.E, Types of Proposals, has been added to describe, in one place, the various other types of proposals that can be submitted to NSF, including the two new types, RAISE and GOALI. This section includes proposal preparation instructions for each of the types of proposal that may supplement or deviate from the guidance provided elsewhere in Chapter II.
  • Chapter II.E.9, Travel Proposal, has been updated from “International Travel Proposals” to “Travel Proposal” to reflect that this type of proposal can be used for both domestic and international travel requests. Additional proposal preparation instructions have also been added to inform proposers of the required proposal elements, including the requirement that the Project Description contain Results from Prior NSF Support.

Clarifications and Other Changes to the PAPPG Part I

  • Introduction A, About the National Science Foundation, has been updated to clarify where proposers can find information on one of NSF’s flagship programs, the NSF Graduate Research Fellowship Program (GRFP). Guidance regarding the GRFP program may be found in the program solicitation, as well as in the GRFP Administration Guide.
  • Chapter I.E, Who May Submit Proposals, includes additional language clarifying that unaffiliated individuals rarely receive direct funding support from NSF, because recipients must be able to demonstrate their ability to fully comply with the recipient requirements specified in 2 CFR § 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). As such, unaffiliated individuals are strongly encouraged to affiliate with an organization that is able to meet the requirements specified in 2 CFR § 200.
  • Chapter I.F, When to Submit Proposals, has been revised to include additional instructions on how to submit proposals under the Special Exception to NSF’s Deadline Date Policy. This section includes proposal preparation instructions for organizations impacted by a natural or anthropogenic disaster. Impacted proposers must check the “Special Exception to the Deadline Date Policy” box on the NSF Cover Sheet and upload the requisite Single Copy Document(s).
  • Chapter II.C.2, Sections of the Proposal, has been amended to include k. Single Copy Documents in the list of the required components of a full research proposal.
  • Chapter II.C.2.f(i), Biographical Sketch(es), Senior Personnel, has been revised to reflect that FastLane no longer accepts the Biographical Sketch inserted as text. The Biographical Sketch for each senior personnel must be uploaded as a single PDF file associated with that individual.
  • Chapter II.C.2.g(i)(a), Senior Personnel Salaries & Wages Policy, has been amended to include a reference to 2 CFR § 200.430(i) to assist proposers in locating the specific requirements relevant to the documentation of effort.
  • Chapter II.C.2.g(iii), Equipment (Line D on the Proposal Budget), includes an additional reference to 2 CFR § 200.313 to assist proposers in locating the specific requirements of relevance in the Uniform Guidance.
  • Chapter II.C.2.g(iv)(b) Domestic Travel, has been revised to inform proposers that travel, meal and hotel expenses of grantee employees who are not on travel status are unallowable. Additional language has also been added stating that costs of employees on travel status are limited to those specifically authorized by 2 CFR § 200.474.
  • Chapter II.C.2.g(viii), Indirect Costs (also known as Facilities and Administrative Costs (F&A) for Colleges and Universities) (Line I on the Proposal Budget), has been updated to clarify that the use of an indirect cost rate lower than the organization’s approved negotiated indirect cost rate is considered a violation of NSF’s cost sharing policy.
  • Chapter II.C.2.g(xii), Voluntary Committed and Uncommitted Cost Sharing, has been amended to include an additional reference to 2 CFR § 200.99, definition of voluntary committed cost sharing. Clarifying language has also been added to emphasize how voluntary committed and voluntary uncommitted cost sharing are treated differently by NSF. In accordance with the Uniform Guidance, in order to be considered voluntary committed cost sharing, the amount must appear on the NSF budget, and be specifically identified in the approved NSF budget. Voluntary uncommitted cost sharing, however, should not be included in the proposal budget or budget justification and these resources are not financially auditable by NSF.
  • Chapter II.C.2.g(xiii)(a), Entertainment, includes an additional reference to 2 CFR § 200.438 to assist proposers in locating the specific requirements of relevance in the Uniform Guidance.
  • Chapter II.C.2.j, Special Information and Supplementary Documentation:
    • has been updated to clarify where the “Mentoring Plan” and “Data Management Plan” should be uploaded in the Supplementary Documentation section of FastLane.
    • includes additional language to emphasize the importance of submitting letters of support only when specifically required by a program solicitation.
    • has been amended to reflect changes in requirements for Antarctic proposals. Antarctic proposals to any NSF program require “Logistical Requirements and Field Plan” supplementary documentation to be submitted with the proposal.
  • Chapter II.D.3.b, Submission of a collaborative proposal from multiple organizations, has been updated to include the Collaborators & Other Affiliations Information in the list of required sections for a collaborative proposal. The Collaborators & Other Affiliations Information should be separately provided by the lead and non-lead organization(s) in a separately submitted collaborative proposal.
  • Chapter II.D.4, Proposals Involving Vertebrate Animals, has been revised to enhance clarity on the use of vertebrate animals for research or education on NSF supported projects. The revised language in this section states that any project proposing the use of vertebrate animals for research or education must comply with the provision in PHS Assurance for Institutional Commitment (Section II) that requires the submitting organization to establish and maintain a program for activities involving animals in accordance with the Guide for the Care and Use of Laboratory Animals (Guide). Taxon-specific guidelines may be used as supplemental references. Departures from the Guide must be approved by the IACUC and based on scientific, veterinary, medical, or animal welfare issues (for more information, see OLAW-Departures from the Guide).
  • Chapter II.D.7, Projects Requiring High-Performance Computing Resources, Large Amounts of Data Storage, or Advanced Visualization Resources, includes additional language that clarifies how submitters can address the locally available high-performance computing resources in their proposal. The description of available computing resources has also been updated.
  • Chapter II.E.11, Research Infrastructure Proposal, has been updated to include a reference to the Large Facilities Manual, a public document managed by the Large Facilities Office, which contains NSF policy related to the planning and management of large facility projects.
  • Exhibit II-1, Proposal Preparation Checklist, has been clarified with an additional sentence letting proposers know that FastLane uses different rules for each type of proposal (e.g. Research, RAPID, EAGER, RAISE, GOALI, Ideas Lab, FASED, Conference, Equipment or Travel) to check for compliance prior to submission to NSF. Additional checklist components have also been added to assist proposers in the pre-submission administrative review of proposals to NSF.
  • Exhibit II-2, Potentially Disqualifying Conflicts of Interest, has been updated to clarify the types of relationships that would prevent a reviewer from reviewing a proposal unless a waiver has been granted by NSF. Specifically, language relating to serving as a consultant at an organization, and involvement as a former Ph.D. student/ advisor has been added in this exhibit.
  • Exhibit II-6, Nondiscrimination Certification, has been revised to ensure that references to subrecipients, contractors and subawards are consistent with definitions in 2 CFR § 200, Subpart A, Acronyms and Definitions.
  • Exhibit II-7, Definitions of Categories of Personnel, has been updated to clarify that a Faculty Associate can be a faculty member or equivalent at the performing institution.
  • Chapter III.F.2(c)(3), Process to Appeal NSF’s Decision to Decline a Proposal for Financial or Administrative Reasons, Procedures, includes additional language to clarify that proposers may submit documentation to support their statements – even documentation that may not have been presented as part of the original review process – as long as it is not “new” information that would not have been available at the time the decision to decline was made.
  • Chapter IV.D.2(b), Reconsideration, has been updated to include Research Advanced by Interdisciplinary Science and Engineering (RAISE) in the list of proposals for which NSF’s reconsideration process does not apply.

Significant Changes to the PAPPG Part II

  • Chapter VI.D.3.c(ii), NSF-Approved Extension, has been updated to clarify that a request for an NSF-approved extension should be submitted at least 45 days prior to the end date of the grant and must be signed and submitted by the AOR via use of NSF’s electronic systems. Information has also been added to make grantees aware of the limited time period of availability of funds due to cancelation of appropriations.
  • Chapter VII.B.2.c, Addition of co-PI/co-PD, has been added to provide instructions to grantees desiring to add a new co-PI/co-PD. This section includes instructions on how an AOR can prepare and submit this request via use of NSF’s electronic systems. This section lists the required components of this type of grantee request.
  • Chapter VIII.C.2, Payment Policies, has been amended to remove the requirement that grantees must certify that all disbursements have been made, or will be made within three days of the receipt of the payment.
  • Chapter VIII.E.6, Award Financial Reporting Requirements and Final Disbursement, has been supplemented with a new subpart, E.6., to make grantees aware of how NSF awards with canceled appropriations will be treated and to include the regulatory citation related to expiration of appropriated funds. In accordance with 31 USC 1552(a), funds will no longer be available for expenditure for any purpose beyond September 30th of the fifth fiscal year after the expiration of a fixed appropriation’s period of availability for incurring new obligations.
  • Chapter X.C.5, Travel and Temporary Dependent Care Costs, includes additional information on allowable travel expenses to specify that costs of employees on travel status are limited to those specifically authorized by 2 CFR § 200.474.
  • Chapter XI.B.1, Human Subjects, has been updated to reflect the Foundation’s implementation of 45 CFR 690.118, applications and proposals lacking definite plans for involvement of human subjects. Clarification has also been added regarding the IRB documentation that NSF must have for projects that involve human subjects.

Clarifications and Other Changes to the PAPPG Part II

  • Chapter VII.B.2.e, Substitute (Change) PI/PD or co-PI/co-PD, includes additional instructions on how an AOR can prepare and submit the request via use of NSF’s electronic systems. This section now lists the required components of this type of grantee request.
  • Chapter VIII.E.5, Award Financial Reporting Requirements and Final Disbursement, has been updated to inform grantees of the time limits applicable to the upward or downward adjustments to the Federal share of costs for a financially closed award.
  • Chapter IX.A, Conflict of Interest Policies, has been amended to remove the term “contractors” from this section for greater consistency with 2 CFR § 200, Subpart A, Acronyms and Definitions.
  • Chapter X.A.2.b, Pre-Award (Pre-Start Date) Costs, includes an additional footnote reminding grantees that in the case of a renewal award, costs incurred under the old grant cannot be transferred to the new grant.
  • Chapter X.B.2, Administrative and Clerical Salaries & Wages, has been updated to reference 2 CFR § 200.413, Direct Costs. Language has also been added to clarify that an AOR should initiate the request for NSF approval to direct charge salaries of administrative or clerical staff after an award has been made.
  • Chapter X.B.3, Intra-University (IHE) Consulting, has been revised to include an additional reference to 2 CFR § 200.430(h)(3) to assist proposers in locating the relevant requirements in the Uniform Guidance.
  • Chapter XI.B.3, Vertebrate Animals, has been supplemented with language regarding NSF’s implementation of the Federal Awardee Performance and Integrity Information System.

 

Available Formats: HTML | PDF
Document Type: Policies and Procedures
Document Number: nsf17001

Public Comment: Effective January 30, 2017

Document History: Posted: October 25, 2016. Replaces: nsf16001.

 

Original post by NSF 10/25/16

Effort Reporting Changes

Effort Reporting Changes

Effective July 1, 2016, and in accordance with federal regulations pertaining to effort certification on federal awards (Uniform Guidance Subpart E §200.430), MBL effort reporting procedures have changed. Sponsored project personnel are no longer required to certify effort on a monthly basis. The new biannual payroll verification process will require that Principal Investigators certify effort for all project personnel every six months. Please note that the process for PI-review of project expenditures and correcting project salary cost allocations (and any applicable cost corrections) will continue on a monthly basis in consult with the appropriate Research Administrator.

Principal investigators will have 30 days to complete the first iteration of the biannual payroll verification in January, 2017 for the 6-month time period beginning July 1 through December 31, 2016. Detailed procedures for this new process will be announced shortly and will be available on the OSP website.

Important! NSF Updates in Fastlane

On September 26, 2016, the National Science Foundation (NSF) will release updates to FastLane that may impact the way you work.

As part of NSF’s efforts to modernize proposal submission and increase competitive fairness in the proposal process, NSF continues to focus on implementing automated proposal compliance checks in FastLane.

Effective September 26, 2016, FastLane will now check to ensure that the combined text of the Project Summary text boxes (or uploaded PDF if the Project Summary contains special characters) does not exceed one page prior to submission, rather than the current check of 4,600 characters. See the Proposal & Award Policies and Procedures Guide (PAPPG), Chapter II.C.2b for further information.

The compliance checks will trigger an error message in the following circumstances:

o   Project Summary text exceeds the one-page limit;

o   Project Summary text is entered and the user also uploads a “Project Summary with Special Characters” supplementary document.

Note About Proposal File Update (PFU):

Proposers should be aware that if a proposal was received by NSF prior to September 26, 2016, containing a Project Summary that complies with the previous 4,600-character limit but exceeds the one-page limit, a PFU addressing any section of the proposal will result in the proposal not being accepted if it does not comply with these compliance checks. The checks will be run on all sections of the proposal, regardless of which section was updated during the PFU.

 Note About Grants.gov:

Proposers should also be aware that Grants.gov will allow a proposal to be submitted, even if it does not comply with these proposal preparation requirements. Should NSF receive a proposal via Grants.gov that is not compliant, it will be returned without review.

You are encouraged to share this information with your colleagues.  For system-related questions, please contact the NSF Help Desk at 1-800-381-1532 or Rgov@nsf.gov.  Policy-related questions should be directed to policy@nsf.gov.

Notice of Change in Animal Welfare Assurance Numbering System

Please note the updated MBL Animal Welfare Assurance No. (aka IACUC) is listed on the MBL Grant Information Sheet (v8.31.16)

For more information please see the NIH policy below regarding this update.

NIH Notice Number: NOT-OD-16-125

Key Dates
Release Date:  August 2, 2016

Related Announcements
None

Issued by
National Institutes of Health (NIH)

Purpose

This Notice informs Public Health Service (PHS) awardee institutions that the Office of Laboratory Animal Welfare (OLAW) has implemented a new Animal Welfare Assurance (Assurance) numbering system.

Background

OLAW oversees PHS-funded animal activities by the authority of the Health Research Extension Act of 1985 and the PHS Policy on Humane Care and Use of Laboratory Animals (Policy). The Policy requires that “No activity involving animals may be conducted or supported by the PHS until the institution conducting the activity has provided a written Assurance acceptable to the PHS, setting forth compliance with the Policy.” Assurance agreements are approved by OLAW and assigned a unique identification number which is used by institutions in applications and proposals for research activities involving the use of vertebrate animals.

Implementation

Effective July 25, 2016, OLAW implemented a new Animal Welfare Assurance database that utilizes a new numbering format (D00-00000). However, the old numbers (A000-01) will be retained for the life of the Assurance. Institutions with an Assurance will receive a new number and may use either the new or old Assurance number in communications with NIH. For convenience, OLAW will reference both new and old Assurance numbers in Assurance-related correspondence. Institutions will be able to view the new Assurance number on the OLAW website list of Assured institutions (Domestic | Foreign) and in any Assurance-related correspondence from OLAW. Institutions seeking a new Animal Welfare Assurance will be provided an Assurance number in the new format only.

original post from Notices of NIH Policy Changes https://grants.nih.gov/policy/notices.htm

 

New! OSP Subaward Payment Authorization Form

Beginning May 1st, 2016 OSP will be attaching a Subaward Payment Authorization cover page to all subaward invoices.  This cover page will replace the manual “stamp” currently used to provide account information, Principal Investigator signature and OSP approval.  The purpose of the new invoice cover page is to provide a mechanism of internal controls required by the new Federal Uniform Guidance for tracking the appropriateness of charges to subaward cost centers.  Upon review of the invoice, Principal Investigators will complete the cover page to approve payment.  Subaward invoices will still be routed through Research Administrators for each center.  Additional questions, please contact the Office of Sponsored Programs x7446

What is NSF’s Public Access Policy?

NSF requires that either the version of record or the final accepted manuscript in peer-reviewed scholarly journals and papers in juried conference proceedings or transactions (also known as “juried conference papers”) be deposited in a public access compliant repository designated by NSF; be available for download, reading and analysis free of charge no later than 12 months after initial publication; possess a minimum set of machine-readable metadata elements in a metadata record to be made available free of charge upon initial publication; be managed to ensure long-term preservation; and be reported in annual and final reports during the period of the award with a persistent identifier that provides links to the full text of the publication as well as other metadata elements. For more information, see section 3.1 of  “Today’s Data, Tomorrow’s Discoveries: Increasing Access to the Results of Research Funded by the National Science Foundation” at http://www.nsf.gov/pubs/2015/nsf15052/nsf15052.pdf.

For more information also see: http://www.nsf.gov/news/special_reports/public_access/

High Level Forms D Information Update from NIH

NIH Application Forms Update: FORMS-D
The NIH periodically updates grant application forms in order to remain current with the most recent form sets available through Grants.gov and approved by the Office of Management and Budget.
NIH and other agencies serviced by NIH’s electronic Research Administration (eRA) use the ‘Competition ID’ field of Grants.gov application packages for quick and easy identification of the forms being used for a particular Funding Opportunity Announcement or individual application package.

NIH will introduce application packages with a Competition ID of ‘FORMS-D’ for due dates on or after May 25, 2016.
Changes to PHS forms included in ‘FORMS-D’ application packages are as follows:

PHS 398 Career Development Award Supplemental Form
• New “Candidate Information and Goals for Career Development” attachment (combines “Candidate’s Background”, “Career Goals and Objectives”, and “Candidate’s Plan for Career Development/Training Activities during Award Period” attachments into a single attachment)
• New “Data Safety Monitoring Plan” attachment
• New “Authentication of Key Biological and/or Chemical Resources” attachment
• Updated Citizenship selections
• Reorganization of attachments
• Field order and label changes
• Added/updated burden statement and form expiration date
• Updated form instructions
PHS 398 Cover Page Supplement
• New Vertebrate Animals section added. New questions:                                                                                                     Are animals euthanized? Yes/No                                                                                                                                                                                          If Yes, is method consistent with AVMA guidelines? Yes/No                                                                                                                                                                                          If No to AVMA guidelines, describe method/provide scientific justification
• Ability to add Program Income information for 10 budget periods (previously 5)
• Field order and label changes
• Added/updated burden statement and form expiration date
• Updated form instructions

PHS 398 Modular Budget
• Indirect (F&A) Costs section changed to dynamically add indirect costs rather than providing static fields for four entries
• Minor label changes
• Added/updated burden statement and form expiration date
• Updated form instructions

PHS 398 Research Plan
• New “Data Safety Monitoring Plan” attachment
• New “Authentication of Key Biological and/or Chemical Resources” attachment
• Minor format and label changes
• Added/updated burden statement and form expiration date
• Updated form instructions

PHS 398 Research Training program Plan
• Removed “Background’ and “Recruitment Plan to Enhance Diversity” attachments (information previously included in these attachments moved to existing “Program Plan” attachment)
• New “Plan for the Instruction in Methods for Enhancing Reproducibility” attachment
• New Data safety Monitoring Plan attachment
• Format and label changes including categorizing attachments into sections
• Added/updated burden statement and form expiration date
• Updated form instructions

PHS 398 Training Budget
• Minor label changes
• Added/updated burden statement and form expiration date
• Updated form instructions
PHS 398 Training Subaward Budget Attachment(s) Form
• Streamlined instruction text
• Added/updated burden statement and form expiration date
• Updated form instructions
PHS Assignment Request Form
• New, optional form
• Used to provide structured information to NIH referral staff regarding: funding component assignment preference, study section preference, individuals who should not review your application due to conflicts, and scientific areas of expertise needed to review your application
• Complements existing “Cover Letter Attachment” on SF424 (R&R) form
• Added/updated burden statement and form expiration date
• Updated form instructions
PHS Fellowship Supplemental Form
• New “Applicant’s Background and Goals for Fellowship Training” attachment (Combines “Doctoral Dissertation and Other Research Experience”, “Goals for Training and Career”, and “Activities Planned Under Award” attachments into a single attachment)
• New “Letters of Support from Collaborators, Contributors, and Consultants” attachment
• New “Description of Institutional Environment and Commitment to Training” attachment
• New “Data Safety Monitoring Plan” attachment
• New “Authentication of Key Biological and/or Chemical Resources” attachment
• New Vertebrate Animals questions added: New questions
Are animals euthanized? Yes/No
If Yes, is method consistent with AVMA guidelines? Yes/No
If No to AVMA guidelines, describe method/provide scientific justification
• Updated list of values for the “Field of Training for Current Proposal” field; changed from 4-digit codes to 3-digit codes
• Updated Citizenship selections
• Reorganization of attachments
• Format and label changes
• Added/updated burden statement and form expiration date
• Updated form instructions

PHS Inclusion Enrollment Report
• Combines Planned Enrollment Report and Cumulative Inclusion Enrollment Report forms into a single form
Questions used to identify type of report:
-Delayed onset study? Yes/No
-Enrollment Type? Planned/Cumulative (Actual)                                                                                                           -Using an Existing Dataset or Resource? Yes/No                                                                                                                 -Enrollment Location? Domestic/Foreign
-Clinical Trial? Yes/No                                                                                                                                           -NIH-Defined Phase II Clinical Trial? Yes/No
• Added/updated burden statement and form expiration date
• Updated form instructions

Notice on Salary Limitation on Grants, Cooperative Agreements, and Contracts

Notice on Salary Limitation on Grants, Cooperative Agreements, and Contracts

Notice Number: NOT-OD-16-045

Key Dates
Release Date: December 24, 2015

Related Announcements
NOT-OD-16-044

Issued by
National Institutes of Health (NIH)

Purpose

This Notice provides information regarding the salary limitation for NIH grant and cooperative agreement awards and extramural research and development contract awards (referred to here as grants). For FY 2016, the Consolidated Appropriations Act, 2016 (Public Law 114-113), signed into law on December 18, 2015, restricts the amount of direct salary to Executive Level II of the Federal Executive pay scale. The Executive Level II salary is currently set at $183,300, increasing to $185,100 effective January 10, 2016.

Background

Every year beginning 1990, Congress has legislatively mandated a provision limiting the direct salary that an individual may receive under an NIH grant. For FY 2015, the Consolidated Appropriations Act, 2015 (Public Law 113-235), signed into law on December 16, 2014, restricted the amount of direct salary to Executive Level II of the Federal Executive pay scale. The Executive Level II salary was $183,300. This information was published December 30, 2014 in the NIH Guide for Grants and Contracts (NOT-OD-15-049).

For the purposes of the salary limitation, the terms “direct salary,” “salary,” and “institutional base salary” have the same meaning and are exclusive of fringe benefits and facilities and administrative (F&A) expenses, also referred to as indirect costs. An individual’s institutional base salary is the annual compensation that the applicant organization pays for an individual’s appointment, whether that individual’s time is spent on research, teaching, patient care, or other activities. Base salary excludes any income that an individual may be permitted to earn outside of the duties to the applicant organization.

NIH grant/contract awards for applications/proposals that request direct salaries of individuals in excess of the applicable RATE per year will be adjusted in accordance with the legislative salary limitation and will include a notification such as the following: None of the funds in this award shall be used to pay the salary of an individual at a rate in excess of the applicable salary cap. Please see the salary cap summary and the time frames associated with salary caps at http://grants.nih.gov/grants/policy/salcap_summary.htm.

Implementation of salary limitation for NIH grant and cooperative agreement awards and extramural research and development contract awards:
No adjustments will be made to modular grant applications/awards or to previously established commitment levels for non-competing grant awards issued with FY 2016 funds.

NIH competing grant awards with categorical budgets reflecting salary levels at or above the new cap(s) that are issued on or after the January 10, 2016 effective date, will reflect adjustments to the current and all future years so that no funds are awarded or committed for salaries over the limitation.

For awards issued in those years that were restricted to Executive Level II (see Salary Cap Summary, FY 1990 – FY 2016), including competing awards already issued in FY2016, if adequate funds are available in active awards, and if the salary cap increase is consistent with the institutional base salary, grantees may rebudget to accommodate the current Executive Level II salary level and contractors may charge at the higher level. However, no additional funds will be provided to these grant awards and the total estimated cost of the contract will not be modified.

An individual’s base salary, per se, is NOT constrained by the legislative provision for a limitation of salary. The rate limitation simply limits the amount that may be awarded and charged to NIH grants and contracts. An institution may pay an individual’s salary amount in excess of the salary cap with non-federal funds.

The salary limitation does NOT apply to payments made to consultants under an NIH grant although, as with all costs, those payments must meet the test of reasonableness and be consistent with institutional policy.

The salary limitation provision DOES apply to subawards/subcontracts for substantive work under an NIH grant or contract.

Competing grant applications and contract proposals that include a categorical breakdown in the budget figures/business proposal should continue to reflect the actual institutional base salary of all individuals for whom reimbursement is requested. In lieu of actual base salary; however, applicants/offerors may elect to provide an explanation indicating that actual institutional base salary exceeds the current salary limitation. When this information is provided, NIH staff will make necessary adjustments to requested salaries prior to award.

Questions & Answers

1. Q: If a grant award (competing or non-competing) has already been issued in FY 2016, will an adjustment be made?
A: No adjustments will be made. However, rebudgeting is allowable.

2. Q: Can I rebudget grant funds or charge contracts issued in prior years (see Salary Cap Summary, FY 1990 – FY 2016) funds to allow for the 2016 salary cap increase?
A: Yes, provided funds are available and the increase is warranted. Prorated figures should be used for the applicable months, i.e., the $185,100 level is effective beginning January 10, 2016.

3. Q: If an application/proposal fails to provide needed salary information, will an adjustment be made based on the new rates?
A: No adjustment will be made if an application fails to provide adequate information regarding the individual’s actual salary level.

4. Q: Does the NIH appropriation language link the salary cap to a Federal Executive Level or to a dollar level?
A: The link is to the Federal Executive Level pay scale (i.e., Executive Level I for FYs 2001-2011, Executive Level II for FYs 2012-2016).

5. Q: As the cap is linked to Federal Executive Levels, can grantees/contractors with ongoing awards rebudget/charge up to the various salary caps, based on the fiscal year of the award and the time the salary expense is incurred?
A: Yes, salary may be charged in accordance with the FY cap(s), as long as the levels are consistent with the individual’s institutional base pay. Please refer to the salary cap summary with times frames for existing salary caps, at: http://grants.nih.gov/grants/policy/salcap_summary.htm.

6. Q: Will grantees be permitted to submit revised categorical budgets reflecting higher base salaries?
A: Not as a general rule. NIH policy for categorical budgets states that grantees should always reflect actual base salaries in the requested budgets or provide an explanation indicating that actual institutional base salary exceeds the current salary limitation. As a general rule, NIH will use the information available in the existing application and make adjustments for the salary cap based on information available at the time of award.

The following are examples of the adjustments that NIH will make when salaries exceed the current salary limitation:

Example 1. Individual with Full-Time Appointment (based on grant award/contract issued on or after January 10, 2016 with salary limitation of $185,100)

Individual’s institutional base salary for a FULL-TIME calendar year appointment $ 200,000
Research effort requested in application/proposal – 6 months (50%)
Direct Salary requested $  100,000
Fringe benefits requested (25% of salary) $   25,000
Subtotal $ 125,000
Applicant organization’s F&A (indirect) costs at a rate of 45% of subtotal $   56,250
Amount requested – salary plus fringe benefits plus associated F&A (indirect) costs $ 181,250
If a grant/contract is to be funded, the amount included for the above individual will be calculated as follows:
Direct salary – restricted to a RATE of $ 185,100
Divided by 12 months multiplied by 6 months (50%) $   92,550
Fringe benefits (25% of allowable salary) $   23,137
Subtotal $  115,687
Associated F&A (indirect) costs at 45% of subtotal $   52,059
Total amount to be awarded due to salary limitation $  167,746
Amount of reduction due to salary limitation
($181,250 requested minus $167,746 awarded) $ 13,504

Example 2. Individual with Half-Time Appointment (based on a grant award/contract issued on or after January 10, 2016 with salary limitation of $185,100)

Individual’s institutional base salary for a HALF-TIME calendar year appointment $  100,000
Research effort requested in application/proposal – 1.8 months (30% of 6 months)
Direct Salary requested $   30,000
Fringe benefits requested (25% of salary) $    7,500
Subtotal $   37,500
Applicant organization’s F&A (indirect) costs at a rate of 45% of subtotal $   16,875
Amount requested – salary plus fringe benefits  
plus associated F&A (indirect) costs $   54,375
If a grant/contract is to be funded, the amount included in the award for the above individual will be calculated as follows:
Direct salary – restricted to a RATE of $   92,550
Divided by 6 months multiplied by 1.8 months (30%) $   27,765
Fringe benefits (25% of allowable salary) $     6,941
Subtotal $   34,706
Associated F&A (indirect) cost at 45% of subtotal $   15,618
Total amount to be awarded due to salary limitation $   50,326
Amount of reduction due to salary limitation  
($54,375 requested minus $50,326 awarded) $    4,049

Example 3. Individual with a Nine-Month Appointment (based on a grant award/contract issued on or after January 10, 2016 with salary limitation of $185,100)

Individual’s institutional base salary for a nine-month calendar year appointment $   150,000
Research effort requested in application/proposal – 2.7 months (30% of 9 months)
Direct Salary requested $   45,000
Fringe benefits requested (25% of salary) $   11,250
Subtotal $   56,250
Applicant organization’s F&A (indirect) costs at a rate of 45% of subtotal $   25,313
Amount requested – salary plus fringe benefits  
Plus associated F&A (indirect) costs $   81,563
If a grant/contract is to be funded, the amount included in the award for the above individual will be calculated as follows:
Direct salary – restricted to a RATE of $  138,825
Divided by 9 months multiplied by 2.7months (30%) $   41,648
Fringe benefits (25% of allowable salary) $   10,412
Subtotal $   52,060
Associated F&A (indirect) cost at 45% of subtotal $   23,427
Total amount to be awarded due to salary limitation $   75,487
Amount of reduction due to salary limitation  
($81,563 requested minus $75,487 awarded) $   6,076

Inquiries

Division of Grants Policy
Office of Policy for Extramural Research Administration (OPERA)
Office of Extramural Research
National Institutes of Health
Telephone: 301-435-0949
Email: GrantsPolicy@od.nih.gov