Effective January 25, 2016

Pam Baker-Webber, Senior Director of Research Administration, SEAS

Jennifer Lech, Sponsored Research Officer, FAS/RAS

Marrybell Ramos, Manager, Grants & Contracts Operations, OSP

Karen Rizman, Sponsored Programs Officer, OSP

Topics

Proposal Policies & Procedures Updates – Karen & Jennifer

Award & Administration Guide Updates - Pam

Dual Use Research of Concern (DURC) – Jennifer

Public Access Policy – Marrybell

Proposals must be submitted by 5pm/submittal local time, Chapter I.F

◦ Standard for all submissions, including proposals submitted in response to solicitations

◦ Failure to submit by 5 p.m. submitter’s local time will result in the proposal not being accepted.

Use of “should” and “must” has been reviewed throughout, and revised, where appropriate.

Format of the Proposal, Chapter II.B.2

◦ Language has been removed permitting solicitations to specify different type size, margin and spacing requirements.

Cover Sheet, Chapter II.C.2.a(4)(h) and Chapter II.C.2.j., respectively

◦ Contains guidance on the procedure to follow if the specific location of an international conference is not known at the time of proposal submission. If not known, enter “Worldwide.”

Project Summary, Chapter II.C.2.b

◦ Only Project Summaries that use special characters may be uploaded in the Supplementary Documents section.

◦ Results from Prior NSF Support, Chapter II.C.2.d(iii) • Revised to reflect that information on prior NSF funding

must be provided with a start date in the past 5 years (including current funding & NCEs), regardless of whether or not support is directly related to proposal.

• Prior funding includes not just salary support, but any

funding awarded by NSF, such as standard or continuing grants, Graduate Research Fellowship, Major Research Instrumentation, travel, conference, and center awards, etc.

Proposals Involving Vertebrate Animals, Chapter 11.D.7

◦ The following must be provided within the 15-page Project Description:

(i) rationale for involving animals;

(ii) choice of species and number of animals to be used;

(iii) description of the proposed use of the animals;

(iv) exposure of animals to discomfort, pain, or injury; and

(v) description of any euthanasia methods to be used.

◦ If IACUC approval is pending at the time of submission, indicate Pending as IACUC approval date on the cover sheet.

◦ If the proposal is selected for funding. an official IACUC approval letter must be provided to NSF before an award can be issued.

Biographical Sketch(es), Chapter II.C.2.f

Senior Personnel: May no longer be submitted as a single PDF for all Senior Personnel. Each individual’s BioSketch must be uploaded as a single PDF file

Other Personnel: Should be uploaded in the Other Supplementary Documents section (submit as one PDF for all)

Equipment Proposals: Should also be uploaded in the Other Supplementary Documents section (submit as one PDF for all)

May use third-party solutions, such as NIH’s SciENcv, to develop biographical sketch, however, the information they submit must be compliant with NSF proposal preparation requirements.

Collaborators & Other Affiliations Information, has been removed from the BioSketch and should be uploaded to the Single Copy document section

Collaborators & Other Affiliations Information, Chapter II.C.1.e

◦ This section has been removed from Biographical Sketch and will now be submitted as a single copy document.

◦ The following information must be provided for each individual identified as senior project personnel:

Collaborators and Co-Editors

Graduate Advisors and Postdoctoral Sponsors

Thesis Advisor and Postgraduate-Scholar Sponsor

List of Suggested Reviewers

◦ PIs should include the email address and institutional affiliation of persons they believe are well qualified to review the proposal.

Participant Support, has been supplemented with information on the types of costs that may be proposed and under what scenarios they are allowable. Chapter II.C.2.g(v), 2 CFR §200.75, respectfully

◦ Costs Allowances are stipends, subsistence allowances, travel allowances, and registration fees

◦ Other costs not described in 2 CFR §200.75 (such as incentives, gifts, souvenirs, t-shirts and memorabilia) must be justified in the budget justification and will be closely scrutinized by NSF

Administrative Salaries and Wages has been updated to parallel the language in 2 CFR §200.413 on administrative and clerical salaries and wages. Chapter II.C.2.g(i)(b) ◦ Must be integral to the project

Visa Costs, has been removed now that the Uniform Guidance CFR §200.463, contains coverage on this topic.

Chapter II.C.2.g(vi)(f) ◦ No changes in the policy refer to the Uniform Guidance.

Conference Proposals, has been supplemented to include information on the types of costs that may be proposed for conferences and under what scenarios they are allowable. Chapter II.D.9

Allowable Costs Unallowable Costs

Conference Facilities Meals & Coffee Breaks for Intramural

Meetings

Supplies Entertainment

Conference Services Alcoholic Beverages

Publications Costs

Salaries

Consultant Services & Speaker Fees

Meals & Coffee Breaks

Participant Support Costs

Current and Pending Support, Chapter II.C.2.h

Must now be uploaded as a separate PDF file for each individual identified on the proposal as senior personnel

The guidance has been revised to reflect that current and pending project support must include internal funds allocated toward specific projects.

Special Information and Supplementary Documentation, now specifies the format recommended to be used for letters of collaboration. Chapter II.C.2.j

Biographical sketches for Other Personnel and for Equipment proposals, should be uploaded as a single PDF file in the Other Supplementary Documents section of the proposal.

Proposal Submission, AOR must provide proposal certification

concurrently upon submission of the proposal. Chapter I.G.2 Withdrawal Function, Only an AOR can perform a withdrawal function on behalf of a proposing organization. Chapter IV.A

Dual Use Research of Concern, AOR provides new certification of DURC (more on this toward the end of presentation.) Chapter II.C.1.d, II.D.14, VI.B.5. respectively

Post-award Notification and Request instructions have been revised to specify that such communications must be signed and submitted by the AOR. Chapter III.C and D, respectively

Collaborative Proposals, reminder; both the lead and non-lead organizations are required to submit separate annual and final project reports. Chapter II.D.5.b

No cost extension requests submitted after the grant end date must include justification for why they were not submitted earlier. Chapter I.D.3.c(ii)(c)

Changes in Project Direction or Management, when a grant is being transferred into Harvard, if funding is requested to support a postdoctoral researcher, a mentoring plan must be provided and the PI must report on the mentoring activities in their NSF project reports. Chapter II.B.2.e

Existing Grants: The same procedures must be followed if a request to subaward, transfer or contract out part of an NSF award includes funding to support a postdoctoral researcher and the original proposal did not include a mentoring plan. Chapter 3

Technical Reporting Requirements, Chapter II.D ◦ Annual project reports due no later than 90 days prior to the end of

the current budget period. ◦ Final project reports and project outcomes reports for the general

public, should be submitted no later than 120 days following expiration of the grant.

Award Financial Reporting Requirements, Chapter III.E ◦ NSF will financially close awards 120 days after the award end date. ◦ Remember Harvard’s closeout policy

◦ 120 days after award end date final cost share notification documented and certified by the Authorized Organizational Representative for awards where there is mandatory cost sharing.

Administrative and Clerical Salaries & Wages Policy, articulates the direct charges of these costs in accordance with UG 2 CFR § 200.413. Chapter V.B.2 • (1) Administrative or clerical services are integral to

a project or activity; • (2) Individuals involved can be specifically identified

with the project or activity; • (3) Such costs are explicitly included in the

approved budget or have the prior written approval of the cognizant NSF Grants Officer; and

• (4) The costs are not also recovered as indirect costs.

Informal Resolution of Grant Administration Disputes, contains revised procedures to be followed when a grantee disagrees with or disputes a post-award decision made by an NSF Grants and Agreements Officer. Chapter VII.B.3

Items of Dispute ◦ cost disallowances pursuant to a Grants and Agreements

Officer’s decision (e.g., specific disallowances under an individual grant or as a result of an audit report);

◦ termination orders; and

◦ the final settlement amount under a termination

Dual Use Research of Concern (DURC), is an entirely new section and serves, in conjunction with coverage in the GPC & AAG, as NSF’s implementation of the US Government Policy for Institutional Oversight of Life Sciences Dual Use Research of Concern. Chapter II.D.14, Chapter VI.B.5, respectively

Definition: “Dual use research of concern” (DURC) is life sciences

research that, based on current understanding, can be reasonably anticipated to provide knowledge, information, products, or technologies that could be directly misapplied to pose a significant threat with broad potential consequences to public health and safety, agricultural crops and other plants, animals, the environment, materiel, or national security.

For More Information, see link http://www.phe.gov/s3/dualuse/pages/default.aspx

6.2.1 Agents & Toxins

a) Avian influenza virus (highly pathogenic)

b) Bacillus anthracis

c) Botulinum neurotoxin 6

d) Burkholderia mallei

e) Burkholderia pseudomallei

f) Ebola virus

g) Foot-and-mouth disease virus

h) Francisella tularensis

i) Marburg virus

j) Reconstructed 1918 Influenza virus

k) Rinderpest virus

l) Toxin-producing strains of Clostridium

botulinum

m) Variola major virus

n) Variola minor virus

o) Yersinia pestis

6.2.2 Categories of Experiments

a) Enhances the harmful consequences of the

agent or toxin

b) Disrupts immunity or the effectiveness of an

immunization against the agent or toxin without

clinical and/or agricultural justification

c) Confers to the agent or toxin resistance to

clinically and/or agriculturally useful prophylactic

or therapeutic interventions against that agent or

toxin or facilitates their ability to evade detection

methodologies

d) Increases the stability, transmissibility, or the

ability to disseminate the agent or toxin

e) Alters the host range or tropism of the agent or

toxin

f) Enhances the susceptibility of a host population

to the agent or toxin

g) Generates or reconstitutes an eradicated or

extinct agent or toxin listed in 6.2.1, above

Institutions must have a mechanism in place to evaluate potential DURC research and must establish an Institutional Review Entity (IRE) to assess and manage its risks.

If IRE determines an award has DURC potential, institution must notify funding agency within 30 days.

What does this mean for all us? No change to current proposal process. Continue to

check Yes for Biohazards in GMAS if proposal involves DURC.

Current COMS registration form asks questions to assist PIs in

identifying work that could meet the definition of DURC.

If DURC is identified by COMS, projects will be referred to separate institutional committee for additional review.

Office of Vice Provost for Research (OVPR), COMS, & Environmental Health & Safety Office have oversight of the policy and procedures.

Public Access to Copyrighted Material, is an entirely new section which provides information on NSF’s Public Access Policy. This policy also is referenced in Chapter VI.E.1 on publication and distribution of grant materials. Chapter VI.D.2.c

NSF requires PI’s to deposit all peer-reviewed journal articles, juried conference papers & data (either the final accepted version of the version of record) in the NSF Public Access Repository (NSF-PAR), hosted by Department of Energy (DOE.)

PI must report on accepted peer-reviewed paper or juried conference papers for journal publication within 12 months following initial publication.

Principal Investigators are responsible for meeting the public access requirements and ensure that all researchers involved on the award meet this requirement.

The NSF Public Access Policy only applies to new NSF awards resulting from NSF proposals submitted, or due, on or after January 25, 2016.

NSF allows an embargo or administrative delay for access up to 12 months from the date of publication for journal articles or juried conference papers in order to be in compliance.

Retains the current Data Management Plan requirements. The DMP should describe how the proposal will conform to NSF policy on the dissemination and sharing of research results (see AAG Chapter VI.D.4)

Requires to be reported in the annual and final reports with a persistent identifier

NSF PAPPG, NSF-16-1, Effective January 25, 2016 http://www.nsf.gov/pubs/policydocs/pappguide/nsf16001/

NSF Public Access https://www.nsf.gov/news/special_reports/public_access/index.jsp

NSF Public Access Plan: Today’s Data, Tomorrow’s Discoveries http://www.nsf.gov/pubs/2015/nsf15052/nsf15052.pdf

Public Access FAQ http://www.nsf.gov/pubs/2016/nsf16009/nsf16009.jsp?WT.mc_id=UNNSF_25&WT.mc-ev=click

Uniform Guidance

http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl

DURC Policy & Procedures http://www.phe.gov/s3/dualuse/pages/default.aspx