The Council on Governmental Relations (COGR), representing 190 research universities and affiliated institutions, submitted comprehensive comments to the National Science Foundation (NSF) regarding the proposed updates in the Proposal & Award Policies & Procedures Guide (PAPPG), specifically NSF 22-1. COGR’s commentary focuses on achieving greater clarity and harmonization in policy language, aligning NSF requirements with recently enacted federal statutes, and minimizing administrative burdens for research institutions.
Key recommendations include clarifying terminology concerning foreign organizations and direct funding, and harmonizing NSF's requirements for disclosing current and pending research support with those mandated by the National Defense Authorization Act for Fiscal Year 2021. COGR underscores the importance of consistent definitions across federal agencies to promote compliance and transparency. Additionally, COGR suggests refining the criteria around consulting activities, in-kind support, and reporting of professional appointments to reduce confusion and align with established practices, such as those of the NIH. The organization also addresses the need for clearer guidance on meeting organizers’ harassment policies and endorses the increased use of fixed amount awards to lessen administrative burdens. Finally, COGR acknowledges and welcomes the new opportunity for Career-Life Balance Supplemental Funding, recognizing its benefit for higher education institutions. Overall, COGR’s response aims to foster effective implementation of federal requirements while safeguarding the research community’s capacity for compliance and performance.
