The Council on Governmental Relations (COGR), representing over 200 research universities and institutes, provided detailed feedback to the National Science Foundation (NSF) on the proposed revisions to the Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 24-1). COGR commends NSF’s efforts toward responsiveness, transparency, and stakeholder engagement, but outlines several areas where clarification and revision are needed to ensure policies are clear, practical, and align with legislative intent and institutional realities.
Key concerns include the definitions of “Foreign Country of Concern” and “Malign Foreign Talent Recruitment Program” (MFTRP), where COGR requests precise language and accessible resources to facilitate compliance and certification accuracy. They also highlight the need for consolidation of requirements, such as foreign gifts and contracts disclosures, to avoid confusion created by dispersed references in the document. COGR urges NSF to harmonize electronic submission systems to minimize administrative burden on institutions, aligning with existing processes at other federal agencies where possible. They also recommend deferring the collection of Current and Pending Support (CPS) until after selection for funding, as only a minority of proposals are funded. Additional comments address necessary clarifications in conflict of interest policies, scientific integrity definitions, and mentoring plan thresholds, encouraging NSF to engage the research community for best practices and clearer implementation. Throughout, COGR emphasizes the necessity for unambiguous standards, streamlined processes, and dialogue to support both national research security objectives and the practical needs of research institutions.
