The Council on Governmental Relations (COGR), representing 200 major U.S. research institutions, submitted formal comments to the National Science Foundation (NSF) on the draft Proposal and Award Policies and Procedures Guide (PAPPG, NSF 23-1). COGR commends NSF for its technological advancements, such as implementing Research.gov and retiring Fastlane.gov, but raises concerns about duplicative systems like the proposed BAAM portal and the resulting administrative burden from multiple grants management systems. The organization urges NSF to consolidate functionalities within Research.gov and ensure seamless integration for any new tools to reduce the learning curve for research administrators.
COGR further addresses several policy changes, emphasizing the significant impact on administrative processes, particularly for smaller or less-resourced institutions. Notable concerns include new certification requirements for Senior Personnel, particularly where institutions cannot verify information for affiliates not employed by the applicant organization. COGR recommends clarifying roles and certification responsibilities for such personnel. The letter also highlights challenges with the transition to mandatory use of SciENcv for reporting Current and Pending Support, citing technical limitations and increased manual workload, and requests a 12-month delay in this requirement to allow for better adaptation. COGR also suggests that the requirement for submitting Current and Pending Support data be shifted to post-award stages, aligning with NIH practices, to reduce unnecessary burden. Additional requests include more resources and examples for new requirements, such as the Safe and Inclusive Field Research plans, and praise for policy updates that better accommodate evolving research methodologies, such as human subject research approvals. Overall, COGR’s comments are constructive, seeking to streamline administrative processes, reduce burden, and ensure that NSF policies support both compliance and research excellence.
