The Council on Governmental Relations (COGR), representing 187 research universities and affiliated institutions, provided feedback to the National Science Foundation (NSF) concerning the draft revision of the NSF Proposal and Award Policies and Procedures Guide (PAPPG). COGR expresses appreciation for the NSF’s ongoing collaboration but raises significant concerns regarding proposed changes to the reporting requirements for Current and Pending Support. Specifically, COGR notes that expanding these requirements to include activities outside an investigator’s institutional appointment, such as outside consulting and in-kind support, marks a substantial shift from past practices, introducing sensitive data and potential compliance burdens. The organization asserts that assessing over-commitment should remain an institutional responsibility in line with existing federal guidance, and emphasizing the need for alignment with NIH policies to mitigate administrative burdens.
COGR also addresses potential complications resulting from the new certification demands placed on Authorized Organizational Representatives (AORs), advocating for clarity in delineating institutional versus individual investigator responsibilities for collecting and certifying data. The council commends recent NSF measures, such as the inclusion of data curation costs as allowable expenses and the simplification of institutional proposal certifications. Nevertheless, COGR underscores the need for stakeholder engagement to clarify reporting obligations and urges the NSF to consider postponing implementation timelines, harmonizing requirements with other agencies, and exploring alternatives to minimize undue burden. The letter concludes with an offer for continued dialogue and the anticipation of further minor recommendations for future revisions.
