The document is a formal comment letter submitted by several major higher education associations in response to the National Science Foundation’s (NSF) proposed reporting requirements regarding findings of sexual harassment, other forms of harassment, or sexual assault among principal investigators (PIs) and co-principal investigators (co-PIs) at NSF awardee institutions. The signatory organizations express broad support for NSF’s goals of creating a safe, harassment-free academic and scientific environment but articulate significant concerns about aspects of the proposed reporting rules. Among the primary issues raised are the potential chilling effect and unintended consequences of requiring the reporting of administrative leave actions, which are often interim, non-punitive measures taken before any formal determination of wrongdoing. The organizations warn that such requirements could discourage institutions from using protective interim measures and may deter individuals from reporting incidents due to fear of negative professional or funding impacts.
The letter further requests clarifications and revisions to various components of the proposed policy, including the protection of confidentiality and privacy (particularly given potential exposure under the Freedom of Information Act), conformity of definitions (such as “other forms of harassment”) with institutional policies, and the need for consistency with federal and state privacy laws. The associations advocate for clearer reporting triggers, streamlined PI/co-PI substitution processes to allow research continuity, an appeals process synchronized with institutional mechanisms, a secure submission system for notifications, adequate timeframes for compliance, and explicit guidelines on responsibility for subrecipient reporting. The associations conclude by urging NSF to address these concerns with stakeholder input before implementation to ensure that new requirements both achieve their intent and avoid unintended harm to research communities and individuals.
