Summary of Changes to the PAPPG (NSF 23-1)

Overall Document

• Editorial changes have been made throughout to either clarify or enhance the intended meaning of a sentence or section. 
• References to Research.gov have been incorporated throughout, as part of the final transition from FastLane to Research.gov for proposal preparation and submission.
• Website and document references have been updated to reflect current information. 
• Updates have been made to ensure consistency with data contained in NSF systems or guidance located and terminology used in other NSF or Federal policy documents.

By-Chapter Changes

Chapter I: Pre-Submission Information

• Chapters I.A, NSF Proposal Preparation and Submission and I.C, Categories of Funding Opportunities, have been updated to address NSF’s use of the Broad Agency Announcement (BAA) and the associated Broad Agency Announcement Management System (BAAM).
• Chapter I.D, Types of Submissions, includes new coverage on the use of concept outlines and the required use of the Program Suitability and Proposal Concept Tool (ProSPCT) for submission. Additional changes on the use of concept outlines and the use of ProSPCT for specific proposal types is available in Chapter II.E.
• Chapter I.E, Who May Submit Proposals, was revised to clarify eligibility requirements of For-Profit Organizations, and State and local governments. New coverage on the eligibility of Tribal Governments also has been included.
• Chapter I.E.3, Unaffiliated Individuals, has been modified to specify that individuals submitting proposals in response to postdoctoral fellowships are not considered unaffiliated individuals.
• Chapter I.G.2, Requirements Relating to Unique Entity Identifier (UEI) and Registration in the System for Award Management (SAM), has been modified to clarify that subrecipients named in a proposal must obtain a UEI and register in Research.gov, however, they do not need to be registered in SAM.

Chapter II: Proposal Preparation Instructions

• Chapter II.B, NSF Disclosure Requirements, incorporates a new section describing specific NSF disclosures, the sections of the PAPPG they apply to and the consequences for violating these requirements.
• Chapter II.D.1.d, Proposal Certifications Provided by the Organization, was modified to include a new certification by the AOR relating to the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 requiring that senior personnel are made aware of the certification requirements required by the Act. A second new certification regarding Responsible and Ethical Conduct of Research (RECR) was added for proposals submitted on or after July 31, 2023. The certification replaces the existing RECR certification and expands the training requirement to faculty and other senior personnel and mandates that the training cover mentor training and mentorship. A third new certification requires the AOR to certify that any organization proposing to conduct research off-campus or off-site has a plan in place for this proposal regarding safe and inclusive working environments.
• Chapter II.D.1.e, Certification Requirement for Senior Personnel Specified in the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021, is a new certification requiring senior personnel to certify that the information provided in their Biographical Sketch and Current and Pending Support documents are accurate, current, and complete. This certification will be included in both SciENcv and the NSF fillable format for proposals submitted or due on or after January 30, 2023.
• Chapter II.D.2, Sections of the Proposal, identifies a new checkbox on the NSF Cover Sheet: Off-Campus or Off-Site Research.
• Chapter II.D.2.f(vi)(e), Subawards, has been clarified regarding the need to obtain prior NSF approval if a subaward organization has changed after an award has been made.
• Chapter II.D.2.f(viii), Indirect Costs, has been revised to provide greater clarity for organizations that do not have a current negotiated indirect cost rate agreement and wish to request indirect cost rate recovery above the 10% de minimus rate.
• Chapter II.D.2.h(i), Biographical Sketch(es), has been revised to increase standardization with the Common Disclosure Form for the Biographical Sketch that has been developed in compliance with NSPM-33 Implementation Guidance. NSF has made every effort to mirror the Common Form. Due to timing disparities between the issuance of the Common Form and the PAPPG, however, it is possible that variances may occur. This section also has been revised to require the use of SciENcv for the preparation of this document effective in October 2023.
• Chapter II.D.2.h(ii), Current and Pending (Other) Support, has been revised to increase standardization with the Common Form for Current and Pending (Other) Support that has been developed in compliance with NSPM-33 Implementation Guidance. NSF has made every effort to mirror the Common Form. Due to timing disparities between the issuance of the Common Form and the PAPPG, however, it is possible that variances may occur. This section also has been revised to require the use of SciENcv for the preparation of this document effective in October 2023. Also, in accordance with NSPM-33 Implementation Guidance, NSF program officers will request updated Current and Pending (Other) Support prior to making a funding recommendation.
• Chapter II.E.5, Proposals Involving Human Subjects, provides greater flexibility in the form that a determination notice must take. The section also clarifies that a PI may conduct preliminary work that does not involve human subjects while the protocol is being developed or under review, consistent with organizational guidelines.
• Chapter II.E.6, Potential Life Sciences Dual Use Research of Concern (DURC), has been updated with new requirements for situations where a decision has been made to fund a proposal and use of a select agent is identified. Additional language also has been added to specify that NSF will not fund research that involves the creation, transfer, or use of enhanced potential pandemic pathogens except under special circumstances.
• Chapter II.E.9, Safe and Inclusive Working Environments for Off-Campus or Off-Site Research, describes the new requirement for the AOR to certify that an organization has a plan in place for safe and inclusive research for any proposal that proposes to conduct off-campus or off-site research. This section also provides considerations for plan development, communication, and dissemination.
• Chapter II.F, Other Types of Proposals, , includes the requirement to submit a Concept Outline for the following proposal types: Planning, Rapid Response Research (RAPID), Early-concept Grants for Exploratory Research (EAGER), and Research Advanced by Interdisciplinary Science and Engineering (RAISE) prior to the submission of a full proposal. The coverage also identifies the Program Suitability and Proposal Concept Tool (ProSPCT) as an option for use in submission of the Concept Outline.
• Chapter II.F.5, Grant Opportunities for Academic Liaison with Industry (GOALI) Proposal, has been modified to permit non-SBIR small businesses to receive funding and includes specific guidance on the eligibility of small business to receive funding under a GOALI award.

Chapter VII: Award Administration

• Chapter VII.D, Technical Reporting Requirements, has been clarified to indicate when NSF required reports become overdue.

Chapter IX: Recipient Standards

• Chapter IX.B.1, Responsible and Ethical Conduct of Research (RECR), has been amended to apply the requirement to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel. The revised section also identifies that the content of the training must address mentor training and mentorship.
• Chapter IX.C, Research Security, has been added as a new section on NSF policy on research security including the overall goals of NSF’s research security initiatives, organizational requirements for post-award disclosure of current support and in-kind contribution information, and when PIs and co-PIs must update current support in annual and final project reports.

Chapter X: Allowability of Costs

• Chapter X.C.1, Build America, Buy America, and Made in America Statutes, incorporates information about the Build America, Buy America provisions of the Infrastructure Investment and Jobs Act.
• Chapter X.D.2, NSF Cognizant Organizations, includes additional information for when NSF is the cognizant agency for indirect costs.

Chapter XI: Other Post Award Requirements and Considerations

• Chapter XI.B.1, Protection of Living Organisms, includes clarifying language for when IRB approval is required for awards involving human subjects.
• Chapter XI.B.5, Potential Life Sciences Dual Use Research of Concern (DURC), includes additional information for recipients on DURC policy requirements.
• Chapter XI.J, Historic Properties, provides clarifying language on research on historic properties as required by the National Historic Preservation Act (NHPA).
• Chapter XI.K, Environmental Considerations, incorporates language on anticipated and unanticipated environmental impacts.
• Chapter XI.M, Scientific Integrity, includes a new section on NSF scientific integrity for organizations and individuals, as well as identifying appropriate NSF offices to report allegations regarding failures to adhere to scientific integrity principles. The new section also reminds organizations and individuals that the principles and requirements that support scientific integrity are integral to multiple topics specified in the PAPPG.