News From the National Science Foundation Office of Inspector General


The Office of Inspector General will issue this newsletter periodically to report the results of recent audits, investigations, and other work related to NSF's programs. Our intent is to help members of the research community become more aware of the types of problems that may be found during an audit or investigation, as well as measures that may be taken to prevent them.



In This Issue





:: NSF Clarifies Policy On Extra Compensation Payments Above Base Salary ::

Prompted by an OIG audit recommendation, NSF clarified its policies pertaining to extra compensation (i.e., compensation above their normal base salaries paid to university researchers for NSF funded research). Although NSF's policy manual requires that extra compensation be provided for in the program solicitation and approved by NSF, the award letter omits these conditions. During a recent audit OIG found that one campus in a major university system had improperly charged NSF $189,114 in excess compensation. Four other campuses in the same system also claimed excess compensation resulting in a total of $484,000 in charges to NSF. Moreover, during a five-year period, these five campuses may have charged as much as $2.4 million in extra compensation to NSF grants. OIG recommended that NSF make the policies in its grant policy manual consistent with the grant general conditions that appear in the award letter. As a result, NSF decided to adopt OMB Circular A-21 cost principles pertaining to extra compensation as policy. The circular requires agency approval of extra compensation payments and sets parameters for specific situations that qualify.



:: Evaluation of Math and Science Partnership Projects Can Be Improved ::
OIG auditors reviewed the evaluation plans for nine Math and Science Partnership projects to determine whether the individual awardees had effective processes in place to evaluate their results. The auditors found that five of the nine partnerships had effective evaluation plans, and for the four that were missing key evaluation elements, steps could be taken to address these issues. NSF also indicated it planned to evaluate the overall MSP program, although the auditors found that NSF had not yet formalized its plans. The agency has now issued a request for proposals for an evaluation of the overall MSP program. The OIG believes NSF's proposed actions will address the issues identified in the audit.  In fiscal years 2002 and 2003, the MSP program awarded a total of $436.6 million for 35 comprehensive and targeted MSP awards that will extend over a five-year period, and it expects to fund an additional $91 million for 12 new projects in FY 2004.



:: NSF Improves Monitoring of Human Subjects Research ::
NSF changed its Grant Proposal Guide to strengthen its monitoring of compliance with regulations for the protection of human subjects after OIG investigations uncovered several weaknesses. NSF has revised the Guide to state: All projects involving human subjects must either (1) have approval from the organization's Institutional Review Board (IRB) before issuance of an NSF award or, (2) must affirm that the IRB or an appropriate knowledgeable authority previously designated by the organization (not the Principal Investigator) has declared the research exempt from IRB review. The new language presents the requirements more clearly and emphasizes the need for someone other than the Principal Investigator to declare the relevant exemptions. In addition, two directorates have taken steps to improve NSF's internal review of human subjects compliance in response to specific OIG investigations.  

Before NSF can make an award for a project involving human subjects, an institution must either have approval from its institutional review board (IRB) or declare an exemption from the government-wide regulation. Although NSF currently relies on grant applicants to identify the involvement of human subjects in proposals, past investigations have shown that this does not always occur. Moreover OIG found that some NSF divisions neglect to indicate on agency forms that a project involves a human subject. As a result, NSF's ability to monitor the involvement of human subjects was compromised in many instances.




To report a possible instance of fraud, waste, or abuse pertaining to NSF programs or awards, please call our hotline at 1-800-428-2189 or contact us at For more information about OIG activities, visit our website:

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