02-151 July 2002
V - Grantee Standards
This chapter discusses various grantee management standards with which
recipients are expected to comply. It consists of the following topics:
510 CONFLICT OF INTEREST POLICIES
520 FINANCIAL MANAGEMENT SYSTEMS STANDARDS
530 PROCUREMENT STANDARDS
540 PROPERTY MANAGEMENT STANDARDS
NSF requires prospective grantees to furnish, upon request
by DGA, basic organization and management information to assist
the NSF Grants Officer in assessing the prospective grantee's
financial and managerial responsibility. GPM
501 describes NSF requirements for the furnishing of organization
and management information.
NSF encourages the increased involvement of academic researchers
and educators with industry and private entrepreneurial ventures,
but recognizes that such interactions carry with them an increased
risk of conflict of interests. GPM 510 contains
NSF's policy on conflict of interest.
Circular A-110 prescribes three sets of standards for
academic and other non-profit recipients of Federal grants.
These govern financial management systems, procurement policies
and procedures and property management. GPM sections 520-540
implement the OMB standards, and extend their applicability
to all types of recipients of NSF grants, including commercial
501 Prospective Grantee Organization and Management Data
Each proposing organization that has not received an NSF grant within the
previous two years should be prepared to submit basic organization and management
information and certifications, when requested, to DGA. The information
required is contained in the NSF Prospective New Awardee Guide, available
electronically on the NSF website at: http://www.nsf.gov/pubsys/ods/getpub.cfm?pnag.
The information contained in this Guide will assist the organization in
preparing documents which the National Science Foundation requires to conduct
administrative and financial reviews of the organization. This Guide also
serves as a means of highlighting the accountability requirements associated
with Federal awards.
510 CONFLICT OF INTEREST POLICIES
NSF requires each grantee institution5 employing
more than fifty persons to maintain an appropriate written
and enforced policy on conflict of interest. Guidance for such
policies has been issued by university associations and scientific
An institutional conflict of interest policy should require
that each investigator disclose to a responsible representative
of the institution all significant financial interests of the
investigator (including those of the investigator's spouse
and dependent children) (i) that would reasonably appear to
be affected by the research or educational activities funded
or proposed for funding by NSF; or (ii) in entities whose financial
interests would reasonably appear to be affected by such activities.
The term "investigator" means the principal investigator, co-principal
investigators, and any other person at the institution who is responsible
for the design, conduct, or reporting of research or educational activities
funded or proposed for funding by NSF.
The term "significant financial interest" means anything of monetary value,
including, but not limited to, salary or other payments for services (e.g.,
consulting fees or honoraria); equity interest (e.g., stocks, stock options
or other ownership interests); and intellectual property rights (e.g., patents,
copyrights and royalties from such rights).
The term does not include:
salary, royalties or other remuneration from the applicant
any ownership interests in the institution, if the institution
is an applicant under the Small Business Innovation Research
Program or Small Business Technology Transfer Program;
income from seminars, lectures, or teaching engagements
sponsored by public or non-profit entities;
income from service on advisory committees or review panels
for public or nonprofit entities;
an equity interest that, when aggregated for the investigator
and the investigator's spouse and dependent children, meets
both of the following tests: does not exceed $10,000 in value
as determined through reference to public prices or other
reasonable measures of fair market value, and does not represent
more than a 5% ownership interest in any single entity; or
salary, royalties or other payments that, when aggregated
for the investigator and the investigator's spouse and dependent
children, are not expected to exceed $10,000 during the twelve
An institutional policy must ensure that investigators have
provided all required financial disclosures at the time the
proposal is submitted to NSF. It must also require that those
financial disclosures are updated during the period of the
award, either on an annual basis, or as new reportable significant
financial interests are obtained.
An institutional policy must designate one or more persons
to review financial disclosures, determine whether a conflict
of interest exists, and determine what conditions or restrictions,
if any, should be imposed by the institution to manage, reduce
or eliminate such conflict of interest. A conflict of interest
exists when the reviewer(s) reasonably determines that a significant
financial interest could directly and significantly affect
the design, conduct, or reporting of NSF-funded research or
Examples of conditions or restrictions that might be imposed to manage,
reduce or eliminate conflicts of interest include, but are not limited to:
public disclosure of significant financial interests;
monitoring of research by independent reviewers;
modification of the research plan;
disqualification from participation in the portion of the
NSF-funded research that would be affected by significant
divestiture of significant financial interests; or
severance of relationships that create conflicts.
If the reviewer(s) determines that imposing conditions or restrictions
would be either ineffective or inequitable, and that the potential negative
impacts that may arise from a significant financial interest are outweighed
by interests of scientific progress, technology transfer, or the public
health and welfare, then the reviewer(s) may allow the research to go forward
without imposing such conditions or restrictions.
The institutional policy must include adequate enforcement
mechanisms, and provide for sanctions where appropriate.
The institutional policy must include arrangements for keeping
NSF's Office of the General Counsel appropriately informed
if the institution finds that it is unable to satisfactorily
manage a conflict of interest. 7
Institutions must maintain records of all financial disclosures
and of all actions taken to resolve conflicts of interest for
at least three years beyond the termination or completion of
the grant to which they relate, or until the resolution of
any NSF action involving those records, whichever is longer.
520 FINANCIAL MANAGEMENT SYSTEMS STANDARDS
NSF grantees are required to have financial management systems which meet
the requirements of Section .21 of OMB Circular A-110.
530 PROCUREMENT STANDARDS
NSF grantees shall adhere to the requirements of Sections .41 through .48
of OMB Circular A-110 which prescribe standards for use by recipients in
establishing procedures for the procurement of supplies and other expendable
property, equipment, real property and other services with Federal funds.
540 PROPERTY MANAGEMENT STANDARDS
Sections .31 through .37 of OMB Circular A-110 prescribe standards
governing the management and disposition of property furnished
by the Federal government or whose cost was charged to a project
supported by a Federal grant.
In the rare instances where NSF grants might involve the acquisition
of real property and unless otherwise specified in the grant
document, the real property standards of OMB Circular A-110
are applicable to such NSF grants.
NSF implementation of the OMB standards on intellectual property
is contained in GPM 730, "Intellectual
Title to materials developed and supplies purchased under
an NSF grant will vest in the grantee.
Section .33(b) of OMB Circular A-110 contains a special category
of "exempt property." Under that provision, any Federal agency
which has statutory authority (such as NSF) may vest title
in an institution of higher education, hospital or other non-profit
organization without further obligation to the Federal Government
and under conditions the agency considers appropriate.
542 Title to Equipment
542.1 Title to Equipment - Non-Profit Organizations
Normal Situations. Unless otherwise specified in the grant,
title to equipment purchased or fabricated with NSF grant funds
by a college or university or other non-profit organization
will vest in the grantee organization upon acquisition. Such
equipment is considered "exempt property" (see GPM
541, "Background") and subject to the conditions of GPM
543, "Conditions for Acquisition and Use of Equipment."
Special Situations. In special situations the grant may require
that title to equipment purchased, acquired or fabricated by
the grantee with NSF funds pass directly to the government
from the vendor.
542.2 Title to Equipment - Commercial Organizations
Unless otherwise specified in the grant, title to equipment purchased or
fabricated with NSF grant funds by a small business or other commercial
firm will vest in the government. Such equipment will be acquired and used
in accordance with GPM 543, "Conditions for Acquisition
and Use of Equipment," and managed in accordance with GPM
545, "Property Management Standards When Title Retained by NSF."
543 Conditions for Acquisition and Use of Equipment
Grantee Assurance. The grantee will assure that for each purchase
of equipment, it is:
necessary for the research or activity supported by the
not otherwise reasonably available and accessible;
of the type normally charged as a direct cost to sponsored
acquired in accordance with organizational practice.
General Purpose Equipment. Expenditures for general purpose
equipment (see GPM 612.2c, "Definitions")
are unallowable unless the equipment is primarily or exclusively
used in the actual conduct of research.
Equipment Usage. The equipment must remain in use for the
specific project for which it was obtained in accordance with
OMB Circular A-110 Section .34c., unless the provision in Section
Equipment Sharing. The equipment must be shared on other projects
or programs in accordance with OMB Circular A-110 Section .34d.
Property Management Standards. The grantee shall maintain
a property management system which, at a minimum, meets the
requirements of OMB Circular A-110 Section .34f.
Competition. Grantees shall not use equipment acquired with
Federal funds to provide services to non-Federal outside organizations
for a fee that is less than private companies charge for equivalent
services, unless specifically authorized by statute, for as
long as the Federal Government retains an interest in the equipment.
Right to Transfer Title.
NSF may identify items of equipment having a unit acquisition
cost of $5,000 or more where NSF reserves the right to
transfer the title to the Federal government or to a third
party named by the Federal government.
In such cases where NSF elects to transfer the title,
disposition instructions will be issued no later than 120
calendar days after the expiration date of the NSF-supported
project for which it was acquired.
544 Principles Relating to the Use of NSF-Supported Research Instrumentation
The following principles on use of NSF-supported instrumentation and facilities
were adopted by the National Science Board:
The National Science Foundation seeks the maximum productive use of the
Nation's scientific instrumentation and research expertise. Ensuring that
the highest quality instrumentation, facilities, and services are available
to scientific users, both academic and industrial, is a key requirement,
as are harmonious relations and cooperation between industry and universities.
Private research and testing laboratories, as well as university, government,
and industrial laboratories, have a contribution to make.
The National Science Board recognizes that there may be circumstances where
NSF grantees use NSF-supported research instrumentation to provide services
in commerce for a fee, to an extent that such practice, (1) detracts from
the performance of their obligation under the grant, and/or (2) may have
a material and deleterious effect on the success of private companies engaged
in the provision of equivalent services. It is contrary to the NSF's intent
for grantees to use NSF-supported research instrumentation or facilities
to provide services for a fee in competition with private companies in a
manner that is prohibited by OMB Circular A-110.
Grantees should implement the above principles and related grant conditions
in a reasonable manner. Grantees are expected to provide fair and adequate
consideration of any complaints about use of instrumentation and facilities.
545 Property Management Standards When Title Retained by NSF
In the event that title to equipment or property is vested in the Federal
Government, such property shall be marked, tagged or segregated in such
a manner as to indicate clearly its ownership by the government. Unless
otherwise provided in the grant, such government property shall be used
only for the performance of the project. The grantee shall submit an annual
inventory report by NSF grant number of such property having an original
acquisition cost of $5,000 or more, to the NSF Property Administrator, Division
of Administrative Services (DAS). A physical inventory of Government-Owned
Equipment (GOE) shall be conducted every two years pursuant to Section .34f
of OMB Circular A-110. Upon expiration of the grant, the grantee shall report
the property to the Property Section for further agency utilization. (See GPM
546, "Excess Government Personal Property.")
546 Excess Government Personal Property
As a means of expanding the ability of grantees to accomplish
NSF objectives while conserving supply and equipment funds,
NSF will continue to sponsor the transfer of excess government
personal property to NSF grantees.
Excess government personal property includes all types of
personal equipment and materials (except consumable items such
as drugs, paint, etc.), new or used, owned by the Federal Government
and no longer needed by the holding agency, but having additional
useful life. Under regulations established by the General Services
Administration (GSA), the agency charged with operating this
program, excess government personal property may be reported
to, or requested from, GSA by other Federal agencies, including
NSF will sponsor the transfer of excess government personal
property to eligible organizations under one of the following
the use of the property significantly furthers an NSF
the property is such that it would have been procured
under the grant for which property is being requested if
additional grant funds had been available;
the property is used as part of the grant activity and
subsequently for research or science education purposes;
the property is classified by GSA as scientific or engineering
research equipment and has a unit acquisition cost of $1,000
or more. (See GPM 546.6, "Restrictions".)
Eligible organizations are NSF grantees that are public or private institutions
of higher education or non-profit organizations whose primary purpose is
the conduct of research or science education activities. State and municipal
governments, public health units, hospitals, profit-making firms and individual
PI/PDs are not eligible for excess government personal property under NSF
To receive information concerning the availability of property,
an eligible grantee should contact the Property Administrator,
DAS. The Foundation will place the grantee on the list of eligible
NSF grantees with the GSA and will provide the grantee with
the names, addresses and telephone numbers of GSA Area Utilization
Officers (AUO) located near the organization. The grantee should
contact an AUO to set up a "needs" list of the research equipment
required for the NSF grant. It is important that the NSF grant
number and the name of the PI/PD be communicated in all conversations
and correspondence regarding excess property acquisitions,
transfers and disposals.
When GSA information on available excess government personal
property is received, the grantee should ascertain whether
any items that are necessary to accomplish the supported project
Materials and equipment so selected should be inspected whenever
possible (see GPM 546.4, "Visiting
Holding Agency Facilities"), or the holding Federal agency
should be contacted by the grantee to verify the condition
of the items, because interpretation of condition codes varies
If the condition of the item is acceptable, the grantee should
freeze (reserve) items by calling the GSA office identified
in the catalog. The verbal reservation should then be followed
up by a letter. Items are usually allocated on a first come,
first served basis. Since GSA may have several freezes on a
piece of equipment, first come, first served is interpreted
as the first approved written request received by the GSA office.
However, preference will be given by GSA to agencies which
do not grant title to equipment.
The grantee should next prepare and submit to the Property
Administrator, DAS, a property request in six copies. A property
request consists of SF 122, Transfer Order Excess Personal
Property, and a separate written justification statement. The
justification will explain why the property is needed to reduce
the cost or enhance the performance under the specific grant
for which the property is requested.
The SF 122 should be signed by both the PI/PD and the Authorized
Organizational Representative. The following information should
also be provided on each SF 122:
name of grantee organization;
the statement "The above equipment is requested for use
by the grantee in support of research or education as outlined
in the grant"; and
the statement "Transfer is in accordance with the provisions
of 41 CFR §101.43." The transfer order should also identify
the automatic release date (from the GSA catalog) to preclude
loss of property before the transaction is processed.
The written justification should detail the scientific need
for the equipment as it relates to the particular grant under
which the equipment is to be used, and should cite the conditions
of this section as being binding upon the grantee, should the
property be acquired.
Upon receipt by NSF, the property request will be reviewed.
As confirmation of approval, the grantee will receive copies
of the SF 122 from NSF and, subsequently, from GSA. If the
request is disapproved, it will be returned to the grantee
with an appropriate explanation.
Upon receipt of the requested property, the grantee should
immediately return a copy of the SF 122 to NSF as evidence
of delivery. Cancellations by GSA, or nonreceipt within a reasonable
period of time, should also be reported to NSF after follow-up
inquiries have been made to GSA.
546.4 Visiting Holding Agency Facilities
Under current GSA regulations all non-Federal grantee representatives
wishing to visit holding agency facilities to screen or freeze
government excess personal property must receive prior certification
from GSA. This certification is not required for those grantees
who do their selecting from GSA catalogs and who freeze property
only via telephone requests.
The number of screeners on a grant should be limited to no
more than two persons. The primary screener should be the PI/PD.
However, if the PI/PD finds it impossible to screen, he/she
may designate, in writing, a substitute.
Normally, certification will be on a regional basis; however,
NSF will, under certain circumstances, sponsor grantee representatives
who need to make interregional visits in order to secure equipment
not readily available within their region. Each person who
plans to visit holding agency facilities must submit to NSF
a completed GSA Form 2946, Authorization Certificate to Select/Freeze
Excess Personal Property. This form may be obtained from the
Property Administrator, DAS. The GSA Regional Office in which
the grantee or organization is located will authorize all regional
certifications and serve as principal coordinator on interregional
requests. The authorization will be forwarded to the grantee
546.5 Dollar Limitation
To ensure equitable distribution of excess government personal property,
grantees may be authorized to acquire property under each NSF project grant
up to a total acquisition cost equal to the dollar value of that particular
grant. Any request for excess property which causes the total to exceed
the value of the grant will require additional justification beyond that
requested in GPM 546.3, "Procedures." A higher
percentage of excess property requested under a particular grant by a grantee
must be approved by an administrative level in NSF which is higher than
the Program Officer who normally administers the grant. NSF will give full
consideration to all factors in determining whether to approve transfers
of excess property above the dollar value of a given grant. Grantees are
therefore urged to be selective in their requests for excess government
personal property to limit quantities of each item where possible and to
avoid stockpiling items for future use.
NSF will sponsor the transfer of excess government personal
equipment to eligible organizations only under project grants.
As defined in the GSA regulations, "project grants" refers
to grants made for specific purposes with established termination
dates, e.g., grants made to specific organizations to perform
specific tasks within set time frames and costs. No excess
property may be acquired on behalf of conference grants, publication-support
grants or travel grants. In addition, on "summer-type training
grants," no property may be acquired after the training period
has terminated. Further, grantees should exercise careful judgment
on the appropriateness of requesting excess personal property
when only a short period of time exists between the date of
the property request and the completion or successful accomplishment
of the NSF-supported activity. GSA will consider items of personal
property as research equipment for transfer without reimbursement
to NSF for use by a grantee when the property requested has
a unit acquisition cost of $1,000 or more and is within Federal
Supply Classification Groups:
14 Guided Missiles;
43 Pumps and Compressors;
58 Communication, Detection and Coherent Radiation Equipment;
59 Electrical and Electronic Equipment Components;
66 Instruments and Laboratory Equipment;
67 Photographic Equipment;
70 General Purpose Automatic Data Processing Equipment,
Software, Supplies and Support Equipment; or
- 74 Office Machines and Visible Record Equipment.
Automatic data processing equipment must be acquired under the provisions
in 41 CFR §201.23.
- GSA will give consideration to the transfer without reimbursement
of items of excess property in other Federal supply classification
groups and items with a unit acquisition cost of less than $1,000,
when NSF certifies that the item requested is a component part
of or related to a piece of research equipment or is an otherwise
difficult to acquire item needed for scientific or engineering
research. Items of property determined by GSA to be common-use
or general purpose property, regardless of classification or
unit acquisition cost, shall not be transferred to a grantee
for the purpose of cannibalization, unless the granting agency
sends with the transfer request a supporting statement which
clearly indicates that disassembly of the requested item for
secondary use of its component parts, or for repair and maintenance
of a similar item, has greater potential benefit than utilization
of the item in its existing form and that a clear cost savings
to the government will result, subject to final determination
Excess government personal property is usually secured without cost. However,
the recipient grantee should specify the method of shipment and must pay
all costs of packing, transportation and subsequent installation, rehabilitation
and maintenance if required. Grant funds may be used to pay such costs.
Title to excess government personal property obtained by academic and other
non-profit grantees through NSF sponsorship remains with the government
until the property is delivered to the grantee organization. Upon delivery,
the grantee should forward to NSF a receipted SF 122 which clearly lists
the items of property actually obtained by the grantee. Unless NSF informs
the grantee to the contrary, when this SF 122 is received at NSF, title
to all property acquired will automatically pass to and be vested in the
grantee organization, subject to the understanding that the property will
be used for research or for science education purposes as long as it has
a useful life. At such time as the property is no longer useful for such
purposes, it may be disposed of in accordance with organizational practices,
but any proceeds therefrom shall be used by the grantee solely for research
or science education purposes. Under certain conditions, such as when highly
specialized equipment is involved, NSF may retain title to ex-cess property.
When such a condition exists, NSF will inform the grantee. Excess government
personal property may not be transferred to a foreign country without the
express written approval of DGA.
546.9 Accountability and Recordkeeping
While no particular type of classification of accounts or
inventory system is required, NSF expects that the responsible
officials of the grantee organization will exercise careful
stewardship of excess government personal property acquired
in support of projects undertaken with NSF's financial assistance.
In accordance with GPM 546.5, "Dollar
Limitation," relating to the dollar limitation on the amount
of excess government personal property provided by NSF, grantees
should maintain appropriate inventory procedures that will
enable them to identify those requests which require more extensive
administrative and scientific justification. In those cases
where title to excess government personal property remains
with the government, the grantee must maintain suitable records
to identify its location, description, utilization and value.
The use of excess government personal property under an NSF
grant is subject to in-spection and audit by representatives
of NSF at all reasonable times during the life of the grant
under which the property was acquired.
Further details may be obtained from the Property Administrator,
Division of Administrative Services, National Science Foundation,
4201 Wilson Boulevard, Arlington, VA 22230.
consistency with the DHHS conflict of interest policy, in lieu of "organization",
NSF is using the term "institution" which includes all categories of proposers. Back
On Preventing Conflicts of Interest in Government-Sponsored
Research at Universities, a Joint Statement of the Council
of the American Association of University Professors and
the American Council on Education (1964); Managing Externally
Funded Programs at Colleges and Universities, especially "Principle
X. Research Ethics and Conflicts", issued by the Council
on Government Relations (1989); Guidelines for Dealing
with Faculty Conflicts of Commitment and Conflicts of Interest
in Research, issued by the Association of American Medical
Colleges (1990); and Framework Document for Managing Financial
Conflicts of Interest, issued by the Association of American
Universities (1993). Back to Text
notifications of conflict of interest that cannot be
managed, reduced, or eliminated must be submitted electronically
via the NSF FastLane system. Back to