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NSF 14-1 January 2014

AAG Summary of Changes

Chapter II.B.2.d(ii), Long-Term Absence of the PI/PD or co-PI/co-PD, has been revised to describe the steps that should occur in the event that the PI/PD or co-PI/co-PD will be temporarily working for NSF as an IPA (Intergovernmental Personnel Act employee) or VSEE (Visiting Scientist, Engineer or Educator).

Chapter II.E, Annual and Final Project Reports, has been amended to emphasize that annual and final project reports are not cumulative and should be written specifically for the most recently completed budget period, as well as add that reports should be submitted electronically in

Chapter III.C.2, Payment Policies, has been modified to state that, when completing a payment request, awardees must certify that all disbursements have been made or will be made within 3 days of the receipt of the payment for the purposes and conditions of the awards.

Chapter III.C.6, Grantee EFT Update, has been updated to make known that SAM will become the NSF system of record for organizational financial information as of October 1, 2014. Once a grant is awarded, failure to maintain current and complete financial information within SAM could prevent the awardee from receiving funds.

Chapter III.D.1, Final Unobligated Balance, has been revised to state that, based on final payment amounts submitted through the Award Cash Management Service (ACM$), the final unobligated balance will be computed by NSF and deobligated from the award amount.

Chapter III.D.4, Program Income, has been supplemented with information on program income reporting requirements.

Chapter III.E, Final Disbursement Reporting, has been modified to clarify procedures under ACM$. For any award listed on the ACM$ Payments screen, the awardee will enter the final payment amount in the Payment Amount Requested column. If final disbursements change by $1.00 or more from the amount at the award financial closeout, the awardee should submit an Adjustment to a Financially Closed Award through the ACM$ payment process. Awardees have the option of using ACM$ to designate awards for financial closeout prior to the scheduled close out date.

Chapter IV.A.6, Conflict of Interest Policies, has been updated to add language regarding awardee notification to NSF of situations where research will proceed without the imposition of conditions or restrictions when a Conflict of Interest exists.

Chapter V.B.8.a, Participant Support Costs, General, has been revised to add that, for colleges and universities, participant support costs may include fellowships, scholarships, and other forms of student aid; and to emphasize that indirect costs are not allowed on participant support costs.

Chapter V.C.3, Rental or Lease of Facilities or Special Purpose Equipment, has been updated to add that rental costs of facilities owned by the awardee or under common control by related parties may be limited to the actual cost of ownership as opposed to fair market rental value.

Chapter V.C.4, Relocation Costs, has been updated to add guidance regarding inclusion of visa costs.

Chapter V.D.1(ii)(b), Provisional Rate, has been added to define a provisional rate as a temporary rate established to permit funding and reporting of costs pending establishment of a final rate.

Chapter VI.A.1, Non-Discrimination Statutes, has been amended to include that Executive Order 13166 requires government agencies to take steps to provide meaningful access to its programs and activities to members of the public who are limited in their English proficiency (LEP).

Chapter VI.L, Environmental Compliance, has been added to affirm that, prior to making an award, NSF considers the anticipated environmental impacts associated with the activities described in the proposal. If, while performing the work required by the award, the awardee learns of any potential or actual unanticipated environmental impacts, the awardee shall immediately notify NSF of such impacts and cease all work anticipated to cause or causing such impacts until NSF has had a reasonable opportunity to assess the situation, comply with all relevant environmental laws, and provide further direction to the awardee.

Clarifications and Other Changes to the AAG

Exhibit I-1, Statutes, Executive Orders and Other Directives, has been updated to include other relevant statutes.

Chapter III.B, Definitions, has been modified to update definitions of Award Cash Management Service (ACM$) and Federal Financial Report History.

Chapter III.C, Payment Requirements, has been revised throughout to acknowledge implementation of ACM$.

Chapter III.C.4, Special Payment Awardees, has been amended to clarify that the cognizant NSF Grants and Agreements Officer is responsible for establishing the documentation requirements for special payment awardees.

Chapter III.E, Award Financial Reporting Requirements, has been changed to omit the section on Quarterly Disbursement Reporting – Federal Financial Report (FFR), submission of which is no longer necessary given the implementation of ACM$.

Chapter V.A, Basic Considerations, has been updated to clarify the awardee’s responsibilities for ensuring that all costs charged to NSF awards meet the requirements of the applicable cost principles, grant general terms and conditions, any other specific requirements of both the award notice and the applicable program solicitation, and their own internal policies and procedures. This part also has been updated to add language on establishing an advance agreement or understanding about charging an item of direct cost that might otherwise subsequently be disputed.

Chapter V.A.2.c, Post-Expiration Costs, has been revised to provide an example of a valid commitment made on or before the expiration date of the grant that may be liquidated subsequent to the expiration date. This part also explains that the grantee should not purchase items of equipment, computing devices, or restock materials and supplies in anticipation of grant expiration where there is little or no time left for such items to be utilized in the actual conduct of the research.

Chapter V.A.3.b, NSF Prior Approval Policy, has been amended to add that awardees should ensure that all costs are fully disclosed in the budget justification. Costs not specifically budgeted in an NSF award may be allowable provided that prior approval is not required, the costs are incurred consistently with the applicable cost principles and the grantee’s written policies and procedures, and proper documentation to explain and support the charge to the NSF award is maintained.

Chapter V.B.1.b, Fringe Benefits, has been updated to add that fringe benefits that are not accrued but are charged as direct costs and incurred under “pay as you go plans” may be subject to reasonableness determination where the benefits are earned under other work and charged to the last activity the employee was working on. This is of particular concern for large lump sum payments for leave, disability, pregnancy, or other employee fringe benefits.

Chapter V.B.6.a, Consultant Services, has been augmented to clarify that all consultant costs should be fully disclosed and explained in the accompanying budget justification.

Chapter V.C.4, Relocation Costs, has been supplemented to explain that relocation costs charged to an NSF award that were not included in the approved budget must be fully documented in the awardee’s records and be in accordance with the awardee’s established policies and procedures.

Chapter V.C.5.k, Meetings and Conferences, has been updated to add that gifts, souvenirs, t-shirts and other memorabilia are not typically considered allowable costs to an NSF grant.

Chapter V.D, Indirect Costs, has been revised to clarify that, where awardees receive limited NSF funding, the Foundation may elect to set award specific rates as opposed to a formal annual negotiated indirect cost rate agreement.

Chapter V.D.1.(ii)(a), Maximum Provisional Rate, has been modified to explain that a maximum provisional rate is both a billing and a ceiling rate. In no event may the grantee recover indirect costs in excess of the maximum provisional rate regardless of actual cost.

Chapter V.D.2, NSF Cognizant Organizations, has been updated to insert information on indirect cost rate proposal submission requirements.

Chapter VI.G.4, Passports and Visas, has been updated to include guidance on the allowability of visa costs. Restrictions concerning directly charging visa costs to an NSF award are described in GPG II.C.2.g.(vi)(f).