NSF PAPPG (23-1): Updates to Disclosure Types, Research Security, Scientific Integrity, and Safe and Inclusive Work Environments

Update, 2/1/2023 – NSF is hosting a Virtual Office Hour for researchers to learn more about the new NSF requirements for Safe and Inclusive Work Environments Plans.

1/30/2023 – NSF has released an updated Proposal and Award Policies and Procedures Guide (PAPPG), effective January 30, 2023. Summarized below are the updates in the new PAPPG regarding venture or capital financing as an added disclosure type, research security requirements, a scientific integrity reminder, and an update on requirements for safe and inclusive work environments for off-campus or off-site research.

Chapter IX.A, Venture or Other Capital Financing – Disclosures (C&P and ERA COI)

In accordance with the disclosure requirements outlined in the National Security Presidential Memorandum – 33 (NSPM-33), NSF has updated its definition of “significant financial interest” (SFI) to include venture or other capital financing.  NSF has indicated that additional clarification on this disclosure item is forthcoming.  In the meantime, Researchers receiving venture or other capital financing need to disclose this interest as part of their proposal Current & Pending (Other) Support information and in COI ERA.

What RAs need to know (Pre-Award and Post-Award):

  • At proposal time, prior to an award being received, and in project reports during the award period, PIs must review their C&P and disclose any venture or other capital financing they are currently receiving.

Chapter IX.C, Research Security – Obligation to Submit Updated C&Ps

This update includes the requirement for PIs and Co-PIs to specify whether new, active support has been received in their annual and final project reports and they must include an updated C&P document if there is any new activity. Additionally, there are new reporting requirements for the institution. If the institution discovers that a PI or a Co-PI failed to disclose current support or in-kind information, the institution must report the information within 30 calendar days via the Notification and Request Module in Research.gov.

What RAs need to know (Post-Award):

  • If an investigator or RA/Unit discover that something needs to be added/disclosed on an NSF C&P, the RA should immediately contact their AMT Fiscal Reporting GCO to coordinate a notification to NSF. ASU must submit an updated C&P within 30 days of becoming aware of the non-disclosure, so do not wait until the next report submission.

Chapter XI.M, Scientific Integrity

This section includes a reminder to the NSF community of the requirement to uphold the highest standards for scientific integrity. Reports or allegations regarding failures to adhere to the NSF Scientific Integrity principles should be sent to the NSF Office of Inspector General.

Chapter II.E.9, Safe and Inclusive Working Environments for Off-Campus or Off-Site Research – Confirm Project-Specific Plan is in Place

This section reiterates NSF policy (see PPAG Chapter XI.A.1.g.) to foster safe and harassment-free environments wherever science is conducted. NSF’s policy recognizes that a community effort is essential to eliminate sexual and other forms of harassment in science and to build inclusive scientific climates where people can learn, grow, and thrive.  For each proposal that proposes to conduct research off-campus or off-site, the AOR must certify that the organization has a project-specific plan in place that describes how the following types of behavior will be addressed for the proposed project:  a.  Abuse of any person, including, but not limited to, harassment, stalking, bullying, or hazing of any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; or b. Conduct that is unwelcome, offensive, indecent, obscene, or disorderly.   ASU Environmental Health & Safety has updated the ASU Field Research Safety Manual (January 2023) for this NSF policy.  Researchers should refer to this manual when preparing the required plan. In April, NSF will begin requiring that the plan be submitted at proposal time. In the meantime, the plan should be retained by the PI and disseminated to the research team before embarking on off-campus or off-site research.

What RAs need to know (Pre-Award):

  • NSF is adding a new Off-Campus/Off-Site check box on the Research.gov proposal Cover Sheet.  
  • When an ASU AOR (the assigned Proposal GCO) submits an NSF proposal between January 30th and mid-April 2023, if the off-campus/off-site box is checked on the cover sheet then the AOR will need to certify that there is a project-specific plan in place to ensure a safe and inclusive working environment while off-campus/off-site.
    • In order to certify, the Proposal GCO will ask the RA for confirmation that a plan is in place for safe and inclusive research for any proposed off-campus or off-site research.
    • For now (until mid-April), the plan should not be submitted to NSF, but the PI should retain the plan on their end. It is recommended that the RA have the PI confirm that a plan is in place, and the RA should then save that written confirmation at the unit level.


  • NSF: National Science Foundation
  • C&P: Current & Pending Support
  • ERA: Enterprise Research Administration
  • COI: Conflict of Interest
  • RAs: Research Advancement Administrators
  • PI: Principal Investigator
  • Co-PI: Co-Principal Investigator
  • AMT: ASU Award Management Team
  • AOR: Authorized Organizational Representative
  • GCO: ASU Grant + Contract Officer