Revised FAQs on NSF PAPPG, Update on Venture or Other Capital Financing – Disclosures

4/26/2023 – The National Science Foundation (NSF) has issued revised  Frequently Asked Questions (FAQs) On Proposal Preparation and Award Administration Related to the NSF Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 23-1).

The updated FAQs include clarifications on many topics, including the following:

  • COLLABORATIVE PROPOSALS and Off-Campus/Off-Site Research
    • The lead organization must check the Off-Campus or Off-Site Research box on the cover sheet if either the lead or any non-lead organization proposes to conduct research off-campus or off-site.
      • Only the lead organization must check the box on the cover sheet if either the lead or any non-lead organization proposes to conduct research off-campus or off-site.
    • In situations where a program solicitation requires submission of the safe and inclusive working environment plan at the time of proposal, consistent with how postdoctoral mentoring and data management plans are handled, the plan should be uploaded by the lead organization.
    • The safe and inclusive working environment requirement to have a plan in place as stated in PAPPG Chapter II.E.9 applies to all lead and non-lead proposals that propose to conduct research off-campus or off-site. If more than one collaborating organization proposes to conduct research off-campus or off-site, one joint plan must be developed, unless otherwise specified in a program solicitation.
  • CONFLICT OF INTEREST –
    • What are NSF’s expectations for disclosure of a significant financial interest in instances where investigators may have an equity stake in a company, but do not know who the investors in the company are?
      • Investigators must disclose their equity stake.  If a venture capital firm does not provide investment information, investigators must obtain a letter* from the venture capital firm stating that the firm does not disclose who or what they have invested in, or who the other investors are.

*ASU Comment: In addition to the guidance on PAPPG Chapter IX.A provided in a previous news post on PAPPG 23-1 requirements, please note that these letters from venture capital firms should be uploaded by the investigator in the ERA COI module to support the COI disclosure, when applicable. This does not impact the proposal submission and is a separate process. Please contact ORIA at [email protected] with additional questions.