The Natural Science Collections Alliance has submitted comments on the National Science Foundation’s (NSF) draft Guidance on Financial Assistance (GFA), the document that would replace the Proposal and Award Policies and Procedures Guide (PAPPG 24-1) and govern how every NSF proposal is prepared, reviewed, and managed.
NSC Alliance supported what the redesign sets out to do — topic-based organization and plainer language, which will help the small museums, herbaria, and field stations that have no sponsored-projects office. The central objection was that the draft is written to align with the Office of Management and Budget’s (OMB) proposed revisions to the Uniform Guidance, a rule that is not final. Comments on that proposal closed on July 13, and OMB has not issued a final rule.
Of most immediate consequence for the collections community, the draft deletes the PAPPG provision that supplied the default rule on who holds legal rights to specimens collected under an NSF award, and moves specimens into property-management language that never says whether they are covered by it. As the comments put it: “Collections don’t work this way. Institutions proposing to transfer samples and the museum collections proposing to accept them for permanent curation must know who owns them and has the legal right to transfer them. All transfers must be binding beyond the term of the grant.”
The letter identified several further concerns, among them termination standards cross-referenced to a regulation without a fixed date, so a later amendment would enter NSF policy without NSF proposing it; a Summary of Changes stating that publication costs are disallowed while the guides themselves treat them as allowable; restricted-entity screening and certification requirements announced outside the draft and absent from its burden estimate; and two overlapping training requirements covering research security, set against different topic lists and different covered populations, that the draft never reconciles and that may or may not apply to recipient institutions other than universities.
NSC Alliance asked NSF to state plainly that specimens, samples, and other tangible research products are owned by the institution unless the award terms provide otherwise, to withhold every provision that rests on the proposed OMB rule, and to re-propose the affected sections for public comment once a final rule exists.