NSF 22-1 October 4, 2021
Chapter VII - Grant Administration

A. Monitoring Project Performance

1. Grantee Responsibilities

a. The grantee has full responsibility for the conduct of the project or activity supported under an NSF grant and for the results achieved. The grantee should monitor the performance of the project to assure adherence to performance goals, time schedules or other requirements as appropriate to the project or the terms and conditions of the grant. In order to carry out these responsibilities, each grantee organization shall agree to comply with the applicable Federal requirements for grants and to the prudent management of all expenditures and actions affecting the grant. Documentation for each expenditure or action affecting the grant shall reflect appropriate organizational reviews or approvals, which should be made in advance of the action. Organizational reviews are intended to help assure that expenditures are allowable, necessary, and reasonable for the conduct of the project, and that the proposed action:

(i) is consistent with grant terms and conditions;

(ii) is consistent with NSF and grantee policies;

(iii) represents effective utilization of resources; and

(iv) does not constitute changes in objectives or scope.

b. Notwithstanding these responsibilities, NSF continues to encourage communication between NSF Program Officers and PIs on the progress of projects supported by NSF as well as on project changes.

c. NSF, through authorized representatives, has the right, at all reasonable times, to make site visits to review project accomplishments, grantee management control systems and administration and management of the grant and to provide technical assistance as may be required. If any site visit is made by the Foundation on the premises of the grantee or a subrecipient under a grant, the grantee shall provide and shall require its subrecipients to provide all reasonable facilities and assistance for the safety and convenience of the NSF representatives.

2. Grantee Notifications to NSF

The following is a listing of grantee notifications to NSF, including a reference to where additional guidance is provided. Except where noted below, all notifications must be submitted via use of NSF’s electronic systems. With the exception of significant changes in methods or procedures and significant changes, delays or events of unusual interest, all notifications must be signed and submitted by the AOR.

a. Grantee-Approved No-Cost Extension – See Chapter VI.D.3.c(i).

b. Significant Changes in Methods or Procedures (Other than Changes in Objectives or Scope) – See Chapter VII.B.1.b.

c. Significant Changes, Delays or Events of Unusual Interest (Other than Changes in Objectives or Scope) – See Chapter VII.B.1.c.

d. Annual and Final Cost Share Notification by Recipient – See Chapter VII.C.3.

e. Conflicts of Interest that cannot be satisfactorily managed, reduced or eliminated and research that proceeds without the imposition of conditions or restrictions when a conflict of interest exists – See Chapter IX.A.

f. Finding/Determination that a PI or co-PI has been found to have violated awardee policies or codes of conduct, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault - See Chapter XI.A.1. This notification must be submitted through use of NSF's Office of Diversity and Inclusion website; or

g. Placement by the grantee of a PI or co-PI on administrative leave or the imposition of any administrative action on the PI or any co-PI by the awardee relating to any finding/determination or an investigation of an alleged violation of awardee policies or codes of conduct, statutes, regulations, or executive orders relating to sexual harassment, other forms of harassment, or sexual assault. See Chapter XI.A.1. This notification must be submitted through use of NSF's Office of Diversity and Inclusion website.

Certain actions require prior approval from NSF. Guidance regarding prior approval requirements is covered in Chapter X.A.3, and the NSF column of the Research Terms and Conditions, Appendix A.

B. Changes in Project Direction or Management

1. Changes in Objectives, Scope or Methods/Procedures

a. Changes in Objectives or Scope

The objectives or scope of the project may not be changed without prior NSF approval. Such change requests must be signed and submitted by the AOR via use of NSF’s electronic systems. If approved by NSF, the Grants and Agreements Officer will amend the grant. Prior written NSF approval also is required for changes to the Facilities, Equipment and Other Resources section of the approved proposal that would constitute changes in objectives or scope (see Chapter VII.C.2.i for further information).

b. Significant Changes in Methods or Procedures

NSF believes that the PI and co-PI, operating within the established policies of the grantee organization, should feel free to pursue interesting and important leads that may arise during the conduct of a research (or other grant-supported) project or to adopt an alternative approach which appears to be a more promising means of achieving the objectives of the project. Significant changes in methods or procedures should be reported to appropriate grantee official(s). The PI also must notify NSF via use of NSF's electronic systems.

c. Significant Changes, Delays or Events of Unusual Interest

In the event there are problems, delays, or adverse conditions that will materially impact the ability to attain the objectives of the project or to meet such time schedules as may have been proposed, the PI should notify the appropriate grantee official(s). The PI also must notify NSF via use of NSF's electronic systems.

NSF should be informed of any events of unusual interest that occur during the course of the project. Reports, communications, or photographs should be submitted via the interim report capability in Research.gov.

2. Changes in PI, co-PI or Person-Months Devoted to the Project at the Initiation of the Grantee Organization

The NSF decision to support a proposed project is based to a considerable extent upon its evaluation of the proposed PI and any identified co-PI's knowledge of the field of study and his/her capabilities to conduct the project in an efficient and productive manner. This is reflected in the NSF merit review criteria (see Chapter III). The named PI (and co-PI) should be continuously responsible for the conduct of the project and be closely involved with the effort.

If the grantee determines that there is a need for the addition of a new co-PI, or the current PI or co-PI plans to, or becomes aware that he/she will: (i) devote substantially less effort to the project than anticipated in the approved proposal; (ii) sever his/her connection with the grantee organization; or (iii) otherwise relinquish active direction of the project, he/she shall advise the appropriate official at the grantee organization, who shall initiate action appropriate to the situation under the guidelines that follow.

a. Long-Term Disengagement of PI or co-PI

(i) In the event the PI or co-PI will be disengaged from the project for a period greater than three months (e.g., sabbatical leave) but intends to return, arrangements for oversight of the project must be signed and submitted by the AOR via use of NSF's electronic systems. This request must be submitted at least 30 days before departure or as soon as practicable after the prospective disengagement is known.⁶⁰ The cognizant NSF Program Officer will provide written approval to the grantee if the arrangements are satisfactory, but no formal amendment to the grant will be made. If the arrangements are not satisfactory to NSF, the grant may be terminated as prescribed in Chapter XII.A.

(ii) In the event the PI or co-PI will temporarily be working for NSF as an IPA (Intergovernmental Personnel Act employee) or VSEE (Visiting Scientist, Engineer or Educator), the appropriate officials at the grantee organization must contact the cognizant NSF Program Officer for procedural guidance regarding any existing grants or pending proposals of the PI or co-PI.

b. Changes in Person-Months Devoted to the Project

If the PI or co-PI will devote substantially less time to the project than anticipated in the approved proposal, (defined in the applicable grant terms and conditions as a reduction of 25% or more in time) he/she should consult with the appropriate officials of the grantee organization. Requests for changes to the person-months devoted to the project must be signed and submitted by the AOR via use of NSF’s electronic systems. This request must be submitted at least 30 days before the proposed change, or as soon as practicable after the prospective change is known. If the grantee organization or NSF determines that the reduction of effort will substantially impair the successful execution of the project, the NSF Program Officer will consult the NSF Grants and Agreements Officer. The NSF Grants and Agreements Officer may:

(i) request the grantee to nominate a replacement PI or co-PI acceptable to the cognizant NSF Program Officer;

(ii) initiate the termination procedures described in Chapter XII.A; or

(iii) negotiate an appropriate modification to the grant.

c. Addition of co-PI

In the event the grantee desires to add a new co-PI to a project⁶¹, the AOR must sign and submit the request via use of NSF's electronic systems. The new co-PI's name, biographical sketch, current and pending support from all ongoing projects and proposals, as well as a justification for the addition must also be included in the request. The contact information for the new co-PI also should be included. If approved by NSF, the Grants and Agreements Officer will amend the grant.

d. Withdrawal of PI or co-PI

In the event the PI or co-PI severs his/her connection with the grantee organization or otherwise relinquishes active direction of the project, the AOR must sign and submit a notification of the withdrawal of the PI or co-PI via Research.gov. This request must be submitted at least 30 days before the proposed change, or as soon as practicable after the prospective withdrawal is known. The grantee also must:

(i) initiate transfer of the grant as described in Chapter VII.B.2.f. (This is generally reserved for the withdrawal of the PI);

(ii) nominate a substitute as described in Chapter VII.B.2.e; or

(iii) initiate grant closeout procedures through submission of final reports as described in Chapter VII.D.2. (This is generally reserved for the withdrawal of the PI if no substitute is nominated).

e. Substitute (Change) PI or co-PI

In the event the grantee desires to continue the project with a substitute PI/PD or co-PI/co-PD, the AOR must sign and submit the request via use of NSF's electronic systems. The substitute PI's name or co-PI's name, biographical sketch, current and pending support from all ongoing projects and proposals, as well as a justification for the substitution must also be included in the request. The contact information for the substitute PI or co-PI also should be included. If approved by NSF, the Grants and Agreements Officer will amend the grant. If not approved, NSF may take steps, pursuant to Chapter XII.A to suspend or terminate the grant.

In cases where a former NSF employee or IPA is being reappointed as PI or co-PI to an award they were previously involved with, the grantee must submit a "Change of PI" request using the FastLane Notifications and Requests module. The change in PI request should include documentation from the AOR designating a substitute negotiator for that award under the Associated Documents section. A co-PI request should designate the PI as the substitute negotiator.

f. Disposition of a Grant When a PI Transfers from One Organization to Another Organization

(i) Policy. When a PI plans to leave an organization during the course of a grant, the organization has the prerogative to nominate a substitute PI or request that the grant be terminated and closed out. In those cases where the PI's original and new organizations agree, NSF will facilitate a transfer of the grant and the assignment of remaining unobligated funds to the PI's new organization. This should normally be done with a tripartite agreement (involving NSF, the PI's original organization and new organization), or by a subaward arrangement between the PI's original and new organizations, subject to NSF's consent. (See Chapter VII.B.3)

(ii) Procedures. When a PI plans to leave an organization during the course of a grant, the PI or the SPO, shall notify the cognizant NSF Program Officer. If the project is to continue with the original organization, the cognizant NSF Program Officer should advise the grantee to nominate a substitute PI (see Chapter VII.B.2.d. If the project is to be continued at the PI's new organization, and if NSF and both organizations agree, formal notification of the impending transfer can be electronically initiated by either the PI or the PI's organization. The amount transferred has to be equal to or less than the unobligated balance. The request shall include a:

(a) brief summary of progress to date;

(b) description of work yet to be accomplished;

(c) completed on-line transfer request, including total disbursements and unpaid obligations to date (transfer amount will be automatically calculated, based on the amount entered in total disbursements). The original organization is responsible for including in the total estimated disbursements, any anticipated costs yet to be incurred against the original grant;

(d) detailed line item budget for the transfer amount and any outstanding continuing grant increments; and

(e) If funding is requested to support a postdoctoral researcher, then the request must include the requisite mentoring plan as described in Chapter II.C.2.j. The plan must be uploaded under "Mentoring Plan" in the Supplementary Documentation section of Fastlane. The PI must report on the mentoring activities provided to the individual(s) in annual and final project reports.

The original organization concurs with the transfer of the award by electronically forwarding the request to the new organization.

The new organization completes the request by providing a detailed budget for the transfer amount agreed to by both organizations. The AOR of the new organization must sign and submit the request via use of NSF’s electronic systems. Submission of the request constitutes agreement by the new organization to assume responsibility for completion of the project effort and to administer the grant (as originally awarded) from the transfer date to completion in accordance with any special terms and conditions and the applicable general terms and conditions that normally govern NSF grants made to the new organization. Special terms and conditions, as appropriate, cited in the original award will convey to the new grantee organization.

NSF will assign a proposal number at the time of submission. This proposal number will become the new grant number when the transfer is approved by an NSF Grants and Agreements Officer.

(iv) Monetary Discrepancies. Upon transfer of the grant to the new organization, any monetary discrepancies must be resolved between the original and the new grantee. NSF will not intervene in any disputes between the two organizations regarding the transferred amount.

(v) Equipment Transfers. Equipment purchased with NSF funds for use in a specific project should remain available for use for the duration of the project. PIs who are in the midst of projects that included funding for equipment and who will continue the project at a new organization with NSF support, should arrange with their original organization to have the equipment transferred with them. Shipping costs for such equipment may be charged to the original or transferred grant as an allowable cost. Budgets should not include funds to "buy" equipment that had been previously obtained with Federal funds.

(vi) Possible Alternatives to the Transfer Process. When the amount of time and funds remaining in a project are modest, and if both the original and new organizations are in agreement, the original organization may issue a subaward to the new organization for completion of the project. This and other possible alternatives should be discussed with the NSF Grants and Agreements Officer.

3. Changes in PI, co-PI or Person-Months Devoted to the Project at the Initiation of NSF

a. Upon receipt of a notification specified in Chapter VII.A.2.f or g, NSF will consider, at a minimum, the following factors:

(i) The safety and security of personnel supported by the NSF award;

(ii) The overall impact to the NSF-funded activity;

(iii) The continued advancement of taxpayer-funded investments in science and scientists; and

(iv) Whether the awardee has taken appropriate action(s) to ensure the continuity of science and that continued progress under the funded project can be made.

b. Upon receipt and review of the information provided, NSF will consult with the AOR, or designee. Based on the results of this review and consultation, the Foundation may, if necessary, assert its programmatic stewardship responsibilities and oversight authority, to initiate the substitution or removal of the PI or any co-PI, reduce the award funding amount, or where neither of those previous options is available or adequate, to suspend or terminate the award.

c. When NSF invokes this authority, the grantee must nominate a substitute PI or co-PI via use of NSF’s electronic systems. The substitute PI's name or co-PI's name, biographical sketch, current and pending support from all ongoing projects and proposals, must also be included in the request. The contact information for the substitute PI or co-PI also should be included. If approved by NSF, the Grants and Agreements Officer will amend the grant. If not approved, or a substitute PI or co-PI is not available, NSF may take steps, pursuant to Chapter XII.A to suspend or terminate the grant.

4. Subawarding or Transferring Part of an NSF Award (Subaward )⁶²

Excluding the purchase of items such as commercially available materials and supplies, equipment, or general support services allowable under the grant, no part of an NSF award may be subawarded or transferred to another organization without prior NSF authorization. The intent to enter into such arrangements should be disclosed in the proposal.

If it becomes necessary to subaward, transfer or contract out part of an NSF award after a grant has been made, the grantee shall submit, at a minimum:

a. a clear description of the work to be performed by each subrecipient;

b. a separate budget and budget justification for each subaward; and

c. If funding is requested to support a postdoctoral researcher, and the original proposal did not include a mentoring plan, then the request must include the requisite mentoring plan as described in Chapter II.C.2.j. The plan must be uploaded under "Mentoring Plan" in the Supplementary Documentation section of Fastlane.

The request must be signed and submitted by the AOR via use of NSF's electronic systems, and NSF authorization will be indicated by an amendment to the grant signed by the Grants and Agreements Officer. The NSF grant terms and conditions will identify which articles flow-down to subrecipients.

Procurements under NSF grants are subject to Chapter X.C as well as 2 CFR §200.317-327.

5. Postaward Additions of Postdoctoral Scholars

If a grantee rebudgets funds to support a postdoctoral researcher and the original proposal included a mentoring plan, no further documentation is necessary. If the original proposal did not include a mentoring plan, then the grantee must send the cognizant NSF Program Officer the requisite mentoring plan, as described in Chapter II.C.2.j.

If supplemental funding is requested to support a postdoctoral researcher and the original proposal did not include a mentoring plan, then the supplemental funding request must include the requisite mentoring plan, as described in Chapter II.C.2.j. The plan should be uploaded to the “Other Supplementary Documents” section of the FastLane Supplemental Funding Request module.

In all cases, the PI must report on the mentoring activities provided to the individual in the annual and final project reports.

C. Cost Sharing

1. General

The National Science Board issued a report entitled "Investing in the Future: NSF Cost Sharing Policies for a Robust Federal Research Enterprise" (NSB 09-20), which contained eight recommendations for NSF regarding cost sharing. In implementation of the Board’s recommendations, NSF’s revised guidance⁵⁴) (see Chapter II.C.2.g(xii)) is as follows:

• inclusion of voluntary committed cost sharing is prohibited. It should be noted that foregoing full indirect cost rate (F&A) recovery is considered voluntary committed cost sharing; and


• when mandatory cost sharing is included on Line M and accepted by NSF, the commitment of funds becomes legally binding and is subject to audit. Failure to provide the level of cost sharing required by the NSF solicitation and reflected in the NSF award budget may result in termination of the NSF award, disallowance of award costs and/or refund of award funds to NSF by the grantee.

2. Mandatory Cost Sharing Commitments

2 CFR §200.306 prescribes criteria and procedures for the allowability of cash and in-kind contributions.

Grantees should be aware that mandatory cost sharing commitments are subject to audit. Audit findings involving cost sharing have pertained to: a) failure to keep adequate source documentation for claimed cost sharing; b) unclear valuation of in-kind donated contributions; c) lack of support for cost sharing contributions by subrecipients; and d) failure to complete annual certifications for awards with mandatory cost sharing requirements. Additional guidance on cost sharing may be obtained at: http://www.nsf.gov/bfa/dias/caar/costrev.jsp.

3. Mandatory Cost Sharing Records and Reports

a. Grantee Records

Grantees shall maintain records of all project costs that are claimed by the grantee to meet mandatory cost sharing requirements specified in an NSF program solicitation. Records for cost share contributed to NSF awards must be compliant with the requirements of 2 CFR §200.306 and are subject to audit.

b. Grantee Reports

The amount of mandatory cost sharing must be documented (on an annual and final basis), certified by the AOR, and reported to the cognizant NSF Program Officer via use of NSF’s electronic systems. Such notifications must be submitted no later than 90 days prior to the end of the current budget period to meet the annual notification requirement, and no later than 120 days following the end date of the of the grant to meet the final notification requirement. The cost share notification is considered due during the 90 or 120 day period respectively. The notification becomes overdue the day after the respective 90 or 120 day period ends.

c. Changes to the Cost Sharing Amount Specified on Line M of the NSF Award Budget

Should the grantee become aware that it may be unable to provide the cost sharing of at least the amount identified on Line M of the NSF award budget, the AOR must immediately sign and submit a request to revise the agreed upon cost sharing amount and submit the request via use of the “Other” category” in the Notification and Request module of NSF’s electronic systems. The request must provide a description of why the cost sharing amount cannot be provided, and either indicate steps the grantee plans to take to secure replacement cost sharing; or indicate the plans that the grantee has to either continue or phase out the project in the absence of the approved level of cost sharing.

Should NSF agree to the organization's proposed plans, the NSF Grants and Agreements Officer will modify the award accordingly, including, if appropriate, reducing the amount of NSF support. Should the organization’s plans be unacceptable to NSF, the award may be subject to termination. NSF modifications to proposed cost sharing revisions are made on a case-by-case basis.

Failure by the organization to notify NSF, in accordance with the paragraph above, may result in the disallowance of some or all of the costs charged to the grant; the subsequent recovery by NSF of some or all of the NSF funds provided under the grant; possible termination of the grant; and may constitute a violation of the terms of the award so serious as to provide grounds for subsequent suspension or debarment.

D. Technical Reporting Requirements

NSF requires project reports for all assistance awards. Information from these reports is used in annual reports to Congress to demonstrate the Foundation’s performance as mandated by the Government Performance and Results Act (GPRA) of 1993. These reports also provide NSF program officers and administrative offices with information on the progress of supported projects and the way these funds are used. Information in these reports may be made available to the general public through the Freedom of Information Act (FOIA). These reports are fully consistent with and implement the Research Performance Progress Report (RPPR), which is the government-wide standard for use with research and research-related activities. Except where another format is approved by OMB for use by an NSF program, this means that the ‘‘where practicable’’ requirement specified in 2 CFR §200.329 is not required as the RPPR does not relate financial information to performance data.

1. Annual Project Reports

Annual Project Reports should address progress in all activities of the project, including any activities intended to address the Broader Impacts criterion that are not intrinsic to the research. These reports are not cumulative and should be written specifically for the most recently completed budget period. Unless otherwise specified in the award, annual project reports should be submitted electronically no later than 90 days prior to the end of the current budget period to allow adequate time for the cognizant Program Officer to review and approve the report.

As reflected in the Project Reporting System in Research.gov, the report is considered due during the 90 day period. The report becomes overdue the day after the 90 day period ends. Failure to submit timely reports will delay processing of additional funding and administrative actions, including, but not limited to, no cost extensions. In the case of continuing grants, failure to submit timely reports may delay processing of funding increments. See also Chapter VI.E.3.

Annual project reports may not be required for fellowship awards. Specific reporting requirements for fellowships are established in the applicable program solicitation and award conditions.

For multi-year standard grants, PIs are required to submit annual reports as outlined above. In the case of cooperative agreements, the annual report is required before NSF approves any future funding increments.

Continuing grants also are subject to the same policies regarding report submission as outlined above. For continuing grants that have a duration of 18 months or more per increment, two annual reports are required. A report must be submitted for the first 12 months of the project, and then another report for the remaining months of the increment. Continuing grants which include an increment of 24 months will require an annual report for each 12 month period.

2. Final Project Report

The final project report should address progress in all activities of the project, including any activities intended to address the Broader Impacts criterion that are not intrinsic to the research. This report is not cumulative; it is the last annual report of the project and should be written specifically for the most recently completed budget period. By submitting the final project report, the PI is signifying that the scope of work for the project has been completed and that he/she does not anticipate that any further research activities (including a no-cost extension, supplemental funding, or transfer of the grant) need to be completed on the project. Submission of the final project report, however, does not preclude the grantee from requesting any further payments for costs incurred during the period of performance.

Unless otherwise specified in the award, the final project report should be submitted electronically no later than 120 days following the end date of the grant. As reflected in the Project Report System, the report is considered due during the 120-day period. The report becomes overdue the day after the 120-day period ends. In addition, the grantee also shall provide to the cognizant NSF Program Officer, within 120 days following the end date of the grant:

• any unique reports or other end items specified in the grant, including any reporting requirements set forth in any NSF brochure, guide, solicitation, etc., referenced in the grant as being directly related to either the award or the administration of the grant.


• a final cost share notification documented and certified by the AOR for grants where there is mandatory cost sharing established for the program.

Final project reports may not be required for institutional graduate research fellowships. However, final reporting requirements for individual fellowships are established in the applicable program solicitation.

3. Project Outcomes Report for the General Public (POR)

This report serves as a brief summary, prepared specifically for the public, of the nature and outcomes of the project.

Section Contents:

a. Describe the project outcomes or findings that address the intellectual merit and broader impacts of the work as defined in the NSF merit review criteria. This description should be a brief (generally, two to three paragraphs) summary of the project's results that is written for the lay reader. PIs are strongly encouraged to avoid use of jargon, terms of art, or acronyms.

b. NSF will automatically include all publications associated with the grant that are reported in annual and final project reports. Other products that have resulted from the grant may also be listed. Examples of other products include collections, data sets, software, as well as educational materials.

c. Information regarding anticipated publication of project results, as well as any other information that would be of interest to the public also may be included in this section.

Grantees are to ensure that the report does not contain any confidential, proprietary business information; unpublished conclusions or data that might compromise the ability to publish results in the research literature; or invention disclosures that might adversely affect the patent rights or those of the organization, in a subject invention under the award. PORs are not to contain any personally identifiable information such as home contact information, individual demographic data or individually identifiable information collected from human research participants. This report will be posted electronically by NSF exactly as it is submitted and will be accompanied by the following disclaimer:

"This Project Outcomes Report for the General Public is displayed verbatim as submitted by the Principal Investigator (PI) for this award. Any opinions, findings, and conclusions or recommendations expressed in this Report are those of the PI and do not necessarily reflect the views of the National Science Foundation; NSF has not approved or endorsed its content."

The POR must be submitted electronically no later than 120 days following end date of the grant. By submitting the POR, the PI is signifying that the scope of work for the project has been completed and that he/she does not anticipate that any further research activities (including a no-cost extension, supplemental funding, or transfer of the grant) need to be completed on the project. Submission of the POR, however, does not preclude the grantee from requesting any further payments for costs incurred during the period of performance.

4. Compliance with Technical Reporting Requirements

PIs must submit final technical reports within the time period specified. Failure to provide these reports on a timely basis will delay NSF review and processing of pending proposals for all identified PIs and co-PIs on a given award.

5. Grant Closeout

Grant closeout is the process by which NSF determines that all applicable administrative actions and all required work of the grant have been completed. See also Chapter VI.D.3.c for additional information on no cost extensions. The close out amount will be based on the costs recorded at that time. See also Chapter VIII.E.5 for additional information on post closeout adjustments and final disbursements. Grants are administratively closed after receipt of the Final Project Report and Project Outcomes Report and after determination that any other administrative requirements in the grant have been met. Grants will be financially closed out 120 days after their expiration date.

In accordance with 2 CFR §200.344(i), if the grantee does not submit all required reports within one year of the period of performance end date, NSF must report the grantee’s material failure to comply with the terms and conditions of the award with the OMB-designated integrity and performance system (currently FAPIIS). NSF may also pursue other enforcement actions per 2 CFR §200.339.

In the event a final audit has not been performed prior to the closeout of the grant, NSF reserves the right to recover funds after fully considering the recommendations on disallowed costs resulting from the final audit.

E. Record Retention and Audit

1. Financial records, supporting documents, statistical records, and all other records pertinent to the NSF grant must be retained by the grantee for a period of three years from award financial closeout described in Chapter VIII.E.3, except as noted in 2 CFR §200.334.

2. It is the responsibility of grantees that are States, local governments, or non-profit organizations to arrange for the conduct of audits as required by 2 CFR §200, Subpart F. They shall provide copies of the reports of these audits to the Federal Audit Clearinghouse (see 2 CFR §200.512(b)). Any Federal audit deemed necessary by NSF shall build upon the results of such audit(s).

3. All awards issued by NSF meet the definition of Research and Development (R&D) at 2 CFR §200.1. As such, auditees should identify NSF awards as part of the R&D cluster on the Schedule of Expenditures of Federal Awards (SEFA). The auditor should test NSF awards for compliance as instructed in Part V, Clusters of Programs. NSF recognizes that some awards may have another classification for purposes of indirect costs (F&A). The auditor is not required to report the disconnect (i.e., the award is classified as R&D for audit purposes but non-research for indirect cost rate (F&A) purposes), unless the auditee is charging indirect costs at a rate other than the rate(s) specified in the award document(s).