FR 2024-29244

The document from the National Science Foundation (NSF), published in the Federal Register, outlines plans to renew its information collection regarding proposal and award processes. This Notice provides the public with an opportunity to comment before the NSF submits a request to the Office of Management and Budget (OMB) for approval to continue the collection for another three years. The primary aim of this initiative is to update the existing Proposal and Award Policies and Procedures Guide (PAPPG) to integrate new policy requirements and enhance clarity.

General Summary

This notice pertains to the NSF's intention to renew its information collection framework, focusing on the PAPPG. In alignment with the Paperwork Reduction Act, the NSF seeks public feedback on the proposed update, which involves revisions to accommodate statutory, policy, and language changes. The NSF processes a significant volume of proposals annually, estimated at 40,000, with roughly 10,500 achieving funding. Public comments are solicited on several aspects, including the necessity, utility, and the burden of this information collection process.

Significant Issues and Concerns

One primary concern highlighted in the document is the substantial time commitment required for proposal preparation. The NSF estimates that each proposal takes approximately 120 hours to complete, amounting to 4,800,000 hours of public burden per year. This extensive time requirement may exert pressure on researchers and institutions, potentially diverting resources away from core activities.

Additionally, the document does not mention specific financial costs associated with preparing these proposals. While time is accounted for, monetary implications remain unaddressed, which may add another layer of complexity for submitting organizations.

A further point of concern involves the transparency of the merit review process that determines which proposals receive funding. The document provides a broad statement on merit-selected projects but lacks detailed criteria or procedural descriptions, which could raise questions about the fairness and openness of the selection process.

Impact on the Public and Stakeholders

Broad Public Impact:

The call for public comment may positively engage a wider audience, allowing stakeholders to voice their opinions on how information collection affects them. This could inform NSF's policies and procedures, ideally tailoring them to better serve public interests. However, complexities within the document and the detailed procedural language might deter non-expert engagement, hindering broader public participation.

Impact on Specific Stakeholders:

For academics and research institutions, the renewal and revision of the PAPPG signals both continuity and adaptation within NSF funding processes. While updates may enhance clarity and compliance, the perceived high burden of proposal preparations might pose challenges, particularly for smaller institutions with limited administrative support.

Meanwhile, the mandate for public comment could serve as a useful platform for stakeholders to influence policy enhancements. Their feedback could advocate for reduced administrative burdens or suggest improvements in proposal submission and evaluation systems.

The failure to address potential issues like favoritism in the award process could concern some stakeholders, particularly given the lack of detail surrounding merit selection criteria. This lack of transparency might influence perceptions of fairness and equality in access to funding.

In conclusion, while this notice invites valuable public commentary on significant procedural updates, it also uncovers challenges regarding the time and clarity of preparation requirements and highlights the need for greater transparency in the merit review process.