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NSF Project Reporting Enforcement Pilot

September 22, 2023


The National Science Foundation (NSF) will implement a pilot program to assess the effectiveness of temporarily withholding cash payments pending the submission and approval of annual project reports. The program includes awards that have overdue project reports of 60 days or more from three participating Divisions at NSF: Computing and Communication Foundations (CCF); Civil, Mechanical and Manufacturing Innovation (CMMI); and Information and Intelligent Systems (IIS). The program begins on October 2, 2023, and runs through January 31, 2024, and Sponsored Research expects that it will impact several existing awards at Northwestern.

Notification and Payment Withholding Process

NSF has outlined the following process that ensures that each award will have at least 60 days after an annual report becomes overdue to have the report submitted and approved by NSF:

  • First notice: PIs and AORs for grants or cooperative agreements with overdue annual project reports will receive a notice (the “First Notice”) informing them that the annual report is overdue and request that the report is submitted as soon as possible.
  • Second notice: If the report remains overdue by the beginning of the second month, PIs and AORs will receive a Second Notice.
  • Final notice and payment withholding: If the report remains overdue by the third month, a Final Notice will be sent informing the recipient that NSF is acting to temporarily withhold award cash payments on the grant or cooperative agreement through the Award Cash Management System (ACM$).

Northwestern Sponsored Research Notification and Escalation Process

Sponsored Research receives overdue notices for reports via a central email box that is monitored by the SR Business Systems & Operations Team (BSO). As standard operational procedure, the BSO forwards these notices to the appropriate Sponsored Research Officer (SRO), who follows up directly with departmental RAs and PIs. This process will remain the same for First Notices under the new NSF program. For Second Notices under the NSF program, the SRO will notify the department as well as the appropriate deans office.

Additional Pilot Program Background Information from NSF

NSF is implementing this pilot program to encourage more timely submission of annual project reports. NSF relies on annual project reports to monitor the progress made on grants and cooperative agreements, assess the impact, and to communicate any concerns to Principal Investigators (PIs). NSF award terms and conditions clearly state that PIs must submit annual project reports 90-days prior to the end of the annual budget period of the project, and if reports are not approved by the cognizant NSF program officer by this date, the report is considered overdue. NSF has identified that a significant number of overdue annual reports are a risk to the Agency’s effective operation.