NATIONAL SCIENCE FOUNDATION OFFICE OF INSPECTOR GENERAL OFFICE OF INVESTIGATIONS CLOSEOUT MEMORANDUM Case Number: A06090045 We received a n allegation of a possible conflict of interests (COI) violation against two former NSF Program Managers.1 The two Program Mangers left NSF a t the same time and submitted a collaborative proposal2 less t h a n 1year after they left NSF. After the review, the proposal was recommended for funding, and both PIS named substitute PIS. NSF's guidance for former staff3 describes prohibitions against representational dealings with NSF for 1year. However, it is not considered a representational dealing to: prepare a proposal, be listed a s a PI or co-PI on a proposal or award, or participate in research under a n NSF award.4 Thus, there is no COI violation for the subjects' submission of a proposal. Although they are allowed to write, submit, and lead the research, they are not allowed to negotiate with the NSF Program Manager about the budget, so t h a t is why they named substitute PIS to do so. Accordingly, this case is closed. 1 (footnote redacted). 2 (footnote redacted). 3 A Guide to Post-Employment Restrictions for Former NSF Staff. 4 Ibid., Part 111-Involvement with Proposals and Awards after NSF Service 5 20 (e) Permitted research and educational activities.
Published by the National Science Foundation, Office of Inspector General on 2006-10-04.
Below is a raw (and likely hideous) rendition of the original report. (PDF)