By: Nina Exner and Megan O’Donnell

On December 12, 2024, the National Science Foundation (NSF)  announced in the Federal Register that there would be an “Agency Information Collection Activity: Comment Request.” The comment request specifically opened a public comment period about a Draft  NSF Proposal and Award Policies and Procedures Guide (PAPPG) for 2026 due February 10, 2025.

The PAPPG is a long document that outlines both how to apply for NSF awards and what is expected of those who are awarded NSF grants. Of note to RDAP members, it is where the NSF data management plan (DMP) policy and guidance about public access compliance is documented (although there is also additional information on the NSF website, particularly on directorate-specific pages.).

Nina Exner, (Virginia Commonwealth University), sent the Executive Board an official request for RDAP to respond to the draft as it contained significant changes to data management plan requirements. The Executive Board approved the request in early January and appointed Megan O’Donnell (RDAP Secretary, Iowa State University) and Nina Exner to lead the response task force.

Due to the release of the draft shortly before many of us took holiday leave, there was a tight deadline for assembling the task force, analyzing changes, and drafting comments. However, less than 24-hours after the call for volunteers was sent out we had more volunteers than we could easily organize and capped membership to the first six respondents.

Three sections were identified for response:

• Part 1 Ch II.i.ii Data Management and Sharing Plan (DMSP) of the Products of Research (pg 70-71)
• Part II. Ch XI.D.2.c Public Access to Copyrighted Material (pg 185); and
• Part II. Ch XI. D. 4 (pg 187)

Even with this limited scope there was a considerable amount to analyze and comment on as there were some significant and surprising changes to data management and public access requirements. The biggest change was the change of how the DMSP (formally DMP) would be submitted. Instead of a separate document, it would be completed through a web form on the research.gov proposal platform. Some of the sections of the DMSP also showed changes and there was new information about DOIs, how to submit dataset metadata to NSF-PAR, and new metadata and intellectual property issues related to data and data sharing.

We recommend that RDAP members who work with NSF funded research read the yellow-highlighted text of pages 70, 71, 185, and 187 of the draft. While not final, the draft provides insight into where and how DMP/DMSPs and public access requirements are likely to change.

A copy of the comment RDAP submitted to NSF is available through the RDAP OSF archive.

Thank you to all of the commenters that gave us input and insights through Slack and email, to the RDAP executive board officers, and to our stellar task force!  Because of the holidays we ended up with a quite short timeframe to do the work and we appreciate every bit of insight and effort contributed.

The task force members who drafted RDAP’s comment are:

• Nina Exner (co-lead)

• Megan O’Donnell (co-lead)
• Jen Ferguson
• Sarah Gonzalez
• Dani Kirsch
• Lauren Phegley
• Allie Tararian
• Brian Westra

Association members can request an official association response by contacting the Executive Board. More information about this can be found on the Advocacy Request page.