Questions and Answers -Women in STEM Implementation.pdf

Women in STEM Data Collection and Reporting – Questions/Comments and Responses

Q. Re: Data fields, how can DoD components discern if an IHE is a collaborator on an application? i.e.

the R&R form appears to only capture the type of organization/entity for the primary applicant, not collaborating applicant organizations, unless we're missing something.

R. The R&R Senior/Key Person Profile (Expanded) form includes an Organization Name field for each person listed on the form, so it is possible for the applicant to include an individual from a collaborating institution of higher education. While we need to collect information about any PD/PI or Co-PD/Co-PI offered by the applicant, we don't see a need to identify the organization below the applicant level at this time. We do not know how often this situation occurs, as it will depend on the funding opportunity guidance and what is permitted. For example, the DoD Centers of Excellence awarded several years ago to three HBCUs required that each HBCU applicant collaborate with either one or two other institutions of higher education.

Q. Will ASD R&E prepare a standard report template for all Components to use?

R. Yes, we plan to provide a spreadsheet template for the Components separately from the implementing memo.

Q. How long will components have to implement this requirement, since building, testing, and providing training for the IT system or method for capturing this data will take some time?

R. The Components were advised on October 2 that the two forms would be required in new funding opportunities starting in January 2018. Since reporting results will not be required until November 2018, the Components are expected to implement their methods for capturing the data during this time. We understand the initial year of data collection may require some combination of automated and manual collection methods.

Q. Re: Data Fields, what is meant by "DoD Dept/Agency"? Is this the agency owning the contracting/awarding office, the funding agency, the agency that conducts the merit evaluations or other? For example, if a USAF contracting office awards a grant funded primarily by the Army, but the application was submitted on a DARPA BAA and evaluated by DARPA, what agency goes in here?

R. The Dept/Agency field is the name of the agency that is the parent to all subordinate awarding offices, e.g., DARPA, Navy, Air Force, Army, DTRA, etc. The awarding office should be the name that is shown as reported in DAADS. We will revise the field guidance to clarify. At this time, we do not foresee a need to capture organizational information beyond the awarding office.

Q. With respect to filling in the information for Awarding Office, has any thought been given to using the FPDS code, e.g. 97AE for DARPA, in lieu of acronyms or free-text which may result in errors or reporting inconsistencies?

R. See response above.

C. Recommend explicitly stating the data collection is for grants only, as there are other types of awards besides grants, cooperative agreements, and contracts. (For example, MIPRs, Interagency Agreements, Other Transactions, etc.)

R. Regarding the excluded awards, we will revise the wording to indicate that any awards other than a grant or cooperative agreement will not be subject to the reporting requirements.

C. In cases where a formal two-phased solicitation process is used and is a requirement for submission of a proposal, the data collection described herein should apply to both the white paper and the proposal submissions.

R. Regarding white papers, we recognize that DTRA and other DoD Components may use a white paper process as an initial step before inviting full applications. While DTRA uses a Grants.gov application package to receive white papers, other DoD Components typically obtain white papers outside of Grants.gov. DoD has no authority to collect the gender or other information outside of the Grants.gov application process. The SF-424 forms used in the Grants.gov application process, including the R&R Personal Data form, have all been previously cleared by OMB for use by federal agencies, but any information collection outside the Grants.gov application process would require a separate OMB clearance. We do not plan to pursue another information collection for white papers, as this will greatly increase the burden and complexity for some Components. We also will not require that DoD Components use an application package to receive white papers through Grants.gov.

DTRA and any other Components that currently receive white papers through Grants.gov may include the two forms in their application packages used for white papers but are not required to do so. If they choose to include the forms, the Personal Data form must be separated from the material provided to the technical reviewers. Any women in STEM data collected from white paper submissions must not be included in the women in STEM data set used to report the results of award competitions resulting from full applications.

C. DTRA will not be reporting any awards for FY18 because grants awarded in FY18 were solicited in CY16 and did not require the personal data forms.

R. Regarding the fact that DTRA will not be reporting any data for FY18: We understand DTRA uses a two-year cycle and will not have any awards in FY18 that were based on the data collection requirements. We will edit the Data Reporting section to make clear that it applies to awards that are issued in FY18 and were based on funding opportunities subject to the data collection requirement.

C. ONR suggests that this implementation memo NOT include this requirement: "Also, the Research & Related Personal Data form is to be separated from the application and will not be provided to merit reviewers. It will be retained in the pre-award files for the funding opportunity." We have moved to electronic grant files with everything loaded in our electronic grant/cooperative agreement funding system and accessible by the Program Officer. Separating that form out and potentially adding it later so that is part of the permanent record will require additional steps. If this is related to Personal Information, our Program Officers typically know the proposing researcher thus already know the gender.

R. We understand separating the Personal Data form from the materials provided to merit reviewers may require additional steps and effort apart from the normal business practice. However, the instructions on the form itself advise applicants that the form will not be provided to reviewers. Since this form has been through OMB clearance, public comment, and legal review with that stipulation; we believe DoD must comply with that requirement and the OSD General Counsel and DoD Information Collections Office concur. Further, although PD/PI gender may already be known to the program officials, the form contains other fields, such as ethnicity and disability status, that applicants may voluntarily complete, so compliance with the requirement to limit reviewer access needs to be maintained.

Q. Does this mean we would be required to document information from contractors? The second bullet under Data Collection seems to indicate that we would be required to do so. Recommend this be removed as this manual data collection requirement is already going to be extraordinarily burdensome;

the focus should be on IHEs only.

R. Collection of any PD/PI data (from IHEs or other entities) on contract awards is not required. In the case where a grant or cooperative agreement is awarded to an entity other than an institution of higher education, e.g., a non-profit entity, and one or more IHEs competed for the award, we need to include the information from the entity receiving the award in the data set to ensure the award is counted in the total number of awards so that success rates can be calculated. Since Title IX does not apply to entities that are not educational institutions, we do not need to capture any information from non-educational institutions that competed for, but did not receive, a grant or cooperative agreement award.

Q. There is no fillable data field called “Role” on this form. The Role is pre-printed on the form as a subtitle under the name of the form. You cannot determine on this form whether the individual is PD, PI, Co-PD, Co-PI. The better place to get that information is on the R&R Senior/Key Person Form (Expanded), Project Role data field.

R. Thank you for noticing this oversight; we will change the name of the form in the data listing.

C. Recommend this be a pilot program for FY18 only to assess the results, particularly because the data is statistically unreliable, and this places an extraordinary burden on an already overly burdened workforce.

R. We understand this requirement imposes an unexpected burden on the Components, however, there is a requirement for federal agencies who provide funding to educational institutions to support the Departments of Education and Justice with Title IX assessment and compliance. The GAO determined that existing DoD data and processes were insufficient for making this assessment. We expect this requirement will continue in future years, while also recognizing that the data collected for FY18 will not cover the entire fiscal year. We will re-assess the approach after FY18 is completed and welcome suggestions from the Components for improvements or best practices.

C. The draft text provided is not written in plain language (which is required by law). Further, different components have different writing styles. It would be nice to have the flexibility to make the text blend seamlessly with the rest of our announcements.

R. We have revised the wording to give Components more flexibility in using their writing style and/or to incorporate the guidance in their existing application instructions, including “companion documents” referenced in 2 CFR 200 Appendix I.D.2.

C. Suggest deleting the references to the GAO report in the background section. The background is irrelevant to recipients and makes us look we are not interested in enforcing Title IX but only responding to a GAO recommendation.

R. We have replaced the reference to the GAO report with a reference to Title IX, which is the primary requirement for the assessment. We believe that having the short background paragraph is appropriate, so applicants understand why DoD is now requesting this additional information on applications.

C. A determination to not process an application due to incomplete data for optional fields requires concurrence from the USAMRAA and must be aligned with the FAR and DODGAR which outline the contracting and Assistance Agreement regulations.

R. We received several comments on this issue and have decided to remove the sentence stating that “applications may not be processed” for failure to provide the educational data. Components may use their existing procedures for addressing missing data on optional form fields. Given that the information may also reside in PD/PI bios elsewhere in the application, rejecting an application for failure to complete these fields may be problematic. After the FY18 data collection, we will determine if further guidance is needed in the event too many applicants are not providing the information.

C. The primary PI will be responsible for completion of optional information for the key personnel/collaborators for which they may not know all professional degrees and/or disabilities.

R. Grants.gov now requires that all applications be completed using Applicant Workspace or system-to-system software. The process used to prepare applications is up to the applicant, but Workspace allows multiple individuals (including collaborators from outside organizations) to have access to the application forms to assist with completing the application. Forms can be completed within Workspace or downloaded individually for completion and then uploaded to the Workspace.

Q. What about Privacy Act and PII? Shouldn’t that be discussed as part of adding this requirement?

R. The intent is to not create a “system of records” that would be subject to the Privacy Act, but to collect and report the PD/PI information without including names or any other data field that would personally identify the PD/PI.