I am working with an association of Appalachian colleges that just had its NSF award terminated. I have directed the association to follow the appeals process first, with the idea in mind that even if it is not responded to, if litigation is pursued, it will show that the association took agency action. The recent terminations claimed that recipients did not have the right to contest, but I argue that 2 CFR 200.342 requires agencies "must provide the recipient with an opportunity to object and provide information challenging the action."
Is anyone else taking this route? And, if so, what has been your approach to preparing the final reports if closeout must eventually occur? My initial reaction is to prepare, but not submit, until absolutely necessary.
Best,
Natalie
------------------------------
Natalie Sweet
Executive Director, Office of Research, Grants, and Sponsored Programs
Lincoln Memorial University
Harrogate, TN
423-869-6607
------------------------------