FASEB Comments on the Draft NSF Guidance on Financial Assistance

Monday, August 24, 2026
Today, FASEB submitted comments on the Draft NSF Guidance on Financial Assistance (GFA), which will replace the NSF Proposal and Award Policies and Procedures Guide (PAPPG), Docket No. NSF-2026-OTR-0001; OMB Control No. 3145-0058. In the comments,  FASEB aligned with the goals outlined in the draft GFA. As currently drafted, several key operational provisions would work against the desired outcomes, and FASEB provided a series of seven key recommendations, including merit-based peer review as the primary decisioning path, ensuring mid-award terminations are rare and weigh sunken costs, automatic allowance of conference travel, automatic allowance of publication costs, upholding recipients statutory civil rights and disability obligations, specific risk-based measures for research security that do not shut down open, reciprocal international collaboration, and a request for specific term definitions. FASEB also referenced our prior comments with the Office of Management and Budget on parallel revisions to 2 CFR 200 (Docket No. OMB-2026-0034) and respectfully requested NSF consider the two submissions as a single, integrated record.