FASEB Urges NSF to Revise Draft Financial Assistance Guidance
By: CJ Neely, PhDThursday, September 10, 2026
FASEB submitted comments on the National Science Foundation’s (NSF) draft Guidance on Financial Assistance (GFA; Docket No. NSF-2026-OTR-0001), which would replace the Proposal and Award Policies and Procedures Guide (PAPPG). As previously reported, the draft reorganizes the PAPPG into topic-based guides and aligns NSF policy with recent executive orders and proposed revisions to 2 CFR 200. The comment period closed August 24.
FASEB supports the draft’s goals of reducing administrative burden, strengthening research security, and maintaining merit-based science. However, FASEB cautioned that several provisions, as written, could work against those goals.
On process and oversight, FASEB urged NSF to:
- Preserve merit-based peer review as the primary basis for award decisions, limiting senior leadership and risk review to statutory eligibility and documented integrity concerns.
- Limit mid-award terminations to rare, clearly defined circumstances, requiring NSF to consider the federal investment already made and commitments to institutions and trainees while preserving a meaningful right of appeal.
- Keep reasonable conference travel presumptively allowable without requiring case-by-case preapproval.
On access, security, and implementation, FASEB urged NSF to:
- Resolve conflicting provisions on publication costs. Although the draft’s summary disallows these expenses, budget instructions elsewhere permit them. FASEB recommended that reasonable publication and dissemination expenses remain automatically allowable.
- Use targeted, risk-based research security measures that do not unnecessarily restrict open, reciprocal international collaboration.
- Confirm that recipients’ civil rights and disability obligations remain in force.
- Clearly define key terms, including “publication costs” and “national interest,” before the GFA takes effect.
FASEB also incorporated its earlier comments on OMB’s parallel 2 CFR 200 revisions into the submission, given the close relationship between the two rulemakings.