Comment on Proposed NSF Guidance on Financial Assistance

VIA ELECTRONIC SUBMISSION
Suzanne H. Plimpton, Reports Clearance Officer
National Science Foundation
Randolph Building, 401 Delany Street
Alexandria, Virginia 22314

Re: Comments on Proposed NSF Guidance on Financial Assistance (Version 27-1)
Information Collection 3145-0058
Docket no. NSF-2026-OTR-0001

Dear Ms. Plimpton,

The American Physical Society (APS) — representing more than 50,000 physicists across academic institutions, national laboratories, and industry — appreciates the opportunity to provide written comments regarding the National Science Foundation’s (NSF’s) proposed Guidance on Financial Assistance (GFA, Version 27-1).

As detailed in the Summary of Changes, the draft GFA explicitly aims to:

1. Align NSF policy with recent Executive Orders, including E.O. 14222 (Department of Government Efficiency Cost Efficiency Initiative), E.O. 14332 (Improving Oversight of Federal Grantmaking), and E.O. 14303 (Restoring Gold Standard Science).
2. Align NSF policy with the Office of Management and Budget’s (OMB) proposed revisions to the Uniform Guidance at 2 CFR 200 published on May 29, 2026 (91 Fed. Reg. 32,198).

We are concerned with the Foundation's pre-supposition of the outcomes of the government-wide federal rulemaking process regarding OMB revisions to the Uniform Guidance. APS previously submitted a comprehensive public comment1 to OMB on July 8, 2026, opposing the proposed revisions to 2 CFR 200. The Society called for OMB to withdraw the proposed rule in its entirety. Instead, it urged the agency to engage in meaningful, transparent dialogue with the scientific, academic, and industrial sectors. This collaborative approach would support, rather than disrupt, the progress of American science and the economic wealth it provides the American people.

Because NSF’s draft GFA directly integrates and embeds these OMB revisions across multiple Guides — including politicized grant review, obstacles for international collaboration, new barriers to covering costs of research dissemination, and removing references to non-discrimination provisions — APS opposes these aspects of the proposed GFA. Below, we outline our primary arguments against the underlying OMB proposal and highlight how incorporating these mandates will severely compromise NSF’s core scientific mission.

I. Politicization of Merit Review and Project Continuity

Draft GFA Guides 8, 9, and 25 / OMB 2 CFR §§ 200.205 & 200.340

For decades, American scientific leadership has relied on a rigorous, merit-based expert review system managed by domain specialists at agencies like NSF. The OMB proposal converts more flexible guidance into rigid, enforceable rules. This new rule would require political appointees to conduct "pre-issuance reviews" and veto technical awards without “routinely defer[ing] to peer review.”

As detailed in our OMB comment, non-expert political designees cannot properly evaluate physical science research. Requiring these political sign-offs introduces non-technical, subjective filters and creates a vast administrative bottleneck, stymieing research across fields and slowing progress in high-priority emerging technology areas like quantum computing and advanced materials.

The expanded contract termination provisions pose a serious threat to our nation’s ability to make discoveries or innovate in burgeoning research areas with tremendous economic potential. Sudden cancellation of funding due to shifting administrative priorities undermines the multi-year stability required for complex physics experiments and the exploration of new technical ideas. Taxpayer dollars are wasted when mid-cycle cancellations interrupt data collection, shelve sensitive experimental set-ups, and derail student and researcher careers. These projects are not easily resumed, meaning there is no return on investment and potentially transformative discoveries are left to languish on hard drives or lab benches.

II. Disruption of Essential International Scientific Collaboration

Draft GFA Guides 2, 14, and 22 / OMB 2 CFR §§ 200.202(e) & 200.220

Physics is an inherently global endeavor that relies on shared international infrastructure and open collaboration. The OMB proposal threatens this vital international collaboration by expanding rigid, Wolf Amendment-style restrictions government-wide and instituting a "domestic-first" framework for research and development.

We fully recognize that there are legitimate national security concerns in the R&D enterprise, and were encouraged by the pilot implementation of the original TRUST program with a focus on risk mitigation. At the same time, APS is concerned with potential changes in the recently-issued Dear Colleague Letter2 and by the proposed OMB rule’s government-wide Wolf Amendment approach. In the physical sciences, a broad, baseline prohibition on funding bilateral or multilateral collaborations — extending to data-sharing, travel, and indirect allocable costs — will severely disrupt unclassified, fundamental research as well as downstream applications-oriented work.

The proposed GFA defines a country of concern as “A country determined by the U.S. Secretary of State, including The People's Republic of China, the Democratic People's Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country deemed to be a country of concern.” However, adherence to an updated 2 CFR 200 expands on this, defining "covered foreign countries" by drawing from multiple statutes and Executive Orders that are fluid and, depending on the rule’s interpretation, expansive lists of up to dozens of countries.

Large-scale, international collaborations will be effectively paralyzed by legal ambiguity due to their complex organizational structures and the number of countries involved. And for the far more numerous small collaborations that carry out the bulk of basic research driving new technology development in the U.S., the impact is magnified. These small groups cannot garner the resources to address such legal complexities.

Forcing an institution to halt standard international scientific interactions without explicit approval from a federal agency head or their designee introduces an unworkable administrative burden. Under the proposed rule, a physicist at an American institution could be barred from accessing a data pipeline, attending a multinational planning conference, or utilizing institutional indirect funds to help support a piece of experimental infrastructure used by the U.S. and partner nations. The United States risks cutting its own researchers out of experiments at the frontiers of discovery, stalling international projects where the U.S. has already invested significant resources, and ceding its position at the vanguard of international physics research. The resulting decreased awareness of U.S. scientists regarding scientific developments around the world would be equally pernicious.

III. Restrictions on Professional Activities, Dissemination, and Periodicals

Draft GFA Guide 12 (Cost Principles) / OMB 2 CFR §§ 200.432, 200.454, & 200.461

The Summary of Changes (pg. 7) in the proposed GFA for Guide 12 states that the GFA now “Disallows publication costs consistent with proposed revisions to 2 CFR 200.” However, nowhere in the document body does the GFA include instructions about publication cost, nor does the linked prior approval matrix mention anything about publication costs.

Scientific publication is the world’s primary forum of research dissemination. Subjecting scientific results to the scrutiny of the rest of the community has resulted in a trustworthy consensus understanding of the world. In detailing experimental methods, presenting data, and cataloging uncertainties, the scientific literature establishes a reliable record that allows today’s scientists to build upon past discoveries, minimize duplication, and accelerate technological innovation. Treating publication expenses as "not inherently necessary" not only cuts U.S. researchers off from this vital forum, but also creates a direct contradiction with federal public access mandates requiring immediate public availability of research outputs.

Federal dollars invested in fundamental, unclassified research for which results are never disseminated brings no value to the public that funded that research. Furthermore, these restrictions threaten mission-driven, non-profit scientific societies like APS, where publication costs fund the extensive digital infrastructure, editorial scrutiny, and ethical oversight required to maintain a validated, trustworthy research record.

IV. Subjective Pre-Award Vetting and Ideological Scrutiny

Draft GFA Guide 13 / OMB 2 CFR § 200.206

The OMB proposal introduces a modernized "risk-assessment framework" that strays from objective research security standards (such as NSPM-33 or the CHIPS and Science Act). Under § 200.206, applicants face subjective pre-award scrutiny over personal histories, institutional affiliations, and whether they have published "discredited or non-replicable studies" or adhered to broad civil rights/religious liberty interpretations. Embedding ideological alignment into grant eligibility departs from objective risk evaluation, and does nothing to advance gold standard science.

V. Erosion of Domestic STEM Workforce Development and Educational Research

Draft GFA Guide 19 / OMB 2 CFR §§ 200.218 & 200.300

The draft GFA aligns with Executive Orders revoking non-discrimination and environmental justice frameworks. However, as outlined in our OMB submission, proposed changes to 2 CFR 200 include more sweeping restrictions on diversity, equity, and inclusion efforts. These changes threaten evidence-based STEM recruitment initiatives and STEM education research.

Implementing the proposed 2 CFR 200 changes would damage critical workforce initiatives like undergrad-to-PhD bridge programs, which help students from rural or under-resourced institutions successfully transition into doctoral physics tracks. Additionally, the changes would prohibit federal support for "disparate-impact" studies that use demographic and statistical data to optimize physics curricula and understand obstacles preventing students from pursuing STEM fields.

Conclusion

The American Physical Society urges NSF to not incorporate the proposed OMB Uniform Guidance revisions into the final Guidance on Financial Assistance. Replacing merit review with political vetting, isolating U.S. scientists from international facilities, prohibiting publication costs, and dismantling workforce pipelines will destabilize the nation's scientific enterprise. NSF should pause implementation of these specific provisions, increase the transparency of its revision process, and advocate for deep consultation with the scientific community to protect American leadership in discovery science.

Sincerely,