Here is What You Should Know About NSF’s New Guidance on Financial Assistance
By Irene Ngun, Associate Director of Policy and Advocacy, Stand Up for Science Foundation
On June 24, 2026, less than one month after the Office of Management and Budget released its proposed revisions to the Uniform Guidance on federal financial assistance—the National Science Foundation updated its Proposal & Award Policies & Procedures Guide (PAPPG), now being rebranded or supplemented as the Guidance on Financial Assistance (GFA). The GFA is a direct outcome of OMB’s proposed rule and the contents should alarm all grantees but specifically higher education institutions that are NSF grant recipients.
NSF is using this update to align its rule with the Trump Administration’s Executive Orders and the still-unfinalized OMB proposed rule on all federal grants and contracts (see page 6). The GFA draft is currently open for public comments, with a deadline of August 24, 2026. Stand Up for Science is alerting the scientific community and urging active engagement to push back against provisions that could harm research integrity, funding stability, and scientific independence.
The GFA draft makes many additions, removals, and reorganizations, and explicitly notes that 2 CFR 200 takes precedence over any requirements in the GFA (see page 11). The Executive Orders that drove that rulemaking include: EO 14332 on improving oversight of federal grantmaking, EO 14222 on cost efficiency, and EO 14303 on Gold Standard Science.
The GFA spans 26 Guides spanning every process of the award lifecycle from grant application formatting and budget guidance to close of award, termination and appeals. The reorganization from PAPPG to GFA is an attempt to streamline (but also)
Expanded and Accelerated Termination Authority -- the suspension and termination guidance explicitly “aligns with the proposed revisions to 2 CFR 200” (see page 9). Under this guidance, NSF may immediately suspend or terminate an award “to protect the interests of the government,” in which case it is not required to issue a notice of non-compliance or provide an opportunity for a corrective action plan. While Guide 25 still points recipients to a post-decision dispute process in Guide 26, this accelerated pathway creates a practical tension: if NSF skips the normal notice and cure process, it is unclear how and when a recipient receives formal notice sufficient to meaningfully exercise its appeal rights. The document also does not define what constitutes “government interests”.
Publication Costs Made Unallowable — This is a direct alignment with the proposed OMB rule, which would reverse the previous default and make publication costs (including APCs/open access fees) generally unallowable unless required by statute or approved case-by-case. This is one of the more controversial cost-principle changes (see psge 7).
Gold Standard Science Section Is Thin and Non-Operational -- the guidance around gold standard science remains thin. There is no operational framework for how these expectations will be evaluated, no additional review criteria, no scoring guidance, and no clear process for determining whether a proposal or award actually meets the standard (see page 140).
Civil Rights and Equity Requirements Removed -- the revisions to Guide 19 remove references to several civil rights and equity-related requirements that previously appeared in NSF policy. Specifically, the GFA eliminates mentions of obligations tied to revoked executive orders on non-discrimination, limited English proficiency, and environmental justice. It also drops references to longstanding U.S. Department of Education requirements that institutions of higher education maintain Section 504 coordinators (disability), Title IX coordinators (sex discrimination), and conduct age discrimination evaluations. While these changes do not repeal the underlying federal civil rights statutes themselves (such as Title VI, Title IX, Section 504 of the Rehabilitation Act, or the Age Discrimination Act), they have practical and signaling effects (see page 8).
Agency Guidance Subordinated to the OMB Proposed Rule -- in essence, the guidance conforms itself to the proposed rule and ultimately subordinates agency specific guidance to 2 CFR 200.
Stand Up for Science Foundation is actively mobilizing the scientific community, especially higher education institutions, to engage in the public comment period and to contact their members of Congress to prevent OMB from further advancing the Administration’s politicization of science through NSF.
Head to the SUFS Action Center: https://fight2win.standupforscience.net
Questions? Email Irene Ngun at irene@standupforscience.net