AIBS has submitted comments on the National Science Foundation’s (NSF) draft Guidance on Financial Assistance (GFA), the document that would replace the Proposal and Award Policies and Procedures Guide (PAPPG 24-1) and govern how every NSF proposal is prepared, reviewed, and managed. AIBS welcomed much of the redesign: the topic-based organization, the plainer language, the removal of obsolete material. The central objection was that the draft is written to align with the Office of Management and Budget’s (OMB) proposed revisions to the Uniform Guidance, a rule that is not final. Comments on that proposal closed on July 13, and OMB has not issued a final rule.
As the comments put it: “Guidance that assumes the outcome of that rulemaking would treat the public comment now before OMB as a formality, and would carry into NSF’s own policies the features of that proposal most damaging to American science—political review in place of scientific merit, awards that can end when priorities shift, and new limits on how findings are shared.”
The letter identified several specific areas of concern, among them provisions that would allow political review of funding decisions, termination standards that could shift whenever the underlying regulation is amended without NSF proposing the change, a Summary of Changes that says publication costs are disallowed while the guides themselves treat them as allowable, and Dangerous Gain of Function provisions already overtaken by the government-wide policy issued on July 28.
AIBS asked NSF to withhold every provision that depends on the proposed rule, to retain current policy in the interim, and if and when OMB issues a final rule, to re-propose the affected sections for public comment.
Stay current on the latest science policy news. Subscribe to our bi-weekly AIBS Public Policy Report.