Comment on FR Doc # 2026-12725 from Stand Up for Science Foundation
Stand Up for Science FoundationOpposeAdvocacy
Summary: The Stand Up for Science Foundation opposes the proposed National Science Foundation Guidance on Financial Assistance (GFA), arguing that it imposes sweeping regulatory controls and significant economic burdens on institutions of higher education without sufficient statutory authority. They request the withdrawal of the proposal until a thorough regulatory impact analysis is conducted and the agency clarifies how it will navigate various executive orders and OMB regulations.
See attached file(s)
If Congress does not hide elephants in mouse holes, then it did not grant the National Science Foundation (NSF) the authority to implement sweeping regulatory control over American institutes of higher education (IHEs) through an information collection. From 1991 to December 2025, there have been 324 changes to administrative requirements associated with federal grants, with 66 percent of those requirements being issued in the past decade . Several provisions raise additional legal and practical concerns. Among other issues, the GFA removes requirements tied to statutory civil rights obligations under the Rehabilitation Act and Title IX, and proposed restrictions on international collaboration conflict with carveouts established in the CHIPS and Science Act.
Taken together, these measures transform a routine information collection into a regulation with significant economic impact, triggering both the analytical requirements of Executive Order 12866 and the major questions doctrine. NSF has not identified the statutory basis for imposing these sweeping behavioral and operational requirements on universities, nor has it conducted the necessary regulatory impact analysis. The proposal should be withdrawn.
There are also urgent matters of practical application that need to be addressed, like how the NSF intends to conduct political review of documents when there are no political appointees, and how and to what extent the requirements of the GFA also apply to awards granted using other transactions authority.