Comment on FR Doc # 2026-12725 from gener8tor Management, LLC

Public Comment Draft: NSF Guidance on Financial Assistance (20260624) Prepared by gener8tor 1. Introduction gener8tor fosters innovation ecosystems through its accelerator programs, venture capital funds, and skills-based workforce initiatives. With a strong track record of supporting high-growth companies, gener8tor has expanded across the U.S. and internationally, building partnerships with governments, corporations, universities, and economic development organizations to drive entrepreneurship and economic impact. gener8tor operates accelerators across 48 cities and 26 states, working with more than 300 startups per year. To date, gener8tor has worked with more than 2,200 startups that have cumulatively gone on to raise more than $3B in financing and employ more than 15,000 people. We operate accelerator programs with multiple university tech transfer offices, including University of Alabama and UNLV, supporting 61 spinouts in 2025 and 71 YTD in 2026. We coach and guide teams on IP strategy, protection and negotiation, structure licenses and options with TTOs, and manage IP terms in sub-awards consistent with Bayh-Dole. The Wisconsin Alumni Research Foundation is an investor in gener8tor and an LP in many gener8tor funds. gener8tor is deeply interested in the NSF’s guidance on financial assistance because we bridge the gap between academic research and market commercialization. Our experience supporting hundreds of startups, including many university spinouts, distinguishes our perspective: we see firsthand how rigid eligibility structures can stifle the translation of critical technologies from lab to market. We believe clear, inclusive eligibility criteria are essential to fostering a robust pipeline of high-growth, mission-driven companies. 2. Background This comment pertains to the "Eligible Entities" section of the NSF Guidance on Financial Assistance. The current text states: "Institutions of higher education; nonprofit, non-academic organizations; and Indian Tribes are eligible to submit proposals. For-profit organizations, state and local governments, foreign organizations, and federal agencies may be eligible if a funding opportunity specifically allows it." 3. Analysis The current language creates ambiguity and potential friction for for-profit entities, which are often the primary vehicles for commercializing NSF-funded research. By making for-profit eligibility conditional on specific funding opportunities, the NSF introduces uncertainty that can deter applicants from even attempting to engage with agency programs. Agency Estimation: While the agency may intend to prioritize non-academic research to maintain a focus on basic science, this approach potentially overlooks the efficiency and speed that for-profit spinouts bring to scaling technologies. Unintended Consequences: The current phrasing may inadvertently create "eligible" and "ineligible" silos, preventing valuable public-private partnerships from forming at the grant-writing stage. Indirect Rates: Furthermore, to ensure taxpayer dollars are utilized effectively, the NSF should incorporate an analysis of an applicant’s indirect cost rates (or NICRA rates) during the evaluation process. Evaluating the ratio of indirect costs versus direct programmatic impact, ensuring more dollars go directly to the work, is a necessary oversight mechanism and consistent with the entrusting taxpayer dollars are being utilized in the most efficient manner. 4. Recommendations We recommend amending the "Eligible Entities" section to provide greater clarity and inclusivity for for-profit partners essential to commercialization. Suggested Amendment: "Institutions of higher education; nonprofit, non-academic organizations; Indian Tribes; and for-profit organizations that demonstrate a commitment to research commercialization are eligible to submit proposals. State and local governments, foreign organizations, and federal agencies may be eligible if a funding opportunity specifically allows it. To ensure efficient use of funds, the NSF will evaluate an applicant’s indirect cost rates as part of the financial review process to maximize the percentage of award funds allocated to direct project activities." 5. Conclusion In summary, the current eligibility language creates unnecessary barriers for for-profit entities that are vital to the NSF’s commercialization goals. By explicitly including for-profit entities and incorporating a review of indirect cost rates, the NSF will streamline its application process, improve financial efficiency, and better support the translation of fundamental research into real-world impact. We urge the NSF to adopt these changes to ensure a more dynamic and competitive research ecosystem.