Comment on FR Doc # 2026-12725 from Marianna Zhang

I am a postdoctoral researcher in psychology at New York University. As a scientist and citizen, I am writing to express my strong opposition to the proposed replacement of NSF's PAPPG, as I believe the new policy will inflict great harm on scientific research and the welfare of Americans more broadly. I was surprised to learn that the proposed Guidance on Financial Assistance (GFA) includes changes not only to align the PAPPG with Executive Orders, but also with newly proposed changes to 2 CFR 200. OMB's proposed changes to 2 CFR 200 have been met with largely negative response in an incredible number of public comments. Changes to align NSF with these merely proposed changes to 2 CFR 200 seem hasty and premature, as such changes have yet to be finalized. I won't repeat my comments regarding 2 CFR 200 (), but will focus on specific details of the proposed GFA below. First, the proposed GFA disallows publication costs in Guide 12 in order to align w proposed revisions to 2 CFR 200. Although many criticisms can be made of the current structure of the scientific publishing industry, such publication costs include open-access fees, which critically allow scientific research to be shared with the public. Disallowing such fees will not only slow down scientific progress, by hampering scientists from sharing their research with each other, but also impede the ability of Americans to learn about the very scientific progress that their taxpayer money funds. Second, I also object to the additional termination provisions in Guide 25, specifically that NSF may immediately suspend or terminate an award when NSF believes such action is "necessary to protect the interests of the government" and that no notice of non-compliance and corrective action plan would be issued in such a case. The threat of immediate termination at any time on the basis of "protecting the interests of the government" introduces a vague and threatening sword of Damocles that would hang over every grant. Immediate and abrupt terminations especially harm early-career scientists, whose livelihood directly depends on continued flow from their advisors' grant funding, and who may leave scientific research forever upon a gap in funding. For example, some of NSF's postdoctoral fellowships disburse stipend quarterly or bimonthly - terminations in such fellowships last year caused postdocs (including myself) to scramble to find other funding with just months or even just weeks of notice. I know many talented postdocs who, not finding other funding in sufficient time, have left science forever after such a termination. These changes would codify such terminations, causing losses early in the scientific pipeline that could seriously hamper scientific progress in the US for decades to come. More broadly, such a threat would seriously chill scientific research in the US, even beyond those directly affected by a termination, by introducing political considerations into scientific research. What is considered "the interests of the government" may change with every administration, but scientific projects often require long-term commitment beyond the timespan of a single administration. In my field of developmental psychology, where data collection from children can be logistically complex and long-term, it is common for a single research project to span years. Even if a project does conform to the present administration's goals, the risk of a potential termination by a future administration may deter scientists from proposing bold but long-term and high-risk ideas, the very ideas that hold the greatest potential for scientific advancement and societal benefit. I urge you to reject these proposed changes that would further inject political influence into our merit-based scientific research system that has benefited and continues to benefit Americans so tremendously.