Agency Information Collection Activities; Proposals, Submissions, and Approvals: National Science Foundation Proposal/Award Information Guidance on Financial Assistance

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.

The American Anthropological Association supports the National Science Foundation's transition to the Guidance on Financial Assistance but requests a detailed "crosswalk" comparison between the old and new policies to ensure transparency. They also recommend that the new guidance specifically recognize the unique data stewardship needs of anthropological research, support community-based partnerships, and include discipline-inclusive examples.

A former senior government official and research scientist opposes the proposed changes, arguing that the guidance is based on non-final OMB rules and will lead to the politicization of award decisions. The commenter contends that these changes will create bureaucratic bottlenecks, increase costs for submitters, and damage the quality of scientific research and international competitiveness.

A university professor and NIH-funded laboratory head opposes the proposed NSF changes, arguing that they increase administrative burdens and politicize the peer review process. The commenter asserts that these changes will demoralize reviewers and grantees, potentially harming U.S. scientific leadership.

The commenter opposes the National Science Foundation's proposal to update its Proposal and Award Policies and Procedures Guide. They argue that the changes align with efforts to politicize research funding, threaten scientific independence, and impose unnecessary regulatory control over higher education institutions.

The commenter opposes the proposed NSF guidance, arguing that it imposes excessive regulatory control, economic impacts, and threats to academic freedom and independent science. They characterize the information collection as a gross overreach of the agency's authority.

The commenter opposes the NSF's proposal to align its grantmaking rules with OMB's Regulation for Federal Financial Assistance. They argue that the proposal represents a gross overreach of authority that threatens scientific independence, academic freedom, and evidence-based decision-making.

The commenter, a professional with a background in international arbitration, labor law, and public health, opposes the proposed regulations and NSF alignment. They argue that the proposal subjects scientific grants to political oversight, restricts international collaboration, and imposes burdensome regulations that stifle academic freedom and evidence-based research.

A postdoctoral researcher at New York University opposes the proposed Guidance on Financial Assistance, arguing that it prematurely aligns with unfinalized 2 CFR 200 changes and disallows publication costs. The commenter also expresses concern that new termination provisions based on "protecting the interests of the government" could chill scientific research by introducing political instability and harming early-career scientists.

Erik Dienemann, a retired senior director at Merck & Co., Inc., opposes the NSF's proposal to align grantmaking rules with OMB's Regulation for Federal Financial Assistance. He argues that the proposal constitutes a gross overreach of authority that threatens scientific independence, academic freedom, and evidence-based decision-making.