Comment on FR Doc # 2026-12725 from Walter Moos

Draft NSF Guidance on Financial Assistance - Public Comment Docket No. NSF 2026 OTR 0001 Information Collection 3145 0058 I strongly support NSF's mission and submit these comments in my personal capacity. My perspective reflects multiple parallel leadership roles since the 1980s, including more than three decades on the faculty of a major west coast medical center, leadership at a major nonprofit research institution, four decades as a biopharmaceutical executive, a decade as a venture capitalist and service on public, private, government, for profit and nonprofit advisory boards over several decades. The U.S. research enterprise depends on merit review, continuity, institutional diversity, responsible stewardship and flexibility to pursue discoveries whose importance cannot always be predicted. (Summary of Changes - Overall Document Changes) NSF should not implement substantive provisions derived from an OMB proposed rule before that rule is final. Premature adoption could force universities and nonprofit institutes to revise systems, budgets, training, compliance procedures and subaward agreements multiple times. NSF should distinguish binding requirements from contingent provisions tied to pending OMB action, retain current policies where the corresponding OMB provision is not final and provide an additional comment period after OMB finalization. (G13 - Scientific Integrity: Gold Standard Science) Transparency, reproducibility, communication of uncertainty, unbiased peer review, responsible data management and conflict disclosure are sound principles. NSF should clarify whether Gold Standard Science principles are review criteria, compliance requirements or nonbinding guidance; what evidence applicants must provide; who will assess compliance; and how standards will vary across basic, exploratory, observational, computational, translational and applied research. Scientific peer review should remain the primary basis for evaluating intellectual merit and broader impacts. Administrative review may address legality, security, conflicts and compliance, but should not replace expert judgment with political or policy preferences. Any override of merit review recommendations should identify its legal or published programmatic basis. (G25 - Suspension and Termination; G26 - Appeals) Allowing termination of compliant awards because of later changes in agency priorities would create serious instability. Institutions hire personnel, support trainees, purchase equipment, establish collaborations and begin multiyear experiments in reliance on federal awards. Abrupt termination can waste prior federal investment and disproportionately harm early career investigators and organizations without large unrestricted reserves. Termination unrelated to recipient performance should be narrowly limited and include written notice, an opportunity to respond, impartial appeal, payment of allowable obligations and reasonable wind down support. NSF should define "changes in priorities" and "interests of the government" and consider modification, transfer, partial suspension or negotiated closeout before termination. (G12 - Publication Costs; G4 - Other Direct Costs; G23 - Publication of Award Materials) Requiring immediate public access while disallowing publication and data deposition costs is inconsistent. Article processing charges, repository fees, data curation, accessibility preparation and related expenses are real and vary across disciplines. Institutions differ in their ability to absorb them, creating inequities unrelated to scientific merit. NSF should permit reasonable publication and repository expenses needed to disseminate NSF funded results and comply with NSF policy. (G4 - Indirect Costs; G12 - Cost Principles and Allowability) The 15 percent de minimis indirect cost rate may benefit organizations without negotiated rates, but it should remain optional and should not become ceilings for institutions with federally negotiated rates. Indirect costs support laboratories, utilities, cybersecurity, libraries, research administration, compliance, data protection and facilities maintenance. Reducing reimbursement does not eliminate these costs; it shifts them to institutions, states, students, donors or other sponsors. NSF should continue to recognize negotiated rates and should not use an institution's rate as a proxy for efficiency or scientific merit. (G14 - Research Security) Research security requirements should be risk based, clearly defined, harmonized across agencies and focused on identifiable risks. NSF should reduce duplicative disclosures, allow good faith corrections, distinguish inadvertent errors from intentional nondisclosure and protect legitimate international collaboration. NSF should preserve merit review, award stability, negotiated indirect cost rates, reasonable publication costs and proportionate research security rules. Respectfully submitted, Walter H. Moos PhD Submitted in a personal capacity