Comment on FR Doc # 2026-12725 from Melinda Rostal

I am a researcher that has been key personnel on NSF grants and has the PI of other Agency’s multimillion and multiyear grants. I fully disagree with these proposed rule changes made by the NSF (NSF-2026-OTR-0001-0003). First off, they are attempting to adopt rules that may change as the proposed changes to 2 CRF 200 comments are still under review, and the final rule hasn’t been released. The NSF risks putting out new regulations that are meant to be based on the OMB regulations and if OMB changes those rules these NSF rules could actually contradict the OMB guidance. This is an irresponsible change and should be retracted. I further think that it is irresponsible to change any policies that will impact the scientific output of NSF investments when all 24 members of the National Science Board (NSB) were fired in April (https://healthpolicy-watch.news/a-string-of-erratic-decisions-national-science-foundation-advisory-board-abruptly-dismissed/). These members need to be reinstated, and these policy changes must be approved by them. I further disagree with the 2 CRF 200 proposal to disallow scientists to use federal grant money to publish their research. The research has been paid for by the American people and therefore it needs to be published in an open-access, peer-reviewed journal that future science can be built on and any American can access. NSF scientists and the NSB, know very well the importance to making results available to build new research platforms and also inspiring new collaborative research to push the bounds of what science can do. By restricting the ability of scientists to be able to publish their results we will dampen this ability and the quality of the US science will degrade significantly. During the past 18 months we have seen the danger and waste created by terminating grants with no cause other than it no longer aligns with the President’s priorities. Cutting clinical trials short puts participants in risky situations. I know NSF funds few if any clinical trials. I also know that terminating a multi-year grant with no notice and prior to the planned analyses being completed, leads to wasted tax-payer money, wasted scientists’ time, wasted participant’s time and wasted wear and tear on expensive equipment that may have been used. In fact, a US court just ruled that agencies could not terminate grants because “It no longer aligns with the agency’s priorities” (https://www.insidehighered.com/news/government/science-research-policy/2026/07/21/agencies-cant-cite-changed-priorities-terminate). Please retract these rules and reinstate the NSB prior to developing new rules that affect the science of NSF.