Comment on FR Doc # 2026-12725 from Kim Westervelt

This new proposal is a follow-up to OMBs proposed rule on grant funding and is just as alarming for the potential to harm scientific research integrity, funding stability, and independence in the US. We should be focused on improving oversight of federal grantmaking, cost efficiency, and Gold Standard Science to advance innovation, not aligning funding with political whims, banning international collaborations and restricting communications and publishing. Specifically: 1. The suspension and termination guidance (see page 9) aligns with the proposed revisions to 2 CFR 200 which means that under this guidance, NSF may immediately suspend or terminate an award to protect the interests of the government, and is not required to issue a notice of non-compliance or provide an opportunity for a corrective action plan. While Guide 25 still points recipients to a post-decision dispute process in Guide 26, this accelerated pathway creates an issue - if NSF skips the normal notice and cure process, how and when would a recipient receive formal notice sufficient to meaningfully exercise its appeal rights. The document also does not define what constitutes government interests. 2.The alignment of this proposal to the OMB proposal making publication costs unallowable would reverse the previous default and make publication costs (including APCs/open access fees) generally unallowable unless required by statute or approved case-by-case. As outlined on page 7, this is a controversial cost principle change. 3.Other requirements in this document impose significant economic impacts on grantees and adds extensive regulatory control of institutes of higher education via information collection. This is a serious overreach of agency authority to regulate speech and academic freedom at independent universities. 4.Additionally, as outlined on page 140, guidance around gold standard science is vague. There is no operational framework for how expectations will be evaluated, no additional review criteria, no scoring guidance, and no clear process for determining whether a proposal or award actually meets the standard. 5.When it comes to Civil Rights and non-discrimination, it appears that Civil Rights and Equity Requirements that previously appeared in NSF policy have been deleted (see page 8). Requirements that would normally be included in this type of document such as non-discrimination, limited English proficiency, and environmental justice. References to longstanding U.S. Department of Education requirements that institutions of higher education maintain Section 504 coordinators (disability), Title IX coordinators (sex discrimination), and conduct age discrimination evaluations have also been dropped. This could cause problems with underlying federal civil rights statutes themselves (such as Title VI, Title IX, Section 504 of the Rehabilitation Act, or the Age Discrimination Act) that should be followed. Please take note of these potential problems and do not approve this proposal.