Comment on FR Doc # 2026-12725 from Lynne Mofenson MD
AnonymousOpposeIndividual
Summary: The commenter opposes the proposed NSF policy changes, arguing that they prematurely align with an unfinalized and litigated OMB regulation. They express concern that the proposal bypasses public comment requirements and allows political appointees to influence grant selections without sufficient scientific expertise or oversight.
I am writing to oppose the proposed changes to NSF policy. The alignment of NSF policy with the proposed OMB regulation (2CFR 200) is premature. This OMB proposed regulation has received almost 300,000 comments that need to be addressed before it is implemented; it has multiple provisions that have ongoing litigation. This NSF proposal appears to have been patched together quickly to get it in the system to “comply in advance” with the proposed OMB regulation before it has even been litigated. This is very disturbing - the NSF proposal should not be a mechanism to go around the requirement for the OMB proposal to respond to public comment. Yet it clearly is doing that by implementing something that has not been approved/finalized yet – so if the OMB regulation does not go forward, NSF is a way to go around the process and will have put it into effect anyway!
One of the most problematic parts of this rule is allowing the final grant selection to be determined by political appointees with no expertise in the subject matter area, with no mechanism for oversight and public accountability. Peer expert review ensures that the US government supports the best science. The leadership of the United States in science has been largely owed to independent scientific research free of any political agenda.
The suspension and termination guidance explicitly states it “aligns with the proposed revisions to 2 CRF 200. This skips the normal notice process it is unclear how a r4ecipients received formal notice sufficient to exercise appeal rights. What constitutes “government interests” is not defined.
There is no definition of “gold standard science” either in this proposal or the OMB proposal. It lacks an operational framework around how expectations will be evaluated, reviewed, scored or any process for how a proposal or award will meet this undefined standard.
This proposal to alter the grant-making and approval process politicizes the process of research and should not be allowed move forward.