Comment on FR Doc # 2026-12725 from Laura Osanitch
AnonymousOpposeIndividual
Summary: The commenter opposes the proposed changes to the National Science Foundation's proposal and award information guidance, specifically criticizing the "Expanded and Accelerated Termination Authority." They argue that the ability to suspend or terminate awards without notice or a corrective action plan creates a lack of clarity regarding a recipient's ability to exercise appeal rights.
I take offense to the changes to OMB's grant issue policies based upon the stance of Stand Up For Science. Among these are their notes on "Expanded and Accelerated Termination Authority -- the suspension and termination guidance explicitly 'aligns with the proposed revisions to 2 CFR 200' (see page 9). Under this guidance, NSF may immediately suspend or terminate an award 'to protect the interests of the government,' in which case it 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 a practical tension: if NSF skips the normal notice and cure process, it is unclear how and when a recipient receives formal notice sufficient to meaningfully exercise its appeal rights. The document also does not define what constitutes 'government interests'. "