Comment on FR Doc # 2026-12725 from Anonymous
AnonymousOpposeIndividual
Summary: A federally-funded scientist opposes the proposed NSF Guidance on Federal Assistance, citing concerns over ambiguous language regarding the suspension and termination of awards. The commenter also argues that making publication costs unallowable will harm scientific research and innovation.
I am a federally-funded scientist working to determine how our cells function so that we can better inform our understanding of life and provide useful data for initiatives like computational models of cells. I am writing to express grave concern about some of the ambiguous language and non-allowable costs in the newly proposed NSF Guidance on Federal Assistance.
For ambiguous language, the suspension and termination guidance states that it "aligns with the proposed revisions to 2 CFR 200" such that NSF may suspend and terminate awards "to protect the interests of the government." What exactly "the interests of the government" are, and how these interests could be threatened are unclear. This would enable a substantial amount of abuse, as the NSF would not be required to issue a notice of non-compliance or provide an opportunity to correct any actions. Additionally, anyone could define "interests of the government" to mean anything. For instance, it could be decided that it is in the best interests of the government to not fund grants from states with certain laws or states whose electoral college delegates voted one way or another. It could be decided that it is in the best interest of the government to not fund specific universities, organizations, or classes of people for ambiguous reasons. This is a slippery slope.
For non-allowable costs, the cost of publishing NSF-funded research would be made unallowable, with limited exceptions. While it is true that some journals have excessive publication costs, many journals run by scientific societies have reasonable publication costs that cover the cost of paying editors and copyeditors without a large profit margin. By not allowing scientists to charge the cost of publication to their NSF grants, this would actively harm scientific research and innovation in the United States. The ability of scientists to share their findings with the scientific community and the taxpayers supporting this work would be significantly harmed.
I urge the NSF to make significant changes to the proposed Guidance on Federal Assistance. As written now, this guidance is rife for abuse and will actively harm the American scientific enterprise.