Comment on FR Doc # 2026-12725 from Erin Ruml

I am here to offer comments on the Draft NSF Guide to Financial Assistance (NSF 27-1). I have worked in research administration for 15 years in university settings. I have worked with faculty to develop their proposals; I have reviewed and approved their expenditures to ensure they were reasonable, allocable, allowable, and consistent (and properly justified!); I’ve trained up new research administrators and new research faculty, ensuring that the institutions I work for have robust and knowledgeable researchers all doing science right. I’ve been around since before uniform guidance, since before research.gov, and since the PAPPG was two documents (the GPG and the AAG). I’m disappointed that the current federal plan is to use research funds as a weapon to stifle advancement and creativity. Incorporation of Executive Order 14303 NSF should remove all reference to EO 14303 Restoring Gold Standard Science. In fact, the EO should be rescinded immediately. This EO is political interference that threatens academic freedom and lets political appointees have too much control over the direction of research. It’s a poor use of NSF’s resources to start research that can be terminated at any time just because a non-scientist doesn’t like the results. It’s a shameful order and has no business existing much less being incorporated in federal assistance guidelines. Incorporation of OMB-2026-0034 This proposed revision to 2CFR200 Uniform Guidance would be disastrous to research. Again, the politicization of research turns it into a weapon to silence good scientists doing good work just because a political appointee finds the results inconvenient. We don’t need climate research killed because oil executives might lose money. We don’t need health research killed because the president’s buddy wants to pretend ivermectin is an antibiotic. We know the current president surrounds himself with grifters and conmen (and is in fact himself a grifter and conman). Additionally, this proposed rule would make it significantly harder for all scientists to publish and disseminate their research by disallowing a lot of historically ENCOURAGED costs. NSF has always advocated for open publication and I think was the first agency to require a data management and sharing plan. The best way to share ideas is to travel to conferences and publish. Those costs should always be allowable (or even be mandatory). Again, it’s a damn shame the current administration is so afraid of new ideas and wants to hide research results.