Comment on FR Doc # 2026-12725 from Charles Weidner

Comment on NSF-2026-OTR-0001, NSF Guidance on Financial Assistance (GFA) Charles Weidner, Ph.D. I am a chemist that is concerned about the direction the current administration is taking in regulating federal grants and politicizing the process by which federal grants such as those provided by the NSF are provided for implementation of basic research critical to the national security needs of the United States. I have not been a recipient of any of these grants but have many colleagues who rely on these grants for conducting research, publishing and presenting research at or in scientific venues. This GFA will cause unnecessary economic consequences for grant recipients and their institutions of higher learning. Additionally, the grants are subservient to the whims of a political appointee who can terminate a grant for any reason- how can all awards be reviewed by a senior political appointee when the Foundation does not have any senior political appointees? For instance, when coupled with the requirements of the not-finalized OMB regulation (OMB-2026-0034) and other various requirements (including those found in National Security Presidential Memorandum 33), the information collection becomes a primary vehicle for regulating the behavior of higher education institutions and non-profit research organizations that rely on federal financial assistance. Consequently, the agency’s estimate of the burden of the proposed information, which assumes 120 hours expended for each proposal submitted, is in fact far greater, and should be treated instead as a regulation with significant economic impact. The estimate of 120 hours is not credible, especially when workload surveys from the Federal Demonstration Partnership suggests that 44.3% of researchers’ active time involves meeting administrative requirements as opposed to conducting research[1] The President’s executive orders, combined with the new requirements from the OMB regulation and the revisions to the GFA, create an excess of new red tape and institutional requirements. The Council on Government Relations (COGR) found that the implementation of the President’s executive order 14222, alone, created additional redundant checkpoints in the implementation of federal awards, resulting in an additional 53,734 hours of work, "simply to process payments to low-risk institutions for projects and costs previously approved by the agency[2]." As noted in the Federation of American Scientists’ comment on the Regulation for Federal Financial Assistance, based on the National Institutes of Health per-publication cost of $2,565-$3,104 per award and estimating between 5.7 and 6.9 publications per award, the potential additional financial burden placed on institutions by implementing the revised 2 CFR 200.461 would create an additional annual financial burden on research institutions of $125-185 million. The Council on Government Relations phase one survey of the cost of complying with research security disclosure requirements, likewise, estimated that the total compliance costs for mid-to-large size institutions with federal research funding over $100 million would be expected to spend an additional $51.5 million implementing research security requirements necessary to receive federal financial assistance from institutions like the National Science Foundation[3]. Because these institutions are reliant on federal financial assistance for their continued operations, this effectively transforms what is otherwise an information collection into a regulation with significant economic impact. I recommend that the GFA be withdrawn until these additional requirements, which are expected to create new and additional financial burdens for institutions reliant on federal financial assistance from the National Science Foundation, can be identified and evaluated given the additional economic impact they are expected to place on research institutions. [1]https://thefdp.org/wp-content/uploads/FDP-FWS-2018-Primary-Report.pdf [2]https://www.cogr.edu/blog/administrative-burden-defend-spend-ncura-magazine-december-2025 [3]https://www.cogr.edu/blog/research-security-and-cost-compliance-phase-i-report-disclosure-requirements-now-available