Agency Information Collection Activities; Proposals, Submissions, and Approvals: National Science Foundation Proposal/Award Information Guidance on Financial Assistance

gener8tor, a company supporting high-growth startups and university spinouts, argues that the current eligibility language for for-profit entities is too ambiguous and creates barriers to commercialization. They recommend explicitly including for-profit organizations that demonstrate a commitment to research commercialization and incorporating an analysis of indirect cost rates to ensure efficient use of funds.

The Stand Up for Science Foundation opposes the proposed National Science Foundation Guidance on Financial Assistance (GFA), arguing that it imposes sweeping regulatory controls and significant economic burdens on institutions of higher education without sufficient statutory authority. They request the withdrawal of the proposal until a thorough regulatory impact analysis is conducted and the agency clarifies how it will navigate various executive orders and OMB regulations.

The American Anthropological Association supports the National Science Foundation's transition to the Guidance on Financial Assistance but requests a detailed "crosswalk" comparison between the old and new policies to ensure transparency. They also recommend that the new guidance specifically recognize the unique data stewardship needs of anthropological research, support community-based partnerships, and include discipline-inclusive examples.

A condensed matter physicist opposes the proposed transition to the new draft GFA, arguing that it is premature to link NSF rules to pending OMB revisions that are subject to litigation. The commenter also highlights concerns regarding the lack of clear termination criteria, the creation of an unfunded mandate for publication costs, and the inclusion of vague executive orders.

Dr. Charles Weidner, a chemist, opposes the proposed National Science Foundation Guidance on Financial Assistance (GFA), arguing that it creates excessive administrative "red tape" and significant economic burdens on research institutions. He recommends withdrawing the GFA until the full economic impact of the new requirements can be properly identified and evaluated.

An NSF-funded researcher provides specific feedback on the draft GFA, requesting the removal of contradictory language regarding publication costs and the inclusion of a net burden estimate for new requirements. The commenter also requests more clarity on termination and risk assessment procedures and seeks clarification on the inclusion of AI-related research misconduct requirements.

A scientist commenting in an individual capacity opposes the draft NSF Guidance on Financial Assistance (GFA). The commenter argues that the GFA is premature, exceeds statutory authority, underestimates administrative costs, removes civil-rights protections, and creates significant risks for international collaboration and research stability.

The commenter opposes the proposed OMB regulatory requirements, arguing that they will hinder scientific progress, increase administrative costs, and undermine the United States' position as a global leader in innovation. They express concern that political oversight will interfere with expert peer review and that the regulations may deter talented scientists from pursuing careers in the U.S.

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.