TOO BAD. The National Science Foundation put up a Request for Information (RFI) about their implementation plan in the event that the OMB proposed changes go into effect: NSF-2026-OTR-0001

You can expect a one-pager about the changes from me in a couple days, including my top-lines for the math community, like the removal of references to fixed-price awards. The overview (straight from the NSF docket) is below.

Here’s my thinking on your next steps, friends:

• If you are a professional society, you went all-in (I hope!) on the OMB docket. Therefore:

  • It makes sense to adopt a defensive strategy (meaning, you defend your time and energy) by not commenting in-depth on “second dominoes.”

  

  • The OMB changes are the first domino and the NSF changes are the second domino in a domino run. If the OMB domino doesn’t fall, the NSF domino (hopefully) doesn’t either.¹
  • If we’re lucky, there won’t be more first dominoes---I don’t feel lucky, do you?
  • RECOMMENDATION: If I were you, my comment on the NSF RFI would simply be “Please see Comment ID…” with your tracking number. Even if your comment hasn’t been screened and posted yet, the tracking number will persist when it is posted.

• If you are an individual and you have more to say about NSF’s proposed changes because they feel more personal to you than all of 2 C.F.R. 200, then I think it makes sense to submit a short comment on the RFI with the problems you see in the proposed text.

What’s in the docket?

The file with the changes in it is 203 pages long. Here’s the summary cut-and-paste so you can gird your loins before heading to the docket and reading the whole damn thing.

Overall Document Changes

The NSF Guidance on Financial Assistance (GFA) replaces the NSF Proposal and Award Policies and Procedures Guide (PAPPG) (version 24-1). The GFA enhances use for proposers and recipients of NSF grants and cooperative agreements by:
- Aligning NSF policy with applicable Executive Orders, including EO 14222, Implementing the President's "Department of Government Efficiency" Cost Efficiency Initiative; EO 14332, Improving Oversight of Federal Grantmaking ; and EO 14303, Restoring Gold Standard Science.
- Aligning with the proposed revisions to the Office of Management and Budget's (OMB) Uniform Guidance at 2 CFR 200 through the proposed rule published on May 29, 2026 (see 91 Fed. Reg. 32, 198, May 29, 2026).
- Streamlining financial assistance policies and procedures to reduce administrative burden and eliminate duplicative content.
- Distinguishing policies from procedures to improve clarity and usability.
- Organizing content by topic rather than by chapter to improve access to information.
- Using plain language to improve readability and accessibility.
- Distinguishing responsibilities for different users (e.g., Principal Investigators, Authorized Organizational Representatives, and Sponsored Project Offices).

I have some questions about some of the summary information related to changes to the individual guides within the PAPPG, like this one:

Guide 9. Proposal Withdrawals, Declinations, and Appeals

Removes the rationale to return a proposal without review solely because it presents a potential research security concern based on credible national security information. It pilots the Trusted Research Using Safeguards and Transparency (TRUST) framework as an alternative risk mitigation approach.

I don’t know enough about the TRUST framework to understand this change yet!

And obviously this is pretty bad:

Guide 19. Discrimination, Sexual Assault, and Harassment

[…]

Removes references to U.S. Department of Education requirements for institutions of higher education to maintain Section 504 coordinators, Title IX coordinators, and age discrimination evaluations.

Back-of-the-envelope, I would say about 30-50% of the proposed changes are related to 2 C.F.R. 200 changes. Many of the others are tied to Executive Orders, and need a minute to think through how to convey, “Don’t put EO stuff in the PAPPG, put it in a separate annex to make version control easier when EOs get revoked!”