Note: I had hoped to get this to you sooner, but life got a little extra life-y. If you know folks thinking deeply about the changes to the NSF PAPPG, please connect me with them! -Courtney

After reading some (but not all) of the proposed changes to the PAPPG (currently NSF 24-1), my big takeaway is that the proposed replacement, NSF 27-1, is a hot mess to try to untangle. Whether intentional or not, the reorganization from "Chapters" to "Guides" obscures many of the large changes to the text of the PAPPG and makes it easy to hide big deletions (jump to the bottom for an example). These changes are not, in my opinion, adequately described in the summary of changes.

At the very highest level, I noticed references to NSF visions and values that support basic science funding have been cut from the text. Consider this omission alongside

• the changes to the agency's funding portfolio (X-labs taking billions of the budget, partnering with DARPA with more of the budget, disbanding SBE entirely);
• the unclear projected outlay from OMB; and
• the politicization of grant policies by OMB in its recent docket;

and it starts to look like there's a particular niche the administration wants NSF to fill as a slush fund for preferred industry partners. Science be damned.

MOTHERFUNCTOR's Toplines

1. A giant reorganization of the PAPPG is proposed into topical guides instead of chapters. Even if this is a good change, there's a lot of other stuff happening in the proposed changes at the same time. So, at least for me, it has becoming an obscuring factor when trying to mentally calculate the diff in the current version (NSF 24-1) and this proposed version. (Particularly irksome to me is that a Guide could be suggested to have "no changes" in the summary of changes when the current PAPPG has no Guides! Only Chapters!)

   If you want my best attempt at a redline, you can see what I put together over at the MOTHEFUNCTOR LLC workbench.

   MF Topline: NSF should prepare an annotated markup of NSF 24-1 to clarify what language will remain versus what language will be struck.

2. The massive update (including renaming!) of the PAPPG is being undertaken by an agency that is supposed to be run by a Senate-confirmed Director (role currently vacant) and the National Science Board (recently made vacant). The changes are responsive to proposed revisions to grants policies in general by OMB, which should be the work of the Controller of the Office of Federal Financial Management (role currently vacant).

   2a. At the rate at which OMB is clearing/posting comments, it cannot meet its own timeline for final rulemaking while observing the law. More on that here, thanks to Christopher Steven Marcum and Abigail Haddad!

   MF Topline: NSF should withdraw any proposed changes related to OMB-2026-0034 hypothetical changes at this time. In particular, NSF should keep references to fixed-cost grants at this time.

   2b. Parts of the NSF proposed changes are responsive to DOGE, which has produced no public accounting of its effectiveness or utility (and maybe never will).

   MF Topline: NSF should withdraw any proposed changes responsive to DOGE at this time. 2. Some changes are very reasonable and timely, like clarifications to comply with law. These are fine and should be proposed separately.

3. Executive Orders do not carry the force of law, so it seems unwise to weave them directly into the changes.

   MF Topline: NSF should withdraw the proposed changes and, only after a Senate-confirmed Director and a reconvened National Science Board have had ample time to be involved in the process, propose a separate annex of policies related to Executive Orders.

Reading between the lines

You can learn a lot about an organization by what it says about itself. For example, in NSF 24-1, the introduction says a lot. In the proposed revision, all of this text has been cut:

Introduction:

A. About the National Science Foundation The National Science Foundation (NSF) is an independent Federal agency created by Congress in 1950 to "promote the progress of science; [and] to advance the national health, prosperity, and welfare" by supporting research and education in all fields of science and engineering.

From those first days, NSF has had a unique place in the Federal Government: it is responsible for the overall health of science and engineering across all disciplines. In contrast, other Federal agencies support research focused on specific missions such as health or defense. The Foundation also is committed to ensuring the nation's supply of scientists, engineers, and science and engineering educators.

NSF recognizes the unique lived experiences of individuals from communities that are underrepresented and/or underserved in science, technology, engineering, and mathematics (STEM) and the barriers to inclusion and access to STEM education and careers. NSF highly encourages the leadership, partnership, and contributions in all NSF opportunities of individuals who are members of such communities supported by NSF. This includes leading and designing STEM research and education proposals for funding; serving as peer reviewers, advisory committee members, and/or committee of visitor members; and serving as NSF leadership, program, and/or administrative staff. NSF also highly encourages demographically diverse institutions of higher education (IHEs) to lead, partner, and contribute to NSF opportunities on behalf of their research and education communities. NSF expects that all individuals, including those who are members of groups that are underrepresented and/or underserved in STEM, are treated equitably and inclusively in the Foundation's proposal and award process.

NSF encourages IHEs that enroll, educate, graduate, and employ individuals who are members of groups underrepresented and/or underserved in STEM education programs and careers to lead, partner, and contribute to NSF opportunities, including leading and designing STEM research and education proposals for funding. Such IHEs include, but may not be limited to, community colleges and two-year institutions, mission-based institutions such as Historically Black Colleges and Universities (HBCUs), Tribal Colleges and Universities (TCUs), women's colleges, and institutions that primarily serve persons with disabilities, as well as institutions defined by enrollment such as Predominantly Undergraduate Institutions (PUIs), Minority-Serving Institutions (MSIs), and Hispanic Serving Institutions (HSIs).

"Broadening participation in STEM" is the comprehensive phrase used by NSF to refer to the Foundation's goal of increasing the representation and diversity of individuals, organizations, and geographic regions that contribute to STEM teaching, research, and innovation. To broaden participation in STEM, it is necessary to address issues of equity, inclusion, and access in STEM education, training, and careers. Whereas all NSF programs might support broadening participation components, some programs primarily focus on supporting broadening participation research and projects. Examples can be found on the NSF Broadening Participation in STEM website.

Instead, you will find:

NSF is a federal agency created through an Act "to promote the progress of science; to advance the national health, prosperity, and welfare; [and] to secure the national defense." NSF funds research and education in most fields of science and engineering. It does this through grants and cooperative agreements to institutions of higher education, K-12 school systems, for-profit organizations, informal science organizations and other research organizations throughout the U.S.