Understanding the proposed changes to NSF’s Proposal and Award Policies and Procedures Guide (PAPPG)
On June 24, 2026, the National Science Foundation (NSF) released a draft policy manual titled “Guidance on Financial Assistance (GFA)” updating its previous Proposal and Award Policies and Procedures Guide (PAPPG). The proposed changes would explicitly align the GFA with the widely-criticized revisions to federal grantmaking policy from the Office of Management and Budget (OMB). The comment period closed on August 24, 2026.
From APS leadership: Comment on Proposed NSF Guidance on Financial Assistance
APS expresses concern with NSF's pre-supposition of the outcomes of the government-wide federal rulemaking process regarding OMB revisions to the Uniform Guidance, and urges NSF to not incorporate the proposed revisions into the final Guidance on Financial Assistance.
Background on the NSF proposal
The National Science Foundation (NSF) has put forward a proposed update to its Proposal and Award Policies and Procedures Guide (PAPPG), now titled “Guidance on Financial Assistance” (GFA, Version 27-1). The PAPPG, now GFA, describes the policies and procedures for preparing and submitting research proposals, as well as the rules for managing and administering NSF financial assistance awards.
NSF states that the purpose of the update is to improve organization and clarity, while also aligning the guide with recent applicable Executive Orders and the proposed revisions to the Office of Management and Budget's (OMB) Uniform Guidance (2 CFR 200). The agency held a public comment period on the draft GFA, which is now closed.
APS has previously expressed significant concern with the proposed revisions to the OMB Uniform Guidance, including its potential harms to the grant review process, international collaboration, professional activities, and efforts to broaden participation in STEM.
During the comment period for the OMB rulemaking, APS members and supporters submitted over 4,700 unique comments, and we are now awaiting the administration's response. However, the NSF draft GFA pre-supposes the outcome of this rulemaking. Given that the GFA is deeply interwoven with 2 CFR 200, the harmful changes proposed by OMB would become part of NSF’s policies and procedures. The draft explicitly states that "The GFA does not address all requirements of 2 CFR 200. Proposing organizations and recipients must be familiar with and follow all applicable requirements at 2 CFR 200, whether or not discussed in the guides."
We include the concerning provisions from the OMB Uniform Guidance (2 CFR 200) that connect directly to sections of the GFA below. These bullets are updated with the relevant sections in the draft GFA and NSF-specific information.
Read the full draft guide
You can see the full draft Guidance on Financial Assistance online.
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