STM submission on NSF Guidance on Financial Assistance (NSF-2026-OTR-0001-0003)

In August 2026, STM submitted comments on behalf of its members in response to the NSF’s draft Guidance on Financial Assistance (GFA), which proposes to replace the Proposal and Award Policies and Procedures Guide (PAPPG). The submission expresses concern that the agency may be moving to implement elements of proposed OMB Uniform Guidance revisions before those changes have been finalised.

The submission urges NSF to recognise publication and dissemination as essential research activities, preserve support for publication-related costs, ensure sustainable implementation of public-access requirements, and maintain policies that strengthen expert merit review, international scientific collaboration, and the integrity of the scholarly record.