Washington Update
NSF Proposes Sweeping Revision to PAPPG
By: Galen CobbThursday, July 16, 2026
The National Science Foundation (NSF) is proposing an overhaul of the Proposal and Award Policies and Procedures Guide (PAPPG), the document that provides guidance on how researchers apply for and manage NSF funding. As part of a broader information collection renewal, NSF has released a draft revision that would rename the PAPPG the NSF Guidance on Financial Assistance (GFA) and reorganize its 26 chapters into topic-based guides.
Many of the proposed changes pre-align NSF policy with revisions to the government-wide grants regulation, 2 CFR 200, that the Office of Management and Budget (OMB) has separately proposed. Additionally, the revision aligns with several Executive Orders (EOs), including EO 14332 “Improving Oversight of Federal Grantmaking,” EO 14303 “Restoring Gold Standard Science,” and EO 14292 “Improving the Safety and Security of Biological Research.” These changes alter NSF requirements and allowances across multiple areas. A selection of particularly relevant changes is summarized below; however, the full draft contains additional changes that may affect specific research programs or institutional processes.
Key Changes
- Public access timeline. The draft removes the current 12-month embargo on peer-reviewed articles and conference proceedings, replacing it with a requirement for immediate public access upon publication, including deposit of author-accepted manuscripts and underlying datasets in NSF's Public Access Repository.
- Publication costs. The GFA's summary of changes states that publication costs are disallowed. Budget instructions elsewhere in the draft continue to list page charges, reprints, and data deposit fees as allowable expenses.
- Research security. The draft codifies research-security training and risk-assessment requirements, updates Malign Foreign Talent Recruitment Program and foreign financial disclosure rules ($50,000 threshold), and pilots a new “TRUST” framework in place of NSF's prior return-without-review policy for security concerns. “Dual Use Research of Concern” is replaced with “Dangerous Gain of Function,” aligning with EO 14292.
- Scientific integrity. The draft adds a Gold Standard Science section reflecting EO 14303 and expands Responsible Conduct of Research training to cover research security, export controls, and disclosure.
- Award oversight and terminations. Funding recommendations would be routed through senior-leadership review and a grants-officer risk-based pre-award review, consistent with EO 14332. NSF's stewardship authority would expand to permit substitution or removal of a principal investigator, reduction of funding, or suspension or termination of an award, including in cases of “changes in priorities.”