Â鶹Çø

Agency Information Collection Activities: Comment Request; National Science Foundation Proposal/Award Information-NSF Guidance on Financial Assistance—Information Collection 3145-0058 (Docket ID: NSF-2026-OTR-0001)

Dear Mr. Stone,

On behalf of Â鶹Çø, thank you for the opportunity to comment on the proposed changes to the NSF Guidance on Financial Assistance. Â鶹Çø is a scientific society and scientific publisher with more than 38,000 members in the U.S. and around the world. 

While Â鶹Çø supports the stated goals of improving the clarity and relevance of NSF guidance, Â鶹Çø is concerned that the proposed changes prematurely integrate elements of the proposed OMB Regulation for Federal Financial Assistance before it is finalized. Â鶹Çø has requested that OMB withdraw the proposed rule, and we request that NSF withdraw this proposed guidance until the wide-ranging concerns regarding the draft OMB Regulation for Federal Financial Assistance are addressed. 

Provisions of the OMB rule that are repeated in the NSF guidance, such as prohibiting grantees from using federal funds to cover publication costs and allowing early termination of grants based on political decisions, will negatively impact individual researchers and the research community. These provisions will pass the cost of publishing onto individual researchers and potentially compromise scientific integrity by making researchers hesitant to share results for fear of their grants being canceled. 

The proposed NSF guidance also includes the requirements of Executive Order (EO) 14292—Improving the Safety and Security of Biological Research, stating that NSF will not fund research that would lead to dangerous gain of function and that NSF will review and assess proposals with potential dangerous gain of function research. The lack of clarity in the guidance regarding how these decisions are made may lead to a de facto ban on any gain of function research, thereby impeding basic research to understand pathogens and develop medical countermeasures and vaccines, as well as developing treatments for chronic diseases like cancer and autoimmune diseases. Under this EO, federal agencies have terminated grants despite scientific disagreement about whether the research in question constitutes dangerous gain of function. These grant cancellations have slowed research making tuberculous less virulent to identify weaknesses of the tuberculous virus and develop treatments.

Further, the , released in July 2026, appears to ban standard, safe research practices, such as procedures to make pathogens weaker and less suited to infect humans and animals and using genetic screening tests to identify traits that stop viruses from spreading. As NSF develops implementation guidance for this policy, we strongly encourage you to engage the scientific and research communities that will be most affected by these changes. Our members are eager to engage with policymakers to develop policies that ensure the highest standards of safety and security while not impeding the development of medical countermeasures.

Thank you for the opportunity to respond to this agency guidance. Â鶹Çø requests that NSF delay implementing provisions of the OMB proposed grants rule until this rule is finalized. If you have any questions or would like to further discuss these comments, please contact Nicole Zimmerman, Senior Federal Affairs Officer, at nzimmerman@asmusa.org.

Thank you,

Stefano Bertuzzi, Ph.D., MPH
Chief Executive Officer, Â鶹Çø