UC Comment Letters

This comment letter responds to the U.S. National Science Foundation (NSF)'s proposed Guidance on Financial Assistance (GFA), which would replace the current Proposal and Award Policies and Procedures Guide (PAPPG). The University of California (UC) urges NSF not to finalize the draft guidance in its current form, expressing concern that it introduces significant policy changes affecting merit review, international collaboration, research security, publication and data-sharing requirements, indirect cost recovery, award administration, and termination authorities. UC recommends substantial revisions to preserve merit-based funding decisions, support international scientific collaboration, maintain allowable research dissemination costs, protect award stability and institutional flexibilities, reduce administrative burden, and provide a transparent, prospective implementation process.