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 The University of California (UC) urges NSF not to finalize the draft guidance in its current form, expressing concern that it introduces significant policy changes affecting merit review, international collaboration, research security,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.
This comment letter responds to the National Science Foundation’s request for comments on proposed government-wide common disclosure forms for biographical sketches and current and pending support. UC supports standardized forms as a means of reducing administrative burden but recommends limiting agency-specific exceptions, simplifying certification requirements, harmonizing definitions and submission requirements across agencies, and allowing sufficient time and technological support for implementation.
This comment letter responds to the National Science Foundation (NSF)'s proposed revisions to the Proposal and Award Policies and Procedures Guide (PAPPG). The University of California (UC) generally supports the proposed updates but expresses concern that expanded Current and Pending Support and Biosketch requirements would increase administrative burden, create ambiguity regarding disclosure obligations, and lack consistency with other federal agencies. UC recommends greater federal harmonization, development of a common disclosure system, clearer definitions and accountability standards, and implementation approaches that reduce burden on researchers and institutions.
