Guest Post by Peter Brass on the new NSF guidelines

Peter Brass is a prior NSF theory director. He has written an intelligent guest post on the new NSF guidelines that we present here.

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You have received many mails regarding the proposed OMB Uniform Guidance for federal grant making. It is a very long document. So far the OMB has received more than 32,000 comments, which nominally all will be read and taken into account, but actually most are general comments along the lines of “this will destroy scientific research,” and unspecific comments will achieve nothing. You can sample the comments, they are public, and you will be disappointed: much heat but no illumination.

It is my aim to bring a bit more content to the debate, and encourage you to file comments, but on specific issues, in my opinion primarily on the passage against “promoting anti-American Values,” which might indeed be a catch-all for political pressure on research. Otherwise there is little new: reviews were always only advisory.

The relevant section is https://www.federalregister.gov/d/2026-10817/p-amd-155, the revision of section 200.205, especially section (b) “pre-issuance review,” which states (underline and boldface mine):

(b) Pre-issuance review. As part of the merit review process, Federal agencies must perform pre-issuance reviews to ensure that Federal award proposals selected for funding are consistent with applicable law, Federal agency priorities, and the national interest. In doing so, Federal agencies heads must designate one or more senior appointees to conduct a pre-issuance review of all discretionary awards. As part of this pre-issuance review for discretionary awards, senior appointees (or their designee) must, as relevant and to the extent consistent with applicable law, apply the following principles when reviewing Federal award proposals:

This is followed by a list of criteria, but to summarize this: The agency head (a presidential appointment) designates a senior appointee (possibly a presidential appointment) who might designate another person inside the agency, who checks all intended awards that certain criteria are satisfied. This is not really different from the state before 2025: any proposal I proposed for award needed to be checked by the division director.

So if there is a problem, it must be in the criteria. It turns out there might be, depending on the interpretation.

1. Discretionary awards must, where applicable, demonstrably advance the President’s policy priorities.
   Whether this is applicable is the agency’s decision.
2. Discretionary awards must not be used to fund, promote, encourage, subsidize, or facilitate:
   • (i) Racial preferences or other forms of racial discrimination by the recipient, including activities where race or intentional proxies for race will be used as a selection criterion for employment or program participation;
   • (ii) Denial by the recipient of the sex binary in humans or the notion that sex is a chosen or mutable characteristic;
   • (iii) Illegal immigration; or
   • (iv) Any other initiatives that compromise public safety or promote anti-American values.
   That last one is a catch-all, which can indeed be used by politics to suppress research. This is the passage against which we should protest.
3. All else being equal, preference for discretionary awards should be given to institutions with lower indirect cost rates.
   All else is never equal, but it is in the program director’s discretion to consider how much funding actually reaches science.
4. Discretionary awards should be given to a broad range of recipients. Research grants should be awarded to a mix of recipients likely to produce immediately demonstrable results and recipients with the potential for potentially longer-term, breakthrough results, in a manner consistent with the notice of funding opportunity.
   I am quite happy about this explicit recognition of the importance of basic research.
5. In performing activities under Federal awards, applicants should commit to complying with administration policies, procedures, and guidance respecting Gold Standard Science.
   It is fairly unclear what Gold Standard Science is, but that seems to affect only lab or simulation sciences with results that are advisory to politics.
6. Discretionary awards should include benchmarks for measuring success and progress towards relevant goals and, as relevant for awards pertaining to scientific research, a commitment to achieving Gold Standard Science.
   Same. For us the benchmark measuring success is publication, so no news.
7. To the extent institutional affiliation is considered in making discretionary awards, agencies should prioritize an institution’s commitment to rigorous, reproducible scholarship over its historical reputation or perceived prestige. For science grants, agencies should prioritize institutions that have demonstrated success in implementing Gold Standard Science.
   No news either. We should not give extra credit to a proposal coming from a famous institution. Of course that is in the discretion of the program director.

(c) Procedure for pre-issuance review. When conducting a pre-issuance review, senior appointees (or their designee) must not ministerially ratify or routinely defer to the recommendations of others, but must instead use their independent judgment when evaluating Federal award proposals.

(so the designee should actually look at the proposal before approving the award)

(d) Use of peer review. Nothing in this part must be construed to discourage or prevent the use of peer review methods to evaluate proposals for discretionary awards or otherwise inform agency decision making, provided that peer review recommendations remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding by senior appointees or their designees. Further, nothing in this part must be construed to create any rights to any particular level of review or consideration for any funding applicant except as consistent with applicable law.

(good news: nothing changes)

(e) Agency discretion to reissue funding opportunities. A Federal agency is not required to issue a discretionary award as a result of a NOFO if doing so would fund low-quality proposals or be inconsistent with the principles of this part. The agency may, at its discretion, repost a funding opportunity.

(so the agency can decide not to make any award)

This is the entire section which causes so much outcries. I believe that the proposed budget cuts are a much larger danger to research than these recommended OMB rules.