On December 8, 2025, the National Science Foundation implemented NSF 26-200, a policy notice supplementing the current Proposal & Award Policies & Procedures Guide (PAPPG) 24-1. The supplement does not replace PAPPG 24-1 outright — it amends specific sections of the existing guide and takes precedence over the prior text wherever the two conflict, for proposals and awards on or after the effective date. This piece summarizes what actually changed; for PAPPG’s general structure and purpose, see CASRAI’s NSF Grants: An Overview guide and the PAPPG dictionary entry.
Why NSF issued a mid-cycle supplement
NSF periodically issues numbered supplements to a standing PAPPG edition rather than waiting for the next full biennial reissue, when a change is time-sensitive — typically because it implements a specific statutory deadline. Supplement 26-200 folds in several changes required by the CHIPS and Science Act of 2022 research-security provisions, updates a federal cost-threshold citation (2 CFR Part 200), and makes a number of process clarifications NSF had signaled informally in prior guidance. Some of the research-security items in this supplement were previously announced on their own timeline via NSF Important Notice No. 149; see CASRAI’s separate coverage of Notice 149 for that notice’s specific certification requirements — the two documents overlap on subject matter (research security, the Confucius Institute funding bar) but are formally distinct NSF issuances with their own numbers and, in places, their own effective dates.
What changed, effective December 8, 2025
Proposal process and review
- SBIR/STTR Project Pitch formalized. The supplement writes the Project Pitch step into the PAPPG as a required precursor before a Phase I or Fast-Track SBIR/STTR proposal can be invited — codifying a submission gate NSF’s SBIR/STTR program office had already been operating.
- Reviewer-minimum clarification. The guide clarifies that a full proposal must receive at least two reviews, and explicitly permits those reviews to be conducted by internal NSF staff rather than requiring both to come from external panelists.
- Return-without-review criteria. Proposals that do not contain sufficient substantive content to support a meaningful merit review may be returned without being sent out for external review at all.
- SBIR/STTR Phase I reconsideration removed. The supplement removes the prior reconsideration option for declined SBIR/STTR Phase I proposals.
Budget and funding thresholds
- Proposal-type funding caps raised. Planning proposals move from a $100,000 cap to $200,000; RAPID awards from $200,000 to $300,000; EAGER awards from $300,000 to $400,000.
- Equipment threshold raised. The dollar threshold for identifying and separately tracking equipment rises from $5,000 to $10,000, aligning PAPPG with the general threshold in 2 CFR § 200.313.
- Payment modernization. References to check payment are removed from the guide; the text now points recipients to electronic remittance through Pay.gov or the Treasury’s Credit Gateway.
Research security and foreign-influence provisions
- Confucius Institute funding bar. NSF funds may not go to an institution that maintains a contract with a Confucius Institute, unless the NSF Director grants a waiver — implementing CHIPS and Science Act Section 10339A.
- Foreign financial disclosure. Institutions of higher education must report foreign financial support of $50,000 or more from a “country of concern” on an annual basis.
- Research-security program requirements. The supplement incorporates the security-assessment and training-certification requirements tied to CHIPS and Science Act Sections 10337 and 10634 directly into PAPPG text (these were the subject of NSF’s earlier Important Notice No. 149).
- Drone procurement restriction. Effective a separate date of December 22, 2025, NSF funds may not be used to procure or operate unmanned aircraft systems manufactured by a Federal Acquisition Security Council-listed covered foreign entity, per the FY2024 NDAA’s Section 1821-1825 restriction.
Data, integrity, and property administration
- Public access to data at time of publication. Data underlying an NSF-funded publication must be made publicly available at the time that publication comes out, with any exceptions specifically justified in the award’s Data Management and Sharing Plan.
- Research-misconduct definition expanded. The definition of research misconduct is broadened to explicitly cover misconduct committed through the use of artificial-intelligence-based tools.
- Scientific-integrity language revised. Guide language is updated to emphasize inclusivity, transparency, and protection of the research record from inappropriate outside influence.
- Federally owned property reporting. The supplement sets out more detailed annual and final inventory-reporting obligations for federally owned property, tied to NSF’s Central Property Inventory Repository system.
- Tribal-entity terminology and eligibility. “Tribal Nations” is replaced with “Indian Tribes” throughout, and eligibility language is expanded to include Alaska Native entities recognized under the Alaska Native Claims Settlement Act.
What this means for proposal preparation right now
For a proposal or award dated on or after December 8, 2025, the supplement’s text governs wherever it conflicts with the base PAPPG 24-1 language. In practice that means: confirm your SBIR/STTR submission has an approved Project Pitch before drafting a Phase I or Fast-Track proposal; budget within the new Planning/RAPID/EAGER caps rather than the superseded figures; track equipment at the $10,000 threshold, not $5,000, for identification purposes; route any outstanding payment processes through Pay.gov or Credit Gateway rather than check; and, if your institution maintains a Confucius Institute contract or receives $50,000+ in reportable foreign financial support, coordinate with your research-security office well ahead of submission — several of these obligations sit with the institution’s Authorized Organizational Representative, not the individual PI. Research offices should also update any internal proposal-checklist templates that still reference the pre-supplement equipment threshold or budget caps, since those are common places outdated figures persist after a PAPPG change.
How this relates to PAPPG generally
PAPPG is NSF’s standing guide governing how proposals are prepared, reviewed, and administered once awarded — see CASRAI’s NSF PAPPG dictionary entry for the guide’s overall structure and the NSF Grants: An Overview guide for how PAPPG fits into the broader NSF proposal and award lifecycle. This piece covers only what Supplement 26-200 specifically changed as of December 8, 2025; it is not a general PAPPG explainer, and NSF may issue further supplements or a full guide reissue that supersedes some of the above — always confirm current requirements against NSF’s own PAPPG policy page before a submission deadline.
Source
This summary is drawn directly from NSF’s policy notice, “Implementation of Policy Changes to Proposal and Award Policies and Procedures Guide (PAPPG) 24-1, Supplement 1” (NSF 26-200), published at nsf.gov/policies/document/pappg24-1-supplement-1. Research offices should treat NSF’s own notice text, not this summary, as the authoritative source when preparing a specific proposal.
