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Editorial · CASRAI · Compliance and regulatory

NSF Is Replacing the PAPPG: The Draft Guidance on Financial Assistance (GFA)

NSF deferred the planned PAPPG 26-1 revision and instead published a draft full replacement, the NSF Guidance on Financial Assistance (GFA), for public comment through Aug. 24, 2026. PAPPG 24-1 plus Policy Notices 26-200 and 26-202 remain current policy today.

Published 16 Aug 2026· 6 minute read

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Status as of August 16, 2026: The NSF Proposal & Award Policies and Procedures Guide (PAPPG) 24-1 remains NSF’s current, in-force policy today, as supplemented by two policy notices. NSF has deferred the planned PAPPG 26-1 revision and instead published a full draft replacement — the NSF Guidance on Financial Assistance (GFA) — for public comment. The GFA is not adopted policy. The public comment window closes August 24, 2026.

What is actually in force right now

Nothing described in this article changes what applies to a proposal or award today. As of this writing, NSF financial-assistance policy is governed by:

  • PAPPG NSF 24-1 — applies to proposals submitted or due on or after May 20, 2024, and remains the base document.
  • Policy Notice NSF 26-200 (Supplement 1), effective for financial assistance awarded on or after December 8, 2025 — amended specific sections of 24-1 covering SBIR/STTR Project Pitch requirements, review and return-without-review criteria, several proposal-type budget thresholds, the equipment tracking threshold, research-security provisions (including Confucius Institute contract eligibility and foreign financial disclosure), and additions to the research-misconduct definition. See CASRAI’s detailed breakdown of the 26-200 changes.
  • Policy Notice NSF 26-202 (Supplement 2), effective for financial assistance awarded on or after January 22, 2026 — among other things, tightened the public-access requirement for NSF-funded publications and underlying data, including the move to zero-embargo Author Accepted Manuscript deposit. See CASRAI’s guide to NSF-PAR and the end of the 12-month embargo.

Neither notice replaces PAPPG 24-1 outright; each amends specific sections and takes precedence only where it conflicts with the base document. Together, 24-1 plus these two supplements is the complete, current rulebook — not the draft GFA discussed below.

Why PAPPG 26-1 was deferred

NSF ordinarily reissues the PAPPG on a roughly annual cycle, and a 26-1 revision had been in development for planned publication in FY2026. NSF deferred that release. The reason NSF has given is Executive Order 14332, Improving Oversight of Federal Grantmaking, which directs the Office of Management and Budget (OMB) to streamline and reform the government-wide Uniform Guidance (2 CFR 200). Rather than issue an incremental 26-1 update that might be immediately out of step with a revised Uniform Guidance, NSF opted to hold PAPPG revisions and instead develop a restructured replacement document aligned to where OMB’s process is headed — continuing, in the meantime, to make necessary policy changes through supplemental Policy Notices like 26-200 and 26-202 rather than a full guide reissue.

What the draft GFA actually is

On June 24, 2026, NSF published a Federal Register notice (docket NSF-2026-OTR-0001) seeking public comment on a draft document titled the NSF Guidance on Financial Assistance. This is not a renamed PAPPG 26-1 — NSF has described it as a restructuring intended to:

  • Replace the PAPPG format entirely rather than issue another point revision of it.
  • Use plain language throughout.
  • Separate policy statements from procedural instructions, which the PAPPG has historically interleaved.
  • Remove policies NSF considers no longer relevant.
  • Incorporate mandated statutory, regulatory, Executive Order, and other policy-driven changes accumulated since 24-1, including alignment work tied to the Uniform Guidance streamlining referenced above.

NSF issued this as an Agency Information Collection Activities notice under the Paperwork Reduction Act (the mechanism NSF uses to solicit comment on the proposal/award information collection the GFA would govern), not as a final rule. NSF posted a subsequent draft revision to the same document in July 2026, meaning the text under review has itself been updated since the original June 24 posting — another reason to treat this as an active, moving draft rather than settled text.

Draft, not adopted — what that means in practice

Until NSF formally adopts and issues a final version, PIs, research offices, and sponsored-programs staff should keep working from PAPPG 24-1 plus Policy Notices 26-200 and 26-202. Do not cite the draft GFA as current policy in a proposal, an internal procedure document, or a compliance training, and do not assume any specific provision in the draft will survive unchanged into the final version — that is precisely what the comment period exists to test. NSF has not announced an effective date for a final GFA; based on the deferral of 26-1 pending Uniform Guidance alignment, institutions should not expect the replacement to take effect on the PAPPG’s usual annual cycle.

How to submit a comment before August 24, 2026

Comments on the draft NSF Guidance on Financial Assistance are accepted through Regulations.gov under docket NSF-2026-OTR-0001:

  1. Go to regulations.gov/docket/NSF-2026-OTR-0001.
  2. Open the draft document and comment-submission link for the notice (posted under docket item NSF-2026-OTR-0001-0001, with the comment form at NSF-2026-OTR-0001-0002).
  3. Submit comments in writing through the Regulations.gov web form before the close of the comment period.

Deadline: written comments must be submitted by August 24, 2026 to be considered as part of this notice-and-comment period. Research offices, sponsored-programs associations, and individual PIs are all eligible to comment; comments on Paperwork Reduction Act information-collection notices like this one are a standard, legitimate channel for institutions to flag operational concerns — for example, provisions that would be difficult to implement, ambiguous procedural language, or a policy/procedure split that doesn’t match how an office’s workflow is actually organized.

What to watch for after August 24

After the comment period closes, NSF will review submitted comments (as with any PRA information-collection notice) before finalizing the document. There is no published date yet for a final GFA or for a related Federal Register notice announcing adoption. Research administrators should watch for: a follow-up Federal Register notice announcing the collection’s OMB approval and any associated effective date, updates to nsf.gov/policies/pappg, and NSF’s own Policy Office communications. CASRAI will update this article and its PAPPG dictionary entry if and when a final version is adopted.

Frequently asked questions

Is the PAPPG being replaced right now?

Not yet. NSF has published a draft replacement (the GFA) for public comment, but PAPPG 24-1 plus its two supplemental Policy Notices remains the operative policy as of this writing. The GFA does not take effect by virtue of being published for comment.

What happened to PAPPG 26-1?

NSF deferred it. Instead of issuing an annual 26-1 revision, NSF held that release — citing Executive Order 14332’s directive for OMB to streamline the Uniform Guidance — and is instead developing the GFA as a full restructuring rather than an incremental update.

Does the draft GFA change any current funding thresholds, deadlines, or requirements?

Not on its own. Until adopted, it has no legal effect. Current thresholds and requirements are still those in PAPPG 24-1 as amended by NSF 26-200 and NSF 26-202.

Who can submit a public comment?

Anyone. Comments on a Paperwork Reduction Act information-collection notice are open to institutions, associations, and individuals; research administration offices and PIs are a natural, informed constituency to weigh in given the GFA would directly govern how their institutions propose for and manage NSF awards.

Where can I read the draft text itself?

NSF has posted the draft document publicly (NSF republished a revised draft in July 2026); the associated Federal Register notice and the comment form are both reachable from the NSF-2026-OTR-0001 docket on Regulations.gov linked above.

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