CASC Comments on the Proposed NSF Guidance on Financial Assistance (GFA) Replacing the Proposal & Award Policies & Procedures Guide (PAPPG)

The Coalition for Academic Scientific Computation (CASC) respectfully submits these comments in response to the National Science Foundation's proposed “Guidance on Financial Assistance” (GFA), which would replace the Proposal & Award Policies & Procedures Guide (PAPPG) and align NSF award administration with the Office of Management and Budget's revised Uniform Guidance (2 CFR Chapter I).

CASC urges NSF not to finalize the GFA in its current form. As detailed below, the transition from the PAPPG to the GFA raises significant concerns about document stability, researcher and institutional rights, administrative burden, and the timing of new requirements relative to institutional review and data-management processes.