NSF Proposes Replacing the PAPPG with the Guidance on Financial Assistance (GFA)

Overview

The National Science Foundation (NSF) is proposing a significant change to the policy framework that governs how researchers and institutions apply for and manage NSF funding. The agency is currently accepting public comments on a draft Guidance on Financial Assistance (GFA) through August 24, 2026, and has stated a goal of implementing a final version in early to mid fiscal year 2027. Fiscal year 2027 begins on October 1, 2026.

The Proposal and Award Policies and Procedures Guide (PAPPG) would be replaced by the GFA. While NSF has described the effort primarily as a modernization and reorganization of its financial assistance guidance, the draft also contains proposed policy revisions affecting several areas of proposal preparation, compliance, research security, and award administration.

What Is Changing?

For many years, the PAPPG has served as NSF’s primary source of guidance on proposal preparation and award administration.

According to NSF, the proposed GFA is designed to make financial assistance policies easier to find, understand, and keep current. The agency cites user feedback, topic-based organization, plain-language revisions, and policy modernization as key drivers behind the effort.

NSF states that the GFA will:

• Separate policy and procedural information.
• Reorganize content by topic area.
• Remove non-policy language and improve readability.
• Use plain-language revisions where appropriate.
• Provide downloadable PDF versions of the guides.

The draft GFA organizes content into multiple topic-based guides covering different stages of the proposal and award lifecycle. Each guide generally includes definitions, policies, and procedures related to a specific topic area. The draft also notes that guides contain references to relevant statutes, regulations, executive orders, and other governing authorities.

The Proposal Involves More Than Reorganization

Much of NSF’s public messaging has focused on improving usability and organization. However, the draft GFA is not solely a restructuring of existing guidance.

According to the draft materials and supporting documentation, the proposal also incorporates revisions affecting areas such as research security, disclosure and reporting requirements, financial management, biosafety oversight, institutional certifications, and award administration. The draft also incorporates requirements linked to more recent federal policies, regulations, and executive actions.

Because the draft spans more than 200 pages and covers a broad range of proposal and award topics, institutions may wish to evaluate both the structural changes and any substantive policy revisions that could affect their operations.

How the Proposed GFA Differs from the PAPPG

According to NSF, the proposed GFA would reorganize proposal and award guidance into topic-based guides rather than relying on a single comprehensive document. The agency also indicates that the new structure would separate policy and procedural information, incorporate plain-language revisions, and include references to governing statutes, regulations, executive orders, and other authorities where applicable.

In practice, the proposed GFA would reorganize information into topic-based guides, provide greater separation between policy and procedural content, and incorporate references to relevant governing authorities. According to NSF, these changes are intended to improve navigation and readability while making guidance easier to maintain over time.

The draft remains subject to revision based on public feedback before any final version is issued.

Why NSF Says the Change Is Needed

NSF describes the transition as part of a broader effort to improve usability and accessibility.

According to NSF, user research identified areas where users experienced difficulty locating or interpreting information. The agency says the proposed framework is intended to improve navigation, organization, readability, and access to current policy information.

NSF also notes that financial assistance policies undergo public review as part of requirements associated with the Paperwork Reduction Act.

Questions and Concerns Raised by Stakeholders

In commentary shared during the public comment period, some members of the research community have highlighted aspects of the proposed structure they believe warrant additional consideration.

For example, University of Pittsburgh bioengineering professor TK Kozai noted in a LinkedIn post that the draft GFA places greater emphasis on references to statutes, regulations, executive orders, and other governing authorities. He argued that users may need to pay closer attention to changes in referenced authorities over time rather than relying solely on periodic updates to a single guidance document.

Kozai also suggested that the proposal formalizes a broader move toward the use of supplemental notices and ongoing policy updates. These observations represent stakeholder perspectives shared during the public comment period and do not reflect NSF’s stated rationale for the transition.

Kozai suggested that this approach could make it more important for users to monitor changes in external authorities referenced by the GFA. He also argued that the proposal reflects a broader movement toward using supplemental notices and ongoing updates rather than relying on periodic editions of the PAPPG.

NSF’s current public comment process provides stakeholders an opportunity to submit feedback on these and other aspects of the proposed framework before the guidance is finalized.

Why This Matters

The proposed changes affect the structure and organization of NSF proposal and award guidance that researchers, research administrators, sponsored programs offices, and compliance professionals use to support proposal development and award management.

In addition to the organizational changes, the draft includes proposed revisions affecting multiple policy areas. As a result, institutions may wish to review both the structural framework and any policy changes that could affect proposal preparation, compliance activities, or award administration.

Because the proposal remains under review, the public comment process provides an opportunity for the research community to provide feedback before NSF finalizes the guidance.

What Happens Next?

NSF has outlined a phased implementation approach. Following the current comment period, the agency plans to:

• Review and evaluate submitted comments.
• Continue refining the draft GFA.
• Publish an additional 30-day public comment opportunity before finalization.
• Conduct outreach and communications activities with stakeholders once the guidance is finalized.

Implementation Timeline

NSF has outlined a phased approach for developing and implementing the GFA. According to the agency:

• The draft GFA has been released for public review.
• The current public comment period remains open through August 24, 2026.
• NSF plans to review submitted comments and refine the draft guidance.
• An additional 30-day public comment period will be provided before the guidance is finalized.
• Once finalized, NSF plans to conduct outreach and communication activities with stakeholders.
• NSF has stated that its goal is to implement the updated GFA in early to mid fiscal year 2027.

NSF has emphasized that comments are open to the public and that researchers, faculty, staff, students, professional associations, institutions, and other interested parties are welcome to submit comments anonymously.

What Researchers and Research Administrators Can Do Now

Individuals and organizations that work with NSF funding may wish to:

• Review the draft GFA.
• Watch NSF’s overview webinar on the proposed transition.
• Discuss potential operational impacts within research administration, sponsored programs, and compliance functions.
• Submit comments before the August 24, 2026 deadline if there are elements of the proposal they believe NSF should consider.

As NSF continues the review process, feedback from researchers, research administrators, and institutions will help inform the agency’s refinement of the proposed Guidance on Financial Assistance.