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A Crosswalk Between OMB and NSF Proposed Rules on Grantmaking

The Office of Management and Budget (OMB) has proposed revisions to its Uniform Guidance under 2 CFR 200, which sets government-wide standards for federal financial assistance. Simultaneously, the National Science Foundation (NSF) has issued draft updates to its Proposal and Award Policies and Procedures Guide (historically called the PAPPG now renamed the Guidance on Financial Assistance or GFA). These two policies work together because the Uniform Guidance establishes the overarching regulatory framework that the National Science Foundation must implement within its specific agency grant terms and conditions.

These proposed policy frameworks intersect directly with core equities surrounding public access to federally-funded research and data. The NSF proposal references these equities by incorporating data management requirements that align with federal public access plans and by eliminating the traditional twelve-month publication delay for peer-reviewed journal articles and conference proceedings. At the same time, the broader OMB proposal introduces rules affecting cost considerations for scholarly publishing, specifically making publication costs like article processing charges unallowable under direct costs unless approved in advance (and some confusing language that may prevent journal subscriptions under indirect costs).

Public participation is critical even if comments are ignored by this Administration (they may help inform a future Administration’s actions and can amplify the distress signal to members of Congress). As of publication of this blog post, there were nearly 70,000 public comments about the OMB rule received and 40K had been published. Comments are due July, 13th). I’ve yet to submit my own (stay tuned!). Comments on the NSF’s GFA proposal under are due by August 24, 2026. There are only 3 published comments to the NSF proposal as of today. I suggest commenting early and often. You don’t need to submit a detailed, expert comment to make your voice heard. You can simply state your concern in plain language. Commenting helps improve the public record on a proposed rulemaking and is an important tool for participatory democracy.

Submit comments here:

CrossWalk

I’ve read both proposals carefully. For full transparency, I had privileged access earlier versions of both 2 CFR 200 and the GFA revisions in my former role at OMB. I was also a contributor to the 2024 revisions of the Uniform Guidance and reviewed the previous iteration of the GFA too. When I left OMB in July of 2025 the Uniform Guidance in 2 CFR 200 internal revisions included:

At that time of my departure, the version I last saw had practically everything else remaining in tact. There was some back-and-forth between career and political officials about certain cost-principles (at some point, there was a bizarre prohibition on using indirects to support things like libraries at Unis which was thankfully struck from early drafts). There was also a strong intent by career staff to do a comprehensive regulatory impact analysis (RIA) with full economic benefit/cost considerations. Political appetite for that appears to have waned as the released version of the RIA is thin on actual economic details.

Because the two documents work together with respect to things I care deeply about like public access to federally-funded research and data, I thought share my read of how the NSF and OMB policies compare to each other.

Award selection, merit and peer-review, and Administration priorities

One of the most widely discussed and consequential changes in the OMB rule concerns how discretionary awards are selected. Proposed § 200.202(a)(1)(iii) requires program design to align with administration policies and priorities. Proposed § 200.205(b) requires agency heads to designate senior appointees to conduct a pre-issuance review of all discretionary awards, ensuring proposals are consistent with applicable law, Federal agency priorities, and the national interest, and applying principles that include demonstrably advancing the President’s policy priorities, several substantive funding prohibitions, and commitments to Gold Standard Science. Proposed § 200.205(c) directs those appointees not to ratify or routinely defer to others’ recommendations. Proposed § 200.205(d) provides that peer-review recommendations remain advisory and are not to be treated as binding.

Technically, peer-review has always been fire-walled from funding decisions. Agencies have always had the discretion to ignore peer-review by funding proposals that were scored poorly, or not funding those that were scored highly, by review panels. What’s new here is the implication that all granting decisions undergo political oversight before being finalized. Much as been said about this aspect of the OMB proposal (I recommend the piece by Science Editor-in-Chief Holden Thorpe ).

The NSF GFA does not reproduce this framework as explicitly as is stated in 2 CFR 200. Its merit review guide (Guide 8) is described in the Summary of Changes as having no significant changes. It retains the Intellectual Merit and Broader Impacts criteria, describes a process in which a Program Director’s recommendation is approved by an NSF leadership official and then reviewed by a Grants Officer for financial, policy, and risk considerations, and states that award decisions are discretionary and consider NSF policies and priorities. The GFA does not reference senior appointees, the President’s policy priorities, or a pre-issuance review applying those priorities, and it does not state that peer-review is subject to oversight for alignment with administration or Presidential priorities. Because § 200.205 is a government-wide requirement, it would apply to NSF directly under 2 CFR 200 once final, but the GFA as drafted does not implement it. However, the GFA does repeatedly reference vague conditions that proposals will be reviewed in the context of “priorities.”

Gold Standard Science (GSS)

Both documents reference EO 14303 and Gold Standard Science, but in different ways. The OMB rule embeds Gold Standard Science in award selection through § 200.205(b)(5) to (7), directing agencies to favor institutions that demonstrate success in implementing it. The NSF GFA treats GSS as a scientific-rigor and integrity expectation in Guide 13 and as a driver of Data Management and Sharing Plan requirements in Guide 5. The NSF GFA does not explicitly apply GSS in its award principles but its invocation in the text implies it will likely guide political pre-issue grant review.

Nondiscrimination and funding prohibitions (e.g. DEIA prohibitions)

The OMB rule adds substantive funding prohibitions through § 200.205(b)(2), § 200.300(b), § 200.218, and § 200.219, covering racial preferences, DEIA practices that violate anti-discrimination law, gender ideology, child transition, disparate-impact liability, and viewpoint discrimination in event services. The NSF GFA Guide 19 retains general nondiscrimination on the bases of race, color, national origin, disability, sex, and age, and removes references to revoked Executive Orders, limited English proficiency, environmental justice, and certain Department of Education coordinator requirements. The GFA does not reproduce the OMB prohibitions. However, the rules would apply to NSF directly under 2 CFR 200 when the rule is finalized.

Award type and foreign or domestic scope

The OMB rule eliminates fixed amount awards and subawards (§§ 200.201(b), 200.333, 200.1, 200.101, 200.102). The GFA removes all fixed-price award references, which is a direct implementation. The OMB rule establishes a domestic-first framework for research and development awards and restricts foreign entities (§ 200.202(e)); the GFA implements an equivalent foreign-organization justification standard tied to the national interest. The OMB rule prohibits covered foreign collaborations (§ 200.220); the GFA addresses foreign-collaboration risk through its research security regime in Guide 14 rather than by restating that section. The OMB rule requires English-language announcements and applications (§ 200.111); the GFA removes limited-English-proficiency requirements, which is consistent with the new 2 CFR 200 proposal.

Integrity and disclosure

The OMB rule revises the conflict-of-interest provision (§ 200.112) to require disclosure of personnel employed by the awarding agency within the preceding two years; the GFA implements this near-verbatim in Guide 14, substituting NSF for the awarding agency. The OMB rule revises mandatory disclosures (§ 200.113), including a ten-day transmittal of OIG disclosures to the U.S. Attorney’s Office for the District of Columbia; the GFA addresses misconduct and disclosure in Guides 13 and 25 but does not reproduce that explicitly. I suspect that the NSF scientific integrity policy would be implicated here in some way but it is not clear

Cost principles

The OMB rule makes publication costs unallowable, including page charges and article processing charges (APCs), except where required by statute or approved in advance, while keeping printing costs allowable (§ 200.461). The GFA states that publication costs are disallowed and reflects the closeout exception, but its budget guidance in Guide 4 still lists page charges and reprints as allowable. This is an internal inconsistency in the GFA.

It is reassuring to see language in the GFA that invokes the policies set forth by the 2022 OSTP Public Access Memo (recast as being consistent with GSS) in Guides 5 and 21, respectively:

There has been some confusion about whether or not the OMB ban on APCs is inconsistent with agency public access policies that require immediate public access to federally funded research. Let me be absolutely clear: the 2022 OSTP Public Access Policy (i.e., the Nelson Memo) makes no reference to any business model. Federal agencies are free to implement the zero-embargo policy by asserting their Federal Purpose License (incidentally codified in § 2 CFR 200.315(b)) by requiring authors to deposit their author-accepted manuscripts in the agency repository (at NSF, it’s PAR at NIH it’s PMC, for instance).

Paying APCs is a business decision that publishers impose on authors - it’s entirely unrelated to agency policy per se. Some publishers have been acting in bad-faith to convince (and sometimes coerce) authors into paying APCs as the only way to comply with federal public access policies. They intentionally conflate open access with public access - open access is never mentioned in the Nelson Memo. Authors may choose APCs in order to publish their work as open access; or they may retain their rights to deposit their author-accepted manuscript in the agency designated repositories. If a publisher says that authors must pay a fee to deposit their own manuscripts, then that means they are tying their editorial decisions to their business model. The agencies’ Federal Purpose License preempts any agreement between authors and publishers because the author’s institutions agreed to the terms when they signed the funding contract with the agency.

However, that is not to say that there may be unintended consequences of not allowing APCs in direct grants. That’s been widely discussed in response to NIH’s proposal to cap APCs:

The GFA invokes the Federal Purpose License, which remains unchanged at § 2 CFR 200.315(b) in the OMB proposal:

To the extent permitted by law, the recipient or sub-recipient may copyright any work that is subject to copyright and was developed, or for which ownership was acquired, under a Federal award. The Federal agency reserves a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use the work for Federal purposes and to authorize others to do so. This includes the right to require recipients and sub-recipients to make such works available through agency-designated public access repositories.

Critically, the OMB rule does not change the de minimis indirect cost rate or modify indirects directly - however, there are indirect modifications of the indirect costs (zing!) because OMB made heavy revisions to Subpart E, which apply to both direct and indirect cost considerations. For example, OMB should clarify whether proposed revisions to § 200.454(b) regarding “costs of the recipient’s or sub-recipient’s subscriptions to business, professional, academic, and technical periodicals are unallowable” mean that Universities cannot use their indirects for libraries to pay for subscriptions to academic journals. A valid argument could be made for prohibiting academic journal subscriptions as direct costs but providing periodicals as a service to the entire University is an historical practice that makes no sense to prevent from flowing as indirect facilities and administrative costs.

The GFA’s 15% rate reflects the existing § 200.414. Additionally: the OMB rule adds an award-selection preference for institutions with lower indirect cost rates (§ 200.205(b)(3)) while the GFA does not adopt that preference directly and the OMB rule makes a narrow change to prior written approval (§ 200.407); the GFA updates its Prior Approval Matrix as a framework alignment.

An AI-Assisted Crosswalk of the Two Proposals

I asked Claude Opus 4.8 with high effort using the following prompt: to generate a crosswalk table:

Attached are two proposed federal rule changes. One is a proposed change to 2 CFR 200 by the Office of Management and Budget. The second is a proposed change to the NSF’s GFA. The two policies work hand in hand in how the NSF sets the terms and conditions of their grants, contracts, and awards. Your task is to do a complete and thorough crosswalk of the two proposed changes, evaluate whether and how the NSF GFA would implement the proposed 2 CFR 200 changes and if there are any deviations.

I then went through and checked that the cross-references were correct (I didn’t find any major issues) and added my own notes and analysis in the rightmost column. Use at your own risk!

Theme 1: Award selection, merit/peer-review, and alignment with priorities

# Policy change OMB 2 CFR 200 location and text NSF GFA location and text Notes
1 Program design must align with administration policies and priorities § 200.202(a)(1)(iii) (instr. 53): a Federal program must be designed with goals that “Align with administration policies and priorities.” Preamble A.5 and Section “200.202.” Guide 8 (“Proposal Processing and Merit Review”) retains Intellectual Merit and Broader Impacts (§ B). Guide 9: “Award of NSF assistance is discretionary,” with “program budget and priorities” as factors. Guide 8 §F: award abstract “articulate how the project serves the national interest.” Summary of Changes, Guide 8: “No significant changes.” GFA references discretionary awards and “NSF policies and priorities” but does not adopt full alignment with OMB’s proposal or its implications that political oversight is mandatory (see below).
2 Pre-issuance review by senior appointees; peer-review is advisory § 200.205(b) (instr. 55): agency heads “must designate one or more senior appointees to conduct a pre-issuance review of all discretionary awards” to ensure proposals are “consistent with applicable law, Federal agency priorities, and the national interest,” applying principles including that awards “demonstrably advance the President’s policy priorities.” § 200.205(c): senior appointees “must not ministerially ratify or routinely defer to the recommendations of others.” § 200.205(d): peer-review recommendations “remain advisory and are not…treated as de facto binding.” Preamble (§ 200.205 strengthens merit review and establishes pre-issuance review consistent with EO 14332). Guide 8 §A: Program Director recommendation “is approved by the NSF leadership official” before the Grants Officer. Guide 8 §F: recommendations “are reviewed by NSF leadership and then evaluated by NSF Grants Officers for financial, policy, and risk considerations.” No reference to senior appointees, the President’s policy priorities, the § 200.205(b)(2) prohibitions, or the “peer-review advisory/not binding” clause. Summary of Changes, Guide 8: “No significant changes.” OMB’s government-wide pre-issuance review and the political-priorities principles are absent from the GFA except vaguely referenced as “priorities”. However, it would apply to NSF directly under 2 CFR 200 once it is finalized.
3 Gold Standard Science (EO 14303) as an award principle § 200.205(b)(5)-(7) (instr. 55): applicants “should commit to complying with administration policies…respecting Gold Standard Science”; awards should include “a commitment to achieving Gold Standard Science”; for science grants, agencies “should prioritize institutions that have demonstrated success in implementing Gold Standard Science.” EO 14303 listed in authority citation. Guide 13 §D “Gold Standard Science” (p.140): defines the term and states NSF “expects the highest standards of scientific rigor, integrity and adherence to tenets of Gold Standard Science.” Guide 5: DMSP requirements “align with NSF’s Gold Standard Science Implementation Plan.” Summary of Changes, Guide 5 and Guide 13. GFA treats Gold Standard Science as a scientific-rigor and integrity expectation and a data-management driver, not as a senior-appointee award-selection principle.
4 Substantive funding prohibitions (DEI, gender ideology, child transition, disparate impact, viewpoint discrimination) § 200.205(b)(2) (instr. 55): awards must not fund racial preferences, “denial…of the sex binary,” illegal immigration, or “anti-American values.” § 200.300(b) (instr. 66): prohibits funding DEI/DEIA practices that violate anti-discrimination law, “gender ideology as defined in Executive Order 14168,” and child “transition.” § 200.218 (instr. 63): eliminate disparate-impact liability. § 200.219 (instr. 64): prohibit discriminatory event services. Guide 19 (“Discrimination, Sexual Harassment, and Assault,” p.173): general nondiscrimination based on “race, color, national origin, disability, sex, or age.” Summary of Changes, Guide 19: “Removes references and requirements to revoked executive orders, including certain non-discrimination, limited English proficiency, and environmental justice requirements,” and removes ED Section 504 / Title IX coordinator / age-evaluation requirements. GFA removes revoked-EO DEI/LEP/EJ content but does not reproduce the OMB DEI, gender-ideology, transition, disparate-impact, or event-services prohibitions. Of course,those would apply to NSF directly under 2 CFR 200 once finalized.

Theme 2: Award type, structure, and foreign/domestic scope

# Policy change OMB 2 CFR 200 location and text NSF GFA location and text Notes
5 Elimination of fixed amount awards and subawards § 200.201(b) (instr. 52): fixed amount awards “not permitted unless otherwise authorized by Federal statute”; § 200.333 (instr. 82): fixed amount subawards “also are not permitted”; § 200.1 (instr. 43.b) removes the definition; §§ 200.101, 200.102 remove references. Summary of Changes, Guide 1: “Removes references to fixed-price awards.” No fixed-price or fixed-amount award language remains in the GFA body (verified absence). These changes appear to be fully aligned between the two proposals.
6 Domestic-first framework for research and development awards § 200.202(e) (instr. 53): R&D awards must go to U.S./State/Tribal entities; foreign entities only where authorized or with a compelling interest “determined by the agency’s senior appointee”; “domestic-first framework”; international elements only if “in the national interest.” Guide 2 §C: foreign-organization funding must be “necessary and beneficial to U.S. research and education and in the national interest of the United States,” with factors mirroring § 200.202(e)(3). This is fully implemented in the GFA, however, the NSF does not reference the “senior appointee” determination.
7 Prohibition on covered foreign collaborations § 200.220 (instr. 65): Federal funds may not support collaborations with a “covered foreign country or covered foreign entity,” subject to exceptions. Guide 14 (“Research Security”): foreign disclosure, Malign Foreign Talent Recruitment Program restrictions, foreign-countries-of-concern provisions, foreign financial disclosure. Summary of Changes, Guide 14. NSF addresses foreign-collaboration risk through its research security regime; it does not reproduce § 200.220 verbatim.
8 English-language-only announcements and applications § 200.111 (instr. 49): all announcements, applications, and award information “must be in the English language.” Summary of Changes, Guide 19: removes limited-English-proficiency requirements. These are full aligned in the two proposals.

Theme 3: Integrity and disclosure

# Policy change OMB 2 CFR 200 location and text NSF GFA location and text Notes
9 Conflict of interest: disclose agency employment within preceding two years § 200.112 (instr. 50): disclose whether personnel who worked on the application or will work on the award “were employed by the awarding Federal agency during the preceding two years prior to application submission…for informational purposes.” Guide 14 “Former NSF Staff”: near-verbatim text, substituting “NSF” for “the awarding Federal agency.” Summary of Changes, Guide 3. This change is consistent between the two policies.
10 Mandatory disclosures of criminal/False Claims violations; OIG transmittal § 200.113 (instr. 51): prompt written disclosure of credible evidence of fraud, conflict of interest, bribery, gratuity, or False Claims violations; OIG disclosures “transmitted to the United States Attorney’s Office for the District of Columbia within ten days.” GFA addresses misconduct/disclosure in Guides 13 and 25; research misconduct under 45 CFR 689. GFA does not reproduce the § 200.113 USAO-DC transmittal mechanic.

Theme 4: Cost principles and allowability

# Policy change OMB 2 CFR 200 location and text NSF GFA location and text Notes
11 Publication costs unallowable § 200.461 (instr. 107): publication costs “(including page charges, article processing charges (APCs), or similar fees…) are unallowable” except where required by statute or approved in advance; printing costs allowable; closeout exception at (c)(2). Summary of Changes, Guide 12: “Disallows publication costs consistent with proposed revisions to 2 CFR 200.” Closeout treatment in Guide 11. But Guide 4 §B6.3 “Documentation and Printing (Line G2)” still permits “Reports, reprints, page charges and illustrations.” Inconsistent. Stated change and closeout treatment align with § 200.461, but Guide 4 still lists page charges as allowable.
12 De minimis indirect cost rate (15%) No change. Preamble Section IX: “OMB is not proposing updates to the indirect cost rate negotiation system.” § 200.414 not amended. 15% is the current rate. Guide 4 §B “De Minimis Rate”: “up to 15%” of MTDC. Summary of Changes, Guide 12: “consistent with 2 CFR 200” (no “proposed”). Current-rule. Not traceable to this rule.
13 Preference for lower indirect cost rates in award selection § 200.205(b)(3) (instr. 55): “preference for discretionary awards should be given to institutions with lower indirect cost rates.” Guide 4 indirect-cost guidance describes negotiated and de minimis rates; no award-selection preference for lower rates. The GFA refers back to NSF’s existing indirect cost-principles throughout the document.
14 Prior written approval framework § 200.407 (instr. 96): removes paragraph (d); adds (l) for § 200.454 memberships and subscriptions; general limitation that agencies “must not impose additional prior approval requirements without OMB approval.” Guide 11 §C “Changes to Projects that Require Prior Approval From NSF”; “NSF Prior Approval Matrix.” Summary of Changes, Guide 12. There is no one-to-one match to the narrow § 200.407 change.
15 Other cost-principle revisions (advertising/PR, conferences, memberships, selling/marketing, travel) §§ 200.421, 200.432, 200.454, 200.467, 200.475 (instr. 97, 100, 105, 108, 110). Guide 4 references several of these by section (for example, 2 CFR 200.432 for meals, 200.465 home office, 200.445 working-from-home, 200.475 airfare). The GFA partially incorporates this by reference. GFA incorporates 2 CFR 200 cost principles generally rather than restating each revision.

Theme 5: Property, termination, and structure

# Policy change OMB 2 CFR 200 location and text NSF GFA location and text Notes
16 Equipment management by States and Tribes § 200.313(b) (instr. 72): States and Indian Tribes manage and dispose of equipment under their own laws; other recipients follow (c) through (e). Guide 15 §2 “Title and Use of Equipment” (p.146): title “normally vests in the recipient upon acquisition unless the award specifies otherwise”; references 2 CFR 200.312-200.313. Summary of Changes, Guide 15: align with “current 2 CFR 200.313.” The single proposed change to § 200.313(b) is not specifically restated.
17 Termination and suspension at agency discretion § 200.340 (instr. 87): new (a)(2) discretionary termination where an award “does not effectuate program goals, Federal agency priorities, or the national interest”; exceptions for entitlement/formula/specified programs; § 200.101(d) makes § 200.340 govern non-statutory conflicts; § 200.339 revised (instr. 86). Guide 25 §A (p.197): “changes in priorities” listed as a termination reason; “Termination” defined by reference to § 200.201; suspension/termination “pursuant to a) 2 CFR 200.339 and 2 CFR 200.340.” Summary of Changes, Guide 25. The proposed policies are fully aligned here; this is the mechanism used by DOGE to justify their arbitrary canceling of government contracts in 2025 and now it’ll be codified in reg if the rule is finalized.
18 Regulatory status, effective date, and conflict precedence §§ 200.101(d), 200.102, 200.106, 200.110 (instr. 44-48): clarify that part 200 governs in non-statutory conflicts (subpart F and § 200.340), agency adherence to other subtitle A parts, and effective-date structure. Guide 1: “2 CFR 200 takes precedence over any requirements in the GFA,” citing 2 CFR 200.102. Aligned in principle per the GFA statement.
19 Definitions revised (§ 200.1) § 200.1 (instr. 43): revises “Federal award date,” “improper payment,” “PII,” “unobligated balance,” “compliance supplement,” “notice of funding opportunity”; removes “Fixed amount award” and “Protected PII.” Does not change “Indian Tribe.” GFA defines terms by reference to 2 CFR 200.1 throughout (for example, “Federal Agency,” “Local Government,” “Indian Tribe”). Summary of Changes, Guide 2: replaces “Tribal Nations” with “Indian Tribes,” align with “current 2 CFR 200.” It’s unclear whether any tribal consultation was done before the change from “Tribal Nations” to “Indian Tribes” were proposed.
20 Prohibition of certain telecommunications/surveillance equipment § 200.216 (instr. 62): retains prohibition on covered telecommunications and video surveillance equipment/services. Guide 4 covers the American Security Drone Act of 2023 (covered drones), a separate authority. Other authority. § 200.216 is not specifically mentioned in the GFA but GFA’s drone provision rests on statute, not § 200.216.
Updates:
  • June 30, 2026 — Fixed typo to state GFA invokes the FPL.

Tags: general government

Recommended Citation:
Christopher Steven Marcum (June 30, 2026). "A Crosswalk Between OMB and NSF Proposed Rules on Grantmaking." Open Evidence. https://doi.org/10.59350/jgh5j-ch105