NSF UPDATE: 26-200 Supplement Released to PAPPG 24-1

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Current Notice

NSF has released a policy supplement NSF 26-200 to PAPPG NSF 24-1, effective December 8, 2025, which takes precedence over existing guidance for all NSF grants and cooperative agreements awarded on or after this date. The changes align with federal priorities (including a new Executive Order on grant oversight) and update multiple sections of the current version of the PAPPG. The NSF is deferring the release of PAPPG 26-1 while the OMB updates the Uniform Guidance.

Supplement NSF 26-200 

Policy revisions

The following revisions, organized by PAPPG chapter, follow:

  1. SBIR/STTR Project Pitch Submissions (Chapter I.D)
    1. SBIR/STTR Project Pitch formally added as a proposal type; a Project Pitch invitation is now required before submitting SBIR/STTR Phase I or Fast-Track proposals.
  2. Tribal Organization Terminology (Chapter I.E)
    1. Terminology updated to “Indian Tribes” and clarified to better cover Native-owned lands.
  3. Proposer Limitations – Confucius Institutes (Chapter I.E)
    1. Confucius Institute restriction: NSF cannot fund IHEs that maintain a contract/agreement with a Confucius Institute. UCSF does not have a contract/agreement with a Confucius Institute. 
  4. Allowable and Unallowable Costs – American Drone Security Act (Chapter II.D)
    1. American Security Drone Act: NSF funds cannot be used (after Dec 22, 2025) to buy or operate drones from certain “covered foreign entities”. This is being reviewed for guidance. 
  5. Data Management and Sharing Plans (Chapter II.D)
    1. All data supporting NSF-funded publications must be publicly shared at the time of publication, with any exceptions justified in the DMS Plan. This is being reviewed for guidance to campus.
  6. Proposal Specific Revision Thresholds (Chapter II.F)
    1. Funding caps raised:
      1. Planning proposal: up to $200,000 TC/year (was $100k)
        1. RAPID proposal: up to $300,000 TC (was $200k)
        2. EAGER proposal: up to $400,000 TC (was $300k)

  7. Minimum Number of Reviewers (Chapter III.B)

    1. Full proposals must be reviewed by at least two reviewers (one may be an internal NSF staff member).
  8. Proposal Not Accepted or Returned Without Review (Chapter IV.B) 
    1. Proposals without sufficient content to permit effective merit review may be returned without review.

  9. SBIR Phase II Reconsiderations (Chapter IV.D)

    1. Reconsideration is no longer available for SBIR/STTR Phase II proposals.
  10. Foreign Financial Disclosure Report (Chapter VII.D)
    1. Certain higher-ed recipients must annually report foreign financial support from countries of concern, at the institutional main campus UEI level.
  11. Financial Requirements and Payments (Chapter VIII)
    1. Emphasis on electronic remittances and clarified handling of unexpended program income
  12. Research Security (Chapter IX.C) 
    1. New research security requirements and documentation expectations are added by reference to NSF Important Notice 149, including training and assessment obligations.
  13. Equipment-Related Thresholds (Chapter IX.E)
    1. Equipment threshold for possible federal title claim increased from $5,000 to $10,000 to align with the CFR. 

  14. Property Management Requirements for Federally Owned Property (Chapter IX.E)

    1. Expanded property management requirements for federally owned property
      1. Use of NSF’s Central Property Inventory Repository (CPIR)
        1. Annual and final inventory reports for Federally Owned Property ≥ $10,000 conducted every 2 years
        2. Biennial physical inventories.
  15. Scientific Integrity (Chapter XI.M)
  • Scientific integrity section revised to align with NSF Gold Standard Science framework by removing inclusivity.
  1. Research Misconduct (Chapter XII.C)
  • Research misconduct definition now explicitly includes misuse of AI-based tools in fabrication, falsification, or plagiarism.
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