Policy Notice: Implementation of Policy Changes to Proposal and Award Policies and Procedures Guide (PAPPG) 24-1, Supplement 1

Issuance date

Dec. 8, 2025

Effective date

Dec. 8, 2025

Applies to

U.S. National Science Foundation (NSF) grants and cooperative agreements

Subject

Implementation of Policy Changes to Proposal and Award Policies and Procedures Guide (PAPPG) 24-1, Supplement 1

Purpose

This notice serves as a supplement to implement several revisions to NSF's Policy Changes for the Proposal and Award Policies and Procedures Guide (PAPPG). It takes precedence over existing policies and procedures set forth in the 24-1 version of the PAPPG for all financial assistance awarded on or after the effective date of this notice or the respective dates set in notices cited in this notice.

Background

The release of Executive Order 14332: Improving Oversight of Federal Grantmaking requires the Office of Management and Budget (OMB) to streamline and transform the Uniform Guidance. To ensure alignment with the Uniform Guidance, NSF will defer release of NSF 26-1 PAPPG, previously developed and planned for publication in Fiscal Year 2026.

While publication of the PAPPG has been deferred, NSF will continue to publish financial assistance policies to advance administration priorities, implement statutes, memorialize current practices, and implement other time sensitive matters. NSF will issue policy changes via NSF supplemental Policy Notices in the interim¹.

Policy revisions

The following revisions, organized by PAPPG chapter, follow:

1. SBIR/STTR Project Pitch Submissions (Chapter I.D)
2. Tribal Organization Terminology (Chapter I.E)
3. Proposer Limitations – Confucius Institutes (Chapter I.E)
4. Allowable and Unallowable Costs – American Drone Security Act (Chapter II.D)
5. Data Management and Sharing Plans (Chapter II.D)
6. Proposal Specific Revision Thresholds (Chapter II.F)
7. Minimum Number of Reviewers (Chapter III.B)
8. Proposal Not Accepted or Returned Without Review (Chapter IV.B)
9. SBIR Phase II Reconsiderations (Chapter IV.D)
10. Foreign Financial Disclosure Report (Chapter VII.D)
11. Financial Requirements and Payments (Chapter VIII)
12. Research Security (Chapter IX.C)
13. Equipment-Related Thresholds (Chapter IX.E)
14. Property Management Requirements for Federally Owned Property (Chapter IX.E)
15. Scientific Integrity (Chapter XI.M)
16. Research Misconduct (Chapter XII.C)

1. SBIR/STTR Project Pitch Submissions

Chapter I.D. is revised to incorporate a new proposal type for the Small Business Innovation Research/Small Business Technology Transfer (SBIR/STTR) Project Pitch to memorialize existing practices. The following underlined text is added:

• 5. SBIR/STTR Project Pitch

  The Project Pitch is the first step in the NSF SBIR/STTR submission process. The proposer must receive an official invitation via the Project Pitch process to submit an SBIR/STTR Phase I or SBIR/STTR Fast-Track proposal. Small businesses can submit one Project Pitch per submission deadline (refer to the latest SBIR/STTR Phase I or Fast-Track solicitation for upcoming submission deadlines). Project Pitches will be internally reviewed by a member of the SBIR/STTR team. Visit the program website, https://seedfund.nsf.gov/apply/project-pitch, for more information and instructions regarding submission of a Project Pitch.

2. Tribal Organization Terminology

Chapter I.E.1.c. clarifies the term "Tribal Nations" to "Indian Tribes" and clarifies eligibility to more thoroughly cover Native-owned lands. The following underlined text is added and strikes previous text:

• (c) Indian Tribes Tribal Nations – The term "Indian Tribe" "Tribal nation" means an American Indian or Alaska Native tribe, band, nation, pueblo, village, or community that the Secretary of the Interior acknowledges as a federally recognized tribe pursuant to the Federally Recognized Indian Tribe List Act of 1994, 25 U.S.C. §§ 5130- 5131. This definition also includes Alaska Native village or regional or village-corporation as defined or established pursuant to the Alaska Native Claims Settlement Act (P.L. 92-203; 43 U.S.C. § 1601 et seq.).

3. Proposer Limitations - Confucius Institutes

Chapter I.E.3 is modified to implement Section 10339A of the "CHIPS and Science Act of 2022." The following underlined text is added and strikes previous text:

• c. Other

  In accordance with Section 10339A of the CHIPS and Science Act of 2022 (42 U.S.C. § 19039), no NSF funds may be awarded to an Institution of Higher Education (IHE) that maintains a contract or agreement between the IHE and a Confucius Institute unless specifically approved in a waiver by the NSF Director. Please see NSF Important Notice 149 (section 6): "Updates to NSF Research Security Policies" issued by NSF on July 10, 2025.

4. Allowable and Unallowable Costs – American Drone Security Act

Chapter II.D.2.f (xiii) is supplemented with new coverage on the "American Drone Security Act of 2023." The following underlined text is added:

• (f) Unmanned Aircraft (Drones)

  The American Security Drone Act of 2023 prohibits use of NSF funds on or after December 22, 2025, to: (1) procure unmanned aircraft systems (drones) that are manufactured or assembled by a covered foreign entity; or (2) in connection with the operation of such a drone or unmanned aircraft systems. Prohibited sources of drones include entities identified on the Consolidated Screening List (see https://www.trade.gov/consolidated-screening-list) and entities from the People's Republic of China or subject to influence or control by the Government of the People’s Republic of China or the Communist Party of the People's Republic of China, as determined by the Secretary of Homeland Security (see https://smartpay.gsa.gov/resources/american-security-drone-act).

5. Data Management and Sharing Plans

Chapter II.D.2.i(ii) is revised as part of the agency's implementation of the public access requirements that align with NSF's Gold Standard Science Implementation Plan that further implements U.S. Office of Science and Technology Policy Memorandum, Agency Guidance for Implementing Gold Standard Science in the Conduct & Management of Scientific Activities. Per the tenets of reproducibility and transparency of Gold Standard Science, publications and supporting data are to be made publicly and freely available at the time of publication. A justification must be provided if there are any access limitations for supporting data. As a reminder, data management and sharing requirements and plans specific to the directorate or other NSF unit relevant to a proposal are available at www.nsf.gov/public-access. The following underlined text is added to the first paragraph of section (ii):

• Recipients are required to share all data supporting NSF funded publications at the time of publication. Exceptions to this sharing requirement should be described and justified within the DMSP.

6. Proposal Specific Revision Thresholds

Chapter II.F is modified to increase caps for Planning, RAPID and EAGER proposals in response to NSF community needs.

• Planning Proposal. Chapter II.F.1 increases the funding request threshold limit to $200,000 from $100,000. The following underlined text is added and strikes previous text:
  • Requests may be for up to $100,000 $200,000 per year (including indirect costs) and for up to two years in duration. The award size, however, will be consistent with the scope of the proposed planning activities and of a size comparable to planning grants in similar areas.
• Rapid Response Research (RAPID) Proposal. Chapter II.F.2 increases the funding request threshold limit to $300,000 from $200,000. The following underlined text is added and strikes previous text:
  • Requests may be for up to $200,000 $300,000 (including indirect costs) and up to one year in duration. The award size, however, will be consistent with the project scope and of a size comparable to grants in similar areas.
• EArly-Concept Grants for Exploratory Research (EAGER) Proposal. Chapter II.F.3 increases the funding request threshold limit to $400,000 from $300,000. The following underlined text is added and strikes previous text:
  • Requests may be for up to $300,000 $400,000 (including indirect costs) and up to two years in duration. The award size, however, will be consistent with the project scope and of a size comparable to grants in similar areas.

7. Minimum Number of Reviewers

Chapter III.B is revised to clarify that at least two reviewers must review a full proposal, one of which can be conducted internally by NSF staff. The following underlined text is added:

• The NSF guidelines for the selection of reviewers are designed to ensure selection of experts who can give Program Officers the proper information needed to make a recommendation in accordance with the NSB-approved criteria for selection of projects. Full proposals, unless excepted, must be reviewed by at least two reviewers, which can be conducted internally by NSF staff. Optimally, reviewers should have…

8. Proposal Not Accepted or Returned Without Review

Chapter IV.B is revised to clarify that a proposal will be returned without review if the proposer does not contain sufficient content to permit effective merit review. The following underlined text is added:

• 7.  is not responsive to the NSF funding opportunity or does not contain sufficient content to permit effective merit review

9. SBIR Phase II Reconsiderations

Chapter IV.D.2.b.(7) is revised to remove reconsideration for all SBIR/STTR proposals. The following underlined text is added:

• (7) Phase I proposals submitted under the Small Business Innovation Research (SBIR)/Small Business Technology Transfer (STTR) programs; and

10. Foreign Financial Disclosure Report

Chapter VII.D.3.a is revised to include new definitions to improve clarity, revisions to coverage on reporting of tuition, changes to report due dates, and use of information collection. The following underlined text is added:

• In accordance with Section 10339B, Foreign Financial Support, of the CHIPS and Science Act of 2022, (42 U.S.C. § 19040), each "recipient institution of higher education" must annually report all "current financial support, the value of which is $50,000 or more⁷⁰, including gifts and contracts, received directly or indirectly from a foreign source" which is "associated with a foreign country of concern" as defined in the PAPPG Introduction, Section D. This requirement applies only to direct recipients of NSF funding. The determination of a direct recipient of NSF funding is based on the entity receiving NSF awards through its own UEI. Satellite, branch, or regional campuses that are not direct recipients of NSF funding must report any financial support via the main campus of the IHE. This does not include entities that receive subawards or individuals that are the beneficiaries of the award.

11. Financial Requirements and Payments

Chapter VIII.D is revised for compliance with Executive Order 14247 Modernizing Payments To and From America's Bank Account by removing references to remittances made via checks.

Chapter VIII.D.2. adds the following underlined text and strikes previous text:

• When electronic remittances are not practical, checks shall be mailed to NSF, Attn. Cashier, 2415 Eisenhower Avenue, Alexandria, VA 22314. Contact the NSF Division of Financial Management at (703) 292-8280 for additional information. The NSF Award ID(s) and the reason for the return (e.g., excess cash, funds not spent, interest, part interest part other, etc.) should be included in any remittance submitted to NSF. The only exception to the requirement for prompt refunding is when the funds involved will be disbursed immediately. This exception for prompt refunding should not be construed as approval by NSF for a recipient to maintain excessive funds on hand contact NSF at (703) 292-8280 or at dfmpab@nsf.gov to discuss the specific circumstances. Exceptions to the electronic remittance requirement will only be considered under extraordinary or rare circumstances and will be considered on a case-by-case basis. The only exception to the requirement for prompt refunding is when the funds involved will be disbursed immediately. This exception for prompt refunding should not be construed as approval by NSF for a recipient to maintain excessive funds on hand.

Chapter VIII.D.4.c.(i). is modified by striking existing text and adding new text in underline below:

• Efforts should be made to avoid having unexpended program income remaining at the end date of the grant. Program income earned during the project period should be expended prior to requesting reimbursement against the grant. In the event a recipient has unexpended program income remaining at the end of the grant, it must be remitted to NSF by crediting costs otherwise chargeable against the grant. If it is not possible to record the credit via ACM$, the excess program income must be remitted to NSF electronically or by check payable to the National Science Foundation via Pay.gov or Credit Gateway at https://fiscal.treasury.gov/credit-gateway. (See section D.2. above for further information.)

12. Research Security

Chapter IX.C includes new coverage on Research Security Assessment and Required Recipient Documentation, includes requirements to maintain supporting documentation, and adds new coverage regarding the Research Security Training Requirements specified in sections 10337 and 10634 of the "CHIPS and Science Act of 2022" (42 U.S.C. §§ 1862o-1, 19040)). The detailed requirements are provided in the NSF Important Notice 149 (sections 1 and 2): "Updates to NSF Research Security Policies," issued by NSF on July 10, 2025. These requirements supersede existing guidance provided in the 24-1 version of the PAPPG.

13. Equipment-Related Thresholds

Chapter IX.E.2.g.(i) is revised to increase the equipment threshold from $5,000 to $10,000 to align with updates provided in Title 2 CFR § 200.313. The following underlined text is added and strikes previous text:

• (i) In accordance with 2 CFR § 200.313(e), NSF may identify items of equipment having a unit acquisition cost of $5,000 $10,000 or more where NSF reserves the right to transfer the title to the Federal government or to a third party named by the Federal government at any time during the award period.

14. Property Management Requirements for Federally owned Property

Chapter IX.E.3 is revised to provide information requirements for the inventory report to align with Title 2 CFR § 200.313(d)(2). The following underline text has been added:

• In the event that title to equipment or real property is vested in the Federal government, such Federally-owned property (FOP) must be identified, tagged or segregated in such a manner as to indicate clearly its ownership by the government. Unless otherwise provided in the award, such FOP must be used only for the performance of the project. The recipient must submit an annual inventory report and final inventory report for all FOP by NSF award number to NSF using the NSF's Central Property Inventory Repository (CPIR). An inventory report must be submitted in accordance with the requirements below, and a physical inventory of FOP must be conducted every two years. The annual report must be received in the CPIR system no later than October 15 each year. Additionally, the final inventory report for all FOP is due upon the end date of the award for further agency guidance on utilization and disposition. (See Chapter IX.E.5). Contact the NSF Property Administrator at nsfproperty@nsf.gov for access to the CPIR system or for any property related questions.
• a.  Annual Inventory Report for Federally Owned Property
  • (i) Submission Requirement. The recipient must submit an annual inventory report by NSF award number for all FOP having an original acquisition cost of $10,000 or more in accordance with 2 CFR § 200.312(a). The annual inventory report must be submitted to the NSF Property Administrator, Division of Administrative Services, no later than October 15 of each year using the NSF Central Property Inventory Repository (CPIR) system.

  • (ii) Content of Annual Inventory Report. The report must include the following information for all FOP purchased or constructed, including land and buildings, under the award, inclusive of all subawards. In addition, the report must include any FOP acquired through the General Services Administration (GSA) Federal Excess Personal Property Utilization Program and the Federal Surplus Personal Property Donation Program.  If the recipient is in possession of FOP under multiple awards, the reporting must be specific to each NSF award number.  The recipient may use the OMB-approved Post-Award Reporting forms for Tangible Personal Property (Standard Form (SF)-428, SF-428A, SF-428B, SF-428C, and SF-428S) accessed on the Grants.gov website.

    Required inventory information:

    • description of the property;
    • a serial number or another identification number;
    • the source of funding for the property (including the Federal Award Identification Number (FAIN);
    • the title holder;
    • the acquisition date;
    • the cost of the property;
    • the percentage of the Federal agency contribution towards the original purchase;
    • the location, use and condition of the property;
    • any disposition data including the date of disposal and sale price of the property; and a description of Construction-in-Progress (CIP) and Work-in-Progress (WIP) items and construction costs incurred to date.

  • (iii) Final Inventory Report for Federally Owned Property

    Upon expiration of the award, the recipient will report all the FOP purchased or constructed under the award or acquired through the GSA Federal Excess Personal Property Utilization Program and the Federal Surplus Personal Property Donation Program to the NSF Property Administrator for further agency utilization and disposition using the CPIR system. The final inventory report must include the same contents as the annual inventory report described in paragraph a.2. above and include the recipient’s disposition request.

15. Scientific Integrity

Chapter XI.M is revised to align with NSF Gold Standards of Science. The following text and footnotes 81, 82, and 83 have been struck:

• Inclusivity, t Transparency, and protection from inappropriate influence are hallmarks of scientific integrity

  Scientific integrity builds on key principles of honesty, objectivity, ethical behavior, transparency, and professionalism in the conduct of scientific activities in an inclusive environment that is conducive to excellence in research and education. 

16. Research Misconduct

Chapter XII.C is revised to incorporate the use of artificial intelligence (AI)-based tools. The underlined text has been added:

• RESEARCH MISCONDUCT means fabrication, falsification, or plagiarism, whether committed by an individual directly or through the use or assistance of other persons, entities, or tools, including artificial intelligence (AI)-based tools, in proposing or performing research funded by NSF, reviewing research proposals submitted to NSF, or in reporting research results funded by NSF.

Contact information

For questions or further clarification, please contact:

U.S. National Science Foundation
Grants Policy Branch
Email: policy@nsf.gov

1. NSF issued Federal Register Notice, U.S. National Science Foundation Proposal/Award Information - NSF Proposal and Award Policies and Procedures Guide, 89 Fed. Reg. 100,549 (Dec. 12, 2024) on Dec. 12, 2024 to seek public comments on many of the policies identified in this notice.