U.S. NATIONAL SCIENCE FOUNDATION
OFFICE OF THE DIRECTOR ALEXANDRIA, VA 22314
STAFF MEMORANDUM OD 26-02
December 1, 2025
ADMINISTRATION AND MANAGEMENT
SUBJECT: Updates to Merit Review Processes
This memorandum communicates changes to the merit review process that are necessary to increase process consistency across the U.S. National Science Foundation (NSF) and to provide flexibility and streamline merit review processes for Program Officers given our reduced workforce. They are also meant to assist in expediting the processing of shutdown-related backlogs while maintaining the rigor of our merit review process. All changes are effective immediately unless otherwise indicated. Changes that require revisions to the Proposal and Award Manual (PAM) and Proposal and Award Policies and Procedures Guide (PAPPG) will be made effective through a forthcoming Policy Update from the Division of Institution and Award Support (DIAS) Office of Policy. Exceptions to the policy below will be considered on a case-by-case basis according to the scale and scope of the investment (e.g., Research Infrastructure, Center-scale, Regional Innovation Engine or Interdisciplinary competitions).
would like to thank the Merit Review Reform Team, the excepted employees who helped plan the Agency Program Restart after the funding lapse, and all employees who participated in August’s Merit Review Reform Survey for your contributions to the policy changes announced today. Each of these policy changes originated in the Merit Review Reform Survey, was further developed and refined by the Merit Review Team and was validated by the Program Restart Team. This Staff Memorandum represent a consultative and comprehensive approach to making improvements in the merit review process that ar meaningful to staff and support agency objectives. We are communicating these changes now to assist staff in planning for the restart of panel reviews on December 8, 2025 (as announced in Staff Memorandum 25-71) to provide needed flexibility as you plan for the remainder of the fiscal year.
Despite the recent shutdown, NSF must obligate as much of our FY 2026 appropriations as possible by September 30, 2026. We lost critical time during the 43-day shutdown and now face significant backlog of unreviewed proposals and canceled review panels. In parallel, our workforce has been significantly reduced, which means we have fewer people performing more work with less time. To complete our FY 2026 merit review processes and make awards by fiscal year end, we must maximize our use of availa procedural flexibilities, make straight-forward policy changes that can be quickly adopted, and leverage our collective knowledge and expertise.
The changes announced in this memorandum were specifically selected to enable Program Officers to expedite award and decline decisions, where appropriate, and avoid excessive demands on staff and external review capacity. External review is a tenet of Gold Standard Science and remains a hallmark of NSF’s merit review process that will not be replaced or removed. However, NSF Program Officers generally have the technical knowledge and the expertise necessary to make recommendations – either to return a proposal, decline a proposal, or recommend an award – without the usual three or more reviews. This and the other changes provided below were designed to give Program Officers greater flexibility during merit review to support NSF’s goal of expediting the award and obligation of FY 2026.
External review will not be required for conference, workshop, or symposium proposals up to $200,000. By December 8, 2025, DIAS will issue a Policy Update raising the PAM threshold for external review of conferences from $100,000 to $200,000. The Policy Update will add workshops and symposia to the definition of “conferences”, eliminate the external review waiver process, and make internal review optional. DD concur with final signoff by the NSF Chief Science Officer is still required for award recommendations prior to routing to the Division of Grants and Agreements (DGA) for award to ensure alignment with Executive Order 14332, “Improving Oversight of Federal Grantmaking” Executive Order.
All full proposals requiring external review must be reviewed by a minimum of two reviewers or have a minimum of two reviews. An internal review may substitute for one of the two required reviews. External review is a tenet of Gold Standard Science and remains a hallmark of NSF’s merit review process. The PAM currently requires at least three reviews or at least three reviewers for proposals requiring external review, but it allows for exceptions, with a written justification. With increasing demands on the reviewer community to review proposals and manuscripts, securing three external reviews or reviews from three reviewers for certain proposals can be time prohibitive. To reduce workload for Program Officers and the external reviewer community and reduce bottlenecks during the merit review process, by December 8, 2025, DIAS will issue a Policy Update establishing a new minimum review threshold of two reviews per full proposal and eliminating the justification requirement for proposals with two reviews. To reduce backlogs and speed the review process, Program Officers are encouraged to use their discretion to organize and schedule ad hoc and panel reviews at the minimum level necessary to produce at least two external reviews or two external reviewers. The panel summary cannot be used to meet the minimum requirement of two reviews.
The December 8 Policy Update will also allow a Program Officer to substitute one internal review in those rare circumstances when an ad hoc or panel review request process fails to produce the minimum of two external reviews. Internal reviews are only appropriate when an NSF employee has sufficient subject matter expertise to conduct a review, does not have a conflict of interest with the proposed research, and is available to review the proposals). Internal review may be performed by the cognizant Program Officer for the proposal based on their subject matter expertise; if the proposal is outside their expertise, an internal review may be provided by any other non-conflicted Program Officer with the relevant knowledge.
Future funding opportunity notices will provide NSF with maximum flexibility to determine the appropriate means of review at the time proposals are received. Effective immediately and until further notice, all funding opportunities that are intended for external review will advertise both internal and external review options under “review and selection process.” Nothing in this memorandum compels a Program Officer or other NSF official to conduct internal review where external review is more appropriate; however, this change provides Program Officers with flexibility to reduce the burden of external review where it is not necessary to make either an award or decline recommendation.
Program Officers are encouraged to triage all proposals where panel discussion is not needed to make a funding recommendation (award or decline). The PAM already permits Program Officers to decline proposals that receive low ad hoc or individual panelist reviews, but the triage process is applied inconsistently across the agency. Given the backlogs of shutdown-related proposals and panels, Program Officers are strongly encouraged to exercise their discretion to triage low-scoring proposals. This policy is already in effect. Local policies or practices that discourage or prohibit triage for low-scoring proposals are contrary to NSF policy and must be modified to conform with the PAM.
By December 8, 2025, DIAS will issue a Policy Update allowing Program Officers to recommend an award without panel discussion if the Program Officer determines that an award recommendation is sufficiently supported by ad hoc or individual panelist reviews (i.e., add the ability to do a ”high” triage). In addition, the Policy Update will remove provisions allowing panelists to ask that triaged proposals be discussed. Once the PAM is updated, proposals that are identified for triage by Program Officers will remain triaged
Most panel summaries should be a concise statement that is limited to a 3-5 sentence.
“Justification for panel recommendation.” Effective immediately, Program Officers are encouraged to prepare concise panel summaries, focusing solely on critical justification for the panel recommendation.
“Critical justification” includes key elements of the proposal discussion, distinguishing features of the proposal that led to or support the panel’s recommendation, and notes of any significant differences of opinions. Written comments on individual review criteria are not required and should not duplicate content already captured in the individual reviews.
Most panel summaries should not exceed five sentences.
Bullet points are an acceptable format for panel summaries.
Program Officers are encouraged to engage in pre-award negotiations only if and to the extent it is needed to fulfill the Program Officer’s due diligence responsibilities. Once a proposal has completed review and is being prepared for award recommendation, Program Officers should only solicit information and request modifications to the proposal when necessary to support award and ensure compliance with law, regulation, and NSF policy. Program Officers are not required to engage in pre-award negotiations and are officially discouraged from engaging in such negotiations for any reason other than what is needed to make a funding decision or ensure compliance. Local policies or practices that impose pre-award negotiation practices such as requiring responses to reviews or across-the-board reductions to project budgets to increase program funding rates must be rescinded or modified to conform with this Staff Memorandum.
Program Officers must preferentially use standard grants over continuing awards where appropriate. It is already NSF policy to prioritize standard grants over continuing grants. This policy was established in FY 2025 to reduce out-year commitments and provide the agency with greater flexibility in the face of budget uncertainty. This policy remains in effect in FY 2026. Program Officers who recommend awards under funding opportunities that permit either standard awards or continuing awards must preferentially use standard awards except in cases where the Program Officer or other NSF official determines there is significant risk, the length of the award would increase the likelihood that funds will be cancelled in future years, or where a cooperative agreement or other transactional arrangement authority is more appropriate
Program Officers are expected to return proposals that fall under the return without review criteria in PAPPG Chapter IV.B. Program Officers are also expected to maximize their use of available automated merit review tools, especially tools that identify proposals that should be returned without review. The Data Analytics Officer (DAO) group maintains a list of automated merit review tools at the NSF Strategic Program Analytics, Reporting & Knowledge Sharing (SPARKs) Lab. DAOs will offer weekly office hours open to all staff from December through January, excluding the last week of December and the first week of January, to support staff who use or want to learn more about these tools. Staff are encouraged to contact their Directorate or Office DAO or leadership for assistance. Local policies or practices that discourage return without review of proposals that fall under the criteria in PAPPG Chapter IV.B are contrary to NSF policy and must be rescinded or modified to conform with the PAPPG.
By December 8, 2025, DIAS will issue a Policy Update allowing for the return without review of proposals that provide “insufficient content to permit effective merit review.” This change will allow Program Officers to return a proposal that contains all the required elements but does not include a sufficient description of the research and proposed activities to allow a reviewer to assess the proposal’s potential merit or impact if awarded.
We remain committed to continually improving merit review policy, procedure, and systems. Today’s announcement introduces several changes we can make without significant system modifications or change management. We have also identified several potential improvements that may require a greater investment of time and funding to implement. Again, we are grateful for the input of the Merit Review Reform team and many others, and we will engage staff in opportunities to develop the most promising ideas into implementation plans. I look forward to announcing new engagement opportunities and new merit review reform implementations in the near future.
