Recent reporting that the National Science Foundation (NSF) is planning to reprogram up to $1.5 billion by reducing funding for some of its existing research programs to redirect those funds to support a new technology initiative has prompted many in the research community to ask: can the NSF actually do that?!
At the heart of that reaction is an important question about federal appropriations law and the relationship between the legislative and executive branches: once Congress appropriates money to a federal agency, how much flexibility does that agency have to move funds internally?
The short answer is that it depends on how Congress wrote the appropriations law. The practical takeaway for research administrators is that federal programs can typically be created, changed, or defunded at the discretion of the federal agency, unless there is a law that requires a program to exist or to be funded at a certain level.
Federal agencies do not receive one undifferentiated pool of money. They receive budget authority through appropriations accounts, and those accounts may include statutory conditions, funding floors, notification requirements, transfer authorities, and other limitations. In short, the legal structure of the appropriation matters.
For research administrators, the most important distinction is between a transfer and a reprogramming of funds. A transfer generally moves money from one appropriations account to another and typically requires specific statutory (i.e. written in law) authority. A reprogramming generally shifts money within the same appropriations account, often from one activity, program, or project to another. Agencies usually have more flexibility to reprogram funds than to transfer them, but that flexibility can be limited by statute, appropriations language, or required notification to Congress.
The reported reprogramming taking place at the NSF illustrates why the structure of the appropriations account matters. NSF’s annual appropriation is typically organized into only six accounts, the largest of which being the Research and Related Activities account that typically contains over 70% of NSF’s annual funding. If funds are being shifted within the same appropriations account, as seems to be the case here, NSF may have room to make internal adjustments, subject to any statutory restrictions and congressional notification requirements that apply. If funds are being moved between accounts, congressional approval or other statutory authority may be required.
In FY2026, Public Law 119-74 appropriated NSF funding through six accounts: Research and Related Activities ($7,176,500,000), Major Research Equipment and Facilities Construction ($251,000,000), STEM Education ($938,250,000), Agency Operations and Award Management ($355,000,000), the National Science Board ($5,090,000), and the Office of Inspector General ($24,160,000). The same law permits NSF to transfer up to 5% of any current-year NSF appropriation between those accounts, but no account may be increased by more than 10% through such transfers, and any such transfer is treated as a reprogramming. In contrast to the NSF, the U.S Department of Energy had 23 accounts and the National Endowment for the Humanities had just one account that received appropriations from the same law.
Congress can also instruct agencies on how to program appropriated funds by writing committee report language and explanatory statements that accompany the appropriations legislation. Historically, agencies have treated this language seriously because it reflects congressional intent and because agencies depend on ongoing positive relationships with the congressional appropriations committees. However, report language generally does not carry the same legal force as the statutory text of the appropriations law. That distinction matters when a presidential administration takes the position that report language is advisory rather than binding, and therefore is optional to adhere to, which is the interpretation favored by the Trump Administration.
Research administrators should be aware that the top-line appropriations amount for an agency, which is what’s typically reported by AAAS and other research budget trackers, does not tell the whole story of what an agency will fund. The way funds are structured, executed, and reprogrammed during the fiscal year can affect the timing, volume, and distribution of awards that organizations and investigators see in practice. For an insider perspective on the mechanics and politics of reprogramming funds at the NSF, check out a blog post from Dr. Jim Olds, formerly Assistant Director of the NSF Biological Sciences Directorate.
For additional detail on this topic, the Congressional Research Service has written a detailed explainer on transfers and reprogramming of appropriations, which informed this article.
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