Regulations.gov Comments

[200.461]<br/>Opposition to proposed 2 CFR &sect; 200.461 &mdash; Disallowing Publication Costs<br/><br/>I am a senior researcher funded by NASA grants for many years. I am commenting anonymously to protect my institution from potential funding risks.<br/><br/>I strongly oppose the proposed changes to 2 CFR &sect; 200.461, which would make standard scientific publication costs unallowable. This is based on two main points:<br/><br/>A. It conflicts with modern open-access research practice. Publishing results in peer-reviewed journals is the final, essential step of any research project. Modern science relies on an open-access model where the funding entity pays upfront fees so the data is immediately free to the public. Labeling these fees &quot;unallowable&quot; will lock taxpayer-funded discoveries behind journal paywalls or stop publication entirely.<br/><br/>B. It directly contradicts Executive Order 14303 (&quot;Restoring Gold Standard Science&quot;), which mandates that federally funded research prioritize transparency, rigor, and unbiased peer review. Cutting off funding for publication costs creates barriers to sharing results, directly violating the order&#39;s requirement to keep American science open and accessible.<br/><br/>OMB must remove the restriction on publication costs under 2 CFR &sect; 200.461 and keep them as fully allowable direct costs for scientific...

I&#39;m not a scientist or student of science, I&#39;m just a lowly animator, but I&#39;ve done my fair share of research and am somewhat familiar with the process.<br/><br/>Face it, grants will fund studies that will present fact, and fact itself is against this regulation. We are long past the point where you couldn&#39;t have heard what the studies say. You just deny them, and then more studies come out that reinforce what you&#39;ve denied - but if you&#39;re in charge of funding them? Simply flop into the grass like a wet fawn, and run into the thick brush when the dogs find you. Without any investment in their results and findings, you don&#39;t have to make any federal decisions based on them, and you don&#39;t have to hear or even think about them. You don&#39;t think about those suffering from malnutrition in the countries that WE pillaged for resources, or the recent Ebola strain, or those facing genocide in Palestine and Sudan. You don&#39;t care that science affirms trans people, and that trans people are statistically more vulnerable to sexual assault from men than children are from trans people. You can almost feel the welfare queens draining our precious tax money. You can pretend to be someone&#39;s private health insurance and plunge your head into the sand when someone doesn&#39;t meet the requirements for valve transplant coverage, or when insulin costs a ...

I am a former neuroscientist and academic researcher who held NIH fellowships at two career stages: first as a pre-doctoral fellow at NIH studying women with premature ovarian failure, and later as a post-doctoral fellow on an NIH training grant at Stanford, where I conducted research on chronic pain interventions including real-time fMRI neurofeedback and compassion meditation. I am also a homeschooling parent raising a child whose future depends on the integrity of publicly funded science. I write in strong opposition to this proposed rule, which I believe poses a grave and lasting threat to American scientific progress, the independence of peer-reviewed research, and the livelihoods of the researchers who dedicate their careers to advancing human knowledge.<br/>&sect;200.205 &mdash; Political Appointee Review of Grants<br/>Allowing political appointees to override peer review is perhaps the most damaging provision in this rule. Scientific funding must be decided by qualified experts, not officials whose positions are awarded on the basis of political loyalty rather than expertise. U.S. scientific leadership since World War II has rested on one principle: government funds science but does not dictate its conclusions. This provision dismantles that principle. It does not reform the grant process &mdash; it corrupts it. I urge OMB to withdraw &sect;200.205(b) entirely.<br/>&...

Office of Management and Budget<br/>Re: Proposed Revisions to 2 CFR Part 200 (Uniform Guidance)<br/><br/>To Whom It May Concern:<br/><br/>I am writing to express my fervent opposition to the Office of Management and Budgets proposed revisions to the Uniform Guidance. The proposed changes would undermine the U.S. research enterprise, weaken America as a global scientific leader, and jeopardize the innovations that drive economic growth, improve public health, and strengthen national security.<br/><br/>The United States is a world leader in scientific discovery because of a research ecosystem built on rigorous peer review, stable federal investment, international collaboration, and the freedom to pursue evidence-based inquiry. OMBs proposed revisions threatens the viability of this enterprise.<br/><br/>Harm to research stability and scientific merit<br/><br/>Scientific discovery requires long-term investment and stability: researchers spend years developing projects, building collaborations, training personnel, and generating data before breakthroughs occur. The proposal would expand the government&#39;s authority to suspend, terminate, or otherwise disrupt research awards based on subjective criteria and priorities. This would create significant barriers to progress for researchers and institutions. <br/><br/>Project funding should not be interrupted for reasons unrelated to ...

This is a terrible proposal. Taken as a whole, these proposed revisions would redirect federal research funding away from a framework based on scientific excellence, transparency, consistency, and the broad sharing of knowledge, and toward one that is more susceptible to political influence, bureaucratic delays, and unpredictability. Such a change would negatively affect researchers, academic institutions, trainees, patients, and society at large. I encourage OMB to revise these provisions by safeguarding the essential role of expert peer review, restricting award termination authority to well-defined and reviewable circumstances, preserving conference attendance and publication expenses as standard allowable research costs, and ensuring that limits on international collaboration are carefully targeted to specific, evidence-based concerns.<br/>The success of the federal research system has long depended on its commitment to scientific rigor, open collaboration, independent peer assessment, and sustained investment. The proposed revisions should therefore be refined to uphold and protect these foundational principles.

The most alarming provision of this rule proposes that before any federal grant can be issued, a senior political appointee must personally review and approve it. The rule explicitly states that peer review &ldquo;remains advisory and does not replace agency discretion.&rdquo; <br/><br/>Peer review has been the foundation of scientific funding decisions since the post-World War II compact between the federal government and the scientific community, leading to the establishment of the National Science Foundation. Under this proposed rule, political officials would have the authority to reject proposals that passed rigorous expert evaluation if they determine the work does not advance &ldquo;the President&rsquo;s policy priorities&rdquo; or is inconsistent with &ldquo;the national interest,&rdquo; which could change or reverse course at any moment. <br/><br/>The rule also imports language from the administration&rsquo;s &ldquo;Gold Standard Science&rdquo; executive order, directing agencies to &ldquo;prioritize institutions demonstrating rigorous and reproducible scholarship,&rdquo; using the language of scientific rigor as a screen for political gatekeeping, just as we warned when that order was issued. There is no appeal process for researchers whose work is rejected on these grounds. <br/><br/>We have spent generations building peer review precisely because decisions about ...

I am faculty member at an academic medical school. I have had multiple grants funded through the NIH. Also, as a public citizen, I and those I love have benefited from medical research that has helped to not only better their lives but in some cases save their lives. I am writing to oppose the proposed revisions to &sect;200.205 and &sect;200.454. Section 200.205 would require a senior political appointee to personally review and approve every discretionary grant, with authority to override peer review. I have been in the medical field as a clinician researcher for over 25 years. Scientific funding decisions must be made by qualified experts, not political officials. Just look at what has happened with DOGE, under Elon Musk. I also object strongly to &sect;200.340, in which grants can be terminated at any time. This creates an atmosphere in which scientists are afraid to study what is in the public interest and are vulnerable to partisan politics. Science needs to be non-partisan. I object as well to &sect;200.432 &mdash; Conference attendance pre-approval. Grants are necessary to allow scientists to meet and exchange ideas. Scientists need the freedom to decide which conference are in their best interests. I find it very time consuming to travel to conferences-- it takes time from my personal life and my family. I do so because it is important to the quality of my researc...

Public Comment Docket OMB 2026 0034<br/>Re Guidance for Federal Financial Assistance (2 CFR), Vol. 91 Fed. Reg. No. 103 (May 29, 2026)<br/>We are (were?) world leaders in science and education <br/>For the last century, American scientific research has been the envy of the entire world, fueled by investment in research and education at every level. The US university system is an engine for economic prosperity, bringing in the best and brightest from around the world to work and study. <br/>Science and education matter to me<br/>My husband and I both have Master&rsquo;s degrees. Both of our children and their spouses have achieved between the 4 of them the following terminal degrees: 1 PhD, 2 Master&rsquo;s, and 2 Bachelor&rsquo;s degrees. Government STEM funding has led to breakthrough treatments and technologies that improve our health, extend our lives, and grow our economic and political power. The NASA space missions inspired our older daughter to pursue her PhD in neurobiology. She now runs her own lab research brain trauma at the cellular level. This will impact our elderly (like me) who are in the highest risk category for TBI as well as countless others like youth football players, car accident victims, and more. Every person in my large family age 30 years and up relies on well-researched medications which involve untold hours of basic research, then drug developmen...

Please do not change the process of scientific review and support for scientific projects within the United States.<br/><br/>NSF and NIH grants empowered me to become a scientist and maintain a career that resulted in hundreds of evidence-based peer-reviewed publications and patents, improving the fields of nutrition, wound healing and hyperactivity and related clinical outcomes during the &gt;50 years of my career as a PhD scientist. These grants also prepared me to train hundreds of students in statistics and experimental design so that they, too became effective scientists and were enabled to recognize good quality scientific findings worthy of applying to improve patient outcomes. <br/><br/>As my experience grew, I also served as a reviewer for grant submissions, journal articles and project reviews, helping to maintain high quality scientific progress in the fields I served.<br/><br/>Expert scientific peer review improves the work reviewed and increases its likelihood of improving psychological and physical outcomes for patients. Care that works, based on peer-reviewed science, reduces costs of physiological and psychological health care. Without science, one cannot draw conclusons about safety and/or efficacy of clinical care.<br/><br/>Our system of scientific review and education earned global respect and has helped humanity overcome and/or avoid plagues like polio, ...

June 10, 2026<br/>From: Dr. James L. Stevens<br/>[ ]<br/><br/>To: www.Regulations.gov/docket/OMB-2026-0034<br/>Subject: Public Comment from a Retired Scientist.<br/>Dear Comment Reviewer:<br/>I am a retired scientist whose early career path has been assisted by federal grants, and I am concerned about the careers of young people following a path like mine. I came from a poor family but was found to be academically talented at an early age. My fondest desire was to become a scientist like those whose biographies that I had read and be able to make a small contribution to the total of human knowledge and the material betterment of society as well as providing for my family. A full college scholarship got me to the BS level of Physics and an NSF Traineeship program allowed me to obtain my Ph.D. My thesis research was federally funded at the Savannah River Site including costs associated with publication and presentation at the American Physical Society Convention. Another grant allowed me to do more research at Case Western Reserve University as a post-doc. Over the next 40 years, I was an assistant professor and then Research Physicist at Philips Electronics where I published about 30 patents and peer-reviewed papers. In short, I was able to realize my dream with the help of federal grants and other sources. I am concerned about OMB-2026-0034. It is easy to see how it...

Federal grants should be lawful, accountable, fiscally responsible, and protected from fraud, unlawful discrimination, and foreign exploitation. Universities and researchers are not entitled to public funds without oversight. However, the proposed revisions to 2 C.F.R. Part 200 go far beyond targeted accountability measures. Taken together, they would make federal research awards politically contingent, less stable, more bureaucratic, and less competitive.<br/>This is not merely an issue for universities. It is a question of American scientific leadership.<br/>The United States has long been the world&rsquo;s leading scientific nation, as reflected in its universities, influential research, innovation, and Nobel Prizes. But that position is no longer secure. China already produces more scientific publications than the United States, leads selected measures of high-quality research output, and is rapidly expanding research and development investment. America&rsquo;s Nobel dominance reflects a scientific system built over decades; it does not guarantee future leadership. The discoveries recognized ten or twenty years from now will depend on the research environment created today.<br/><br/>An America First science policy should ensure that discoveries are made in American laboratories, that talented scientists build their careers here, and that federally funded research strengt...

Transparency, accountability, and oversight of taxpayer dollars, are ones I share, but this proposal does not serve those goals. They transfer the core decisions of federal research funding from qualified scientific experts to political appointees, at every stage of the funding lifecycle. Several provisions would raise administrative burden rather than reduce it, and the cumulative effect would be to make federally funded science less rigorous, less stable, and less responsive to the public interest. I urge OMB to withdraw or substantially revise the rule, and in particular to strike or rewrite the provisions identified below &mdash; most urgently [200.205], [200.300], [200.340], [200.432], [200.454], and [200.461].<br/>Provisions [200.205] and [200.300] are positioned to displace expert judgement and make categorical prohibitions on broad, loosely defined subject areas. This increases the chances that researchers will self-censor their work, rather then exploring legitimate lines of research as determined by peer researchers who have the background and expertise to judge its merit. The provisions also expands the authority to terminate active awards [200.340] in ways that essentially make all multi-year funding a guessing game. Ending projects midway through wastes federal funding, in terms of investing funding without getting final outcome reports that would make the expe...

This proposed rule change is dismantling the long held focus on peer reviewed science, open competition, and institutional autonomy. Please remove section &sect;200.205(d) so that peer review can remain the primary measure of scientific measure. Please define what the &#39;Gold Standard Science&#39; concept means in clear terms with benchmarks for compliance. Please update section &sect;200.340 so that grants can only be terminated when there are findings of noncompliance or fraud. Section &sect;200.206 is too broad and organizations that &#39;advocate for the overthrow of the United States Government&#39; should be clearly listed in an appendix to prevent the weaponization of political affiliations or advocacy groups that the administration does not agree with. Please remove section &sect;200.303 - E verification adds unnecessary administrative burden to organizations. Please remove section &sect;200.432 that requires direct approval for conference attendance. Grantees should be allowed to attend conferences to present work without agency approval. Please remove section &sect;200.461 so that grants can cover journal fees. Publication is an essential component of research and it is an unnecessary burden for researchers to find additional funding to cover journal costs in order to share research performed under a federal grant.

Submitted on behalf of Vascudyne, Inc - Small MedTech Company: VASCUDYNE AS PRIME RECIPIENT<br/><br/>1. Termination/suspension for convenience destroys disproportionate value in milestone-gated medical product development (&sect; 200.340).<br/>One of Vascudyne&#39;s awards is a four-year, $3.99M program with a sequential, capital-intensive regulatory path &mdash; cGMP production, GLP preclinical testing, a preIND/IND submission to FDA, and aiming toward a subsequent Phase 1 trial in adolescents &mdash; with costs heavily front-loaded into Years 1 and 2. Allowing an agency to terminate when it determines the award &quot;does not effectuate program goals, Federal agency priorities, or the national interest as they exist at the time of the termination&quot; means a mid-stream discretionary termination &mdash; for example, after GLP testing but before IND submission &mdash; would strand a large sunk federal and private investment with no clinical or regulatory readout. For regulated, milestone-sequenced medical product development, value is realized only at the end of the sequence. Convenience-termination and the parallel 90-day temporary suspension should carry heightened justification and wind-down/close-out protections for FDA-track awards.<br/><br/>2. The lower-IDC preference penalizes small for-profit recipients already at the floor (&sect; 200.205(b)(3)).<br/>Vascudyne cur...

I do not support this at all. This is going to make the &ldquo;old Boys club&rdquo; grant funding even worse. We need double blind reviews, lottery system for the top most grants, and caps on indirect costs. The final say on whether the grant gets approved to be in the lottery needs to be from unbiased scientists who are experts on the topic and could be someone who has been elected by US voters.

We are faculty researchers at the University of North Carolina, Chapel Hill, a leading R1 public institution in North Carolina; however, we are speaking solely in our individual capacities as private citizens and not as representatives of our institution. Our work spans nutrition, chronic disease, health behavior, and epidemiology, supported substantially by NIH and CDC. We submit this comment in strong opposition to the proposed revisions and urge OMB to withdraw the provisions described below, which would irreparably damage the American research enterprise and directly harm the health of Americans.<br/><br/>Political Override of Peer Review (&sect;200.205)<br/>Proposed &sect;200.205(b) would authorize a senior political appointee to override scientific peer review panels on discretionary grant awards. This provision undermines the merit-based system that has defined U.S. biomedical leadership since World War II. Our grants &mdash; supporting longitudinal cohort studies, community-based research, and randomized trials &mdash; were awarded through rigorous expert review. Allowing political override with no defined criteria, no required scientific expertise, and no appeal right introduces an arbitrary basis for grant denial incompatible with sound administrative practice. We urge OMB to strike &sect;200.205(b) in its entirety.<br/><br/>Discretionary Grant Termination (&sect;2...

RE: Comments in Opposition to Proposed Rule: Regulation for Federal Financial Assistance (Docket No. OMB-2026-0034 / RIN 0348-AB87) <br/><br/>To Whom It May Concern: <br/><br/>I am writing to express my strong opposition to the Office of Management and Budget&rsquo;s (OMB) proposed revisions to the Guidance for Federal Financial Assistance (2 CFR Subtitle A), published in the Federal Register on May 29, 2026 under Docket No. OMB- 2026-0034. <br/><br/>While I support the stated goals of fiscal responsibility and reducing waste, the sweeping overhauls outlined in this proposal will severely compromise the integrity of American scientific research, destabilize the operational continuity of grant recipients, and introduce unprecedented political interference into historically objective merit-review systems. Ultimately, I believe this rule would have devastating impacts on the American economy.<br/><br/>I urge the OMB to reconsider and withdraw the following provisions: <br/><br/>1. Introduction of Political Review Over Scientific Merit (&sect; 200.205) <br/>The proposal to subject all discretionary awards to mandatory pre-issuance review by &quot;senior appointees&quot; fundamentally undermines the peer-review system that has made American research the gold standard of global innovation for more than 75 years. Elevating political priorities above independent, objective, and spec...

Docket No. OMB-2026-0034<br/> <br/>I am an early-career researcher in the psychological and brain sciences whose work depends on Federal research funding, on the integrity of scientific peer review, and on the ability to publish federally funded results. I write to oppose this proposed rule in the strongest terms and to urge that it be withdrawn in its entirety. (I comment in my personal capacity, not on behalf of my institution.)<br/> <br/>Let me be clear about common ground: I support genuine accountability and the responsible stewardship of public funds. That is precisely why I oppose this rule. It does not strengthen accountability &mdash; it dismantles the one mechanism that has reliably protected the value of Federal research dollars, the independent evaluation of scientific merit, and replaces it with political control answerable to priorities other than quality and public benefit.<br/> <br/>1. The rule subordinates expert peer review to political review. Requiring senior political appointees to screen every discretionary award for &quot;presidential priorities,&quot; demoting peer review to merely &quot;advisory,&quot; and instructing appointees not to defer to reviewers guts the merit-based system. Political appointees cannot replicate the technical judgment of qualified scientists across thousands of specialized proposals. Substituting alignment for expertise guara...

I am writing to strongly oppose the proposed OMB rule on federal financial assistance. This proposal would fundamentally weaken the merit-based system that has allowed American science, public health, medicine, engineering, and innovation to lead the world for generations.<br/><br/>Federal research funding should be awarded based on scientific merit, public need, statutory purpose, and independent expert review. This proposed rule moves in the opposite direction. It gives political appointees broad power to approve, deny, condition, or terminate grants based on whether the work aligns with the policy priorities of the current administration and reflects political control over research.<br/><br/>One of my greatest concerns is the proposed change to the grant review process. The rule would require senior political appointees to review discretionary grants before award and expressly prevents them from simply relying on peer review recommendations. Peer review is not perfect, but it is the best system we have for evaluating complex scientific work. Scientists, medical experts, engineers, and subject-matter specialists are in the best position to judge whether proposed research is rigorous, feasible, and important. Political appointees should not be empowered to override expert review.<br/><br/>This rule would also impose an undefined standard called &ldquo;Gold Standard Science....

I have seen Alzheimer&#39;s up close personally and professionally.<br/>My great grandfather&#39;s progression of Alzheimer&#39;s was a merciful one. He started to forget things and people pretty quickly and had passed on in a matter of months. Although many others&#39; stories are more intense, there was not one person around my great grandfather that wasn&#39;t heartbroken. <br/>In my professional life, I see many people with dementia and there&#39;s nothing I can do about it. One person had to take 5 minutes to put their things away in their wallet, pulling them back out, verbally checking to see what it was, putting it away and pulling it right back out to check.<br/>I am happy knowing that currently there are studies that look into how we can treat these people, what measures we can take to prevent dementia and Alzheimer&#39;s.<br/><br/>I have not personally known many folks with cancer, but the results I&#39;ve seen from research has filled me with so much joy. We&#39;re now able to treat leukemia by withdrawing some blood, treating it and replacing it, which can avoid chemotherapy that makes them feel more sick. This is incredible! And it would not have happened if many many years of continuous research hadn&#39;t taken place.<br/><br/>These are only some ways that the National Science Foundation and the National Institutes of Health have helped us progress and make A...

I am concerned that this proposal could mean that researchers with federal grants may no longer be able to use grant funds to pay for publishing the work those grants require them to make public. Also, libraries that have Open Access Publication Funds and Read-and-Publish agreements with publishers could face significantly increased demand as the only remaining options for covering APCs (article processing charges). Library journal subscriptions that are currently supported through indirect cost recovery on federal grants could also be affected. Researchers may be discouraged from seeking federal funding altogether if the cost of publishing falls entirely on them or their departments.<br/><br/>Therefore, please do not implement these changes.<br/>Thank you,<br/>

As a researcher who executes clinical trials for treatment of severe disease, this rule is both disappointing and alarming. Each section has the potential to slow research and end America&#39;s ability to be competitive in the world of science and research. <br/>Section 200.205 means that grants written to be timely and aligned with department agenda will be reviewed slowly by individuals who may not be well versed on the scientific topic. A board of scientists can question the vigor of research and its efficacy in ways a single government appointee would not be able to do. Additionally, the bottleneck this causes would lead to loss of work force in research and a need to re-hire a team with each slow grant approval. A process that takes time, money and resources away from doing the actual science. <br/>200.340 neglects ongoing work. Stopping research mid-stream is not only a waste of time and resources, but could stop the sharing of valuable information. We know that good research takes time and observation. Trying to solve problems that affect the daily lives of Americans should not be conducted at the whim of Agency Priority Memos. When research is approved, it should be conducted to its full extent. <br/><br/>200.454 and 200.461 effectively pause scientific communication. Journals are the best way to stay up to date on research and write the best, competitive grants. Bec...

Comment on OMB-2026-0034: Regulation for Federal Financial Assistance<br/><br/>I respectfully urge OMB to reconsider several proposed revisions to the Regulation for Federal Financial Assistance, particularly those restricting diversity, equity, and inclusion (DEI) activities; limiting support for publication, conference participation, and scientific collaboration; expanding agencies&rsquo; authority to terminate awards; and increasing political oversight of discretionary funding decisions. Collectively, these changes are likely to reduce the effectiveness, quality, and public value of federally funded research, evaluation, and public-service programs. (Ropes &amp; Gray⁠)<br/><br/>The proposed restrictions on DEI-related activities are inconsistent with a substantial body of empirical evidence demonstrating that diversity contributes to innovation and scientific impact. An analysis of more than 9 million scientists and 6 million scientific publications found that ethnically diverse research teams consistently produced higher-impact scientific work than less diverse teams (AlShebli et al., 2018). Similarly, Freeman and Huang (2015) found that diversity in scientific collaboration contributes to stronger research outcomes. Organizations that identify and address barriers to participation are often better positioned to recruit talent, engage stakeholders, and serve diverse comm...

I am an NIH-funded scientist with more than a decade of experience. I respectfully urge OMB to withdraw this proposed rule. If OMB proceeds with rulemaking in this area, I urge the agency to retain the existing peer review framework as the primary basis for grant award decisions, remove the prohibition on health disparities research, restore due process protections for grant terminations, and extend the comment period to allow meaningful public participation. The federal research enterprise has served this country well because it has been grounded in scientific merit. This proposed rule would dismantle that foundation. The costs, in human health, in scientific capacity, and in international competitiveness, would be borne for generations.

Re: Regulation for Federal Financial Assistance (Docket No. OMB-2026-0034)<br/>I am writing to oppose this proposed rule. While framed as a measure to improve accountability, its actual effect would be to politicize federal research funding and destabilize the scientific enterprise that the United States depends on for its health, economy, and global competitiveness.<br/>&sect;200.205 would inject political review into discretionary grant decisions, allowing political considerations to influence or override peer review. Independent peer review exists precisely because scientific merit cannot be judged by political alignment. Replacing expert evaluation with political oversight will not produce better science&mdash;it will produce science chosen for its convenience to whoever holds power at a given moment.<br/>&sect;200.340 would permit termination of any active award &quot;for convenience,&quot; without cause or notice. Research is a multi-year commitment involving clinical trials, patient participants, trainees, and substantial taxpayer investment. Allowing abrupt termination whenever agency priorities shift means no researcher, institution, or patient can rely on a funded study being completed. This wastes public money already spent and breaks faith with the patients who volunteer for studies.<br/>&sect;200.220&#39;s restrictions on international collaboration would cut Am...

I am a retired principal investigator who enjoyed 30+ years of funding by both NIH and NSF. I sat on study sections for both. I am grateful for the financial support I had from NIH through the years of graduate and post-doctoral training.<br/>The proposed changes are concerning. &sect;200.205 refers specifically to Executive Order 14332 as the document that will inform &ldquo;senior appointee&rdquo; review of pre-issuance awards. This document forbids agencies to &ldquo;fund, promote, encourage, subsidize, or facilitate&rdquo; racial preference, denial of the existence of more than two genders, or the totally undefined &ldquo;anti-American values.&rdquo; The exclusion of DEI considerations fails to realize that &ldquo;underserved&rdquo; populations continue to be &ldquo;underserved. The exclusion of gender identity studies fails to realize that gender dysphoria is not an evil conspiracy that aims to brainwash or &ldquo;mutilate children,&rdquo; but a real phenomenon experienced by real people. Why prevent scientists from studying the physiological underpinnings of their gender dilemma?<br/>Another provision of EO14332 is to prioritize funding to institutions with low indirect costs. An institution with low indirect costs is often an institution that has not invested in the scientific infrastructure nor has supported that scientific personnel required for the rapidly-changing...

As someone working in research administration, this is an unfathombly stupid proposal. This will kneecap research in the US and set us back irreparably in scientific progress for years to come. 1) Making direct agency approval by a political appointee (rather than scientists) one of the main decision making points just means we will get worse science and the funded priorities will bend to the will of a political appointee. When funded decisions are made upon the lines of what is politically convenient, scientists are forced to bend to that to keep their labs funded. This produces a gross incentive to aim for projects and results that will benefit political power, rather than good science 2) Limitation of indirect costs just makes supporting research more expensive for research institutions; it does not reduce the actual overhead costs that are necessary to support said research 3) Making publication and conference costs unallowable only serves to stifle the spread of knowledge among the scientific community. What good are research results if they cannot be shared to be further built upon?

I am an Assistant Professor at a research university with an active NIH award from NIGMS. I trained on NIH T32 support and have presented federally funded research at national and international meetings throughout my career. I submit this comment in my individual capacity as a working scientist whose laboratory and trainees are directly affected by the following proposed rules.<br/><br/>[200.205 / 200.205(d)] Section 200.205 conflicts with the Public Health Service Act (42 U.S.C. 289a), which establishes peer review by qualified experts as the statutory basis for NIH funding decisions. My grant was evaluated by a Special Emphasis Panel of domain experts in molecular biology. No political appointee has the expertise to assess whether that science meets merit standards. Reducing peer review to advisory status while requiring political pre-approval produces funding decisions that are scientifically arbitrary and legally indefensible under the PHS Act.<br/>[200.340] I support three graduate students on an active multi-year NIH award. Each made career decisions based on the reasonable expectation that a funded grant would run its course. The authority to terminate without cause or misconduct finding converts a funded award into a contingent one. Training the next generation of American scientists requires a stable funding environment. This provision destroys that stability.<br/>[...

I am a professor of biochemistry and chemistry at a primarily undergraduate institution where federally funded research supports both scientific discovery and the training of undergraduate researchers. I am concerned that several provisions in the proposed revisions to the Uniform Guidance would undermine the effectiveness, stability, and integrity of the federal research enterprise.<br/><br/>I oppose the changes proposed in &sect;200.205 regarding political review of discretionary grant awards. Federal research funding decisions should continue to be based primarily on rigorous peer review conducted by subject-matter experts. Allowing political appointees to override or substantially influence funding decisions introduces uncertainty into the process and risks shifting funding away from the most scientifically meritorious proposals. Such a change could discourage innovative, high-risk research and weaken confidence in the fairness and objectivity of federal funding programs.<br/><br/>I am also concerned about the expanded grant termination authority proposed in &sect;200.340. Research projects often span multiple years and require institutions to make long-term commitments involving personnel, equipment purchases, student training, and collaborative partnerships. The possibility that an award could be terminated because priorities change after funding has been awarded creat...

I submit this comment as a principal investigator, professor, and librarian working in research infrastructure, scholarly communication, and research data management.<br/><br/>I support OMB&rsquo;s effort to clarify federal financial assistance rules and strengthen accountability, but I urge caution, Under proposed &sect; 200.205, merit review should remain grounded in law, agency mission, program priorities, national interest, and expert review. Presidential priorities may shape agency direction, but they should not weaken independent scientific judgment or peer review.<br/><br/>I support proposed &sect; 200.461 making publication costs such as APCs generally unallowable unless specifically approved. The APC model has created unhealthy incentives in scholarly publishing. Federal policy should instead encourage Diamond Open Access, repositories, data publishing, and other durable public-access infrastructure.<br/><br/>I also strongly support proposed &sect; 200.455(c), which continues to treat data, evaluation, cybersecurity, metadata, dashboards, repositories, and research data management as allowable costs. These activities are central to modern research and to the public value of federal funding.<br/><br/>Some restrictions in proposed &sect;&sect; 200.432 and 200.454 are reasonable, including limits on subscriptions and memberships. However, reasonable conference and coll...

I am a Professor at The Lewis Katz School of Medicine at Temple University in Philadelphia, PA and have been a scientist in academic medicine for over 35 years. I speak only for myself and not on behalf of Temple University. Gold Standard Science at its best involves forming collaborative partnerships to bring together scientists with diverse techniques and areas of expertise to test novel hypotheses that will move biomedical science forward, bringing about novel therapies and treatments to impact human health across the globe. Gold Standard Science also requires those scientists to disseminate their work in open scientific forums where that work can be rigorously evaluated through peer review and where that work can propagate new ideas to move the field forward. While the OMB&rsquo;s proposed revisions to the Uniform Guidance for Federal Financial Assistance are, in part, designed to &ldquo;restore&rdquo; Gold Standard Science, they instead will raise barriers, both in time and in dollars, to American scientists who have devoted their careers to these standards. Among the many changes proposed, publication fees, scientific society membership fees and conference attendance costs will be either unallowable or subject to prior review and authorization, barriers that will result in a disastrous drop in scientific society membership, conference attendance and publication in top-...

Comment on Regulation for Federal Financial Assistance (Docket OMB-2026-0034, 91 FR 32198)<br/>I am a physician and researcher whose work focuses on patient safety and quality of care for patients who speak a language other than English, including the measurement of clinician language proficiency and the reduction of preventable harm caused by language barriers in cancer care. My federally supported research includes a two-site study with collaborators at another institution. I am writing as an individual to raise specific concerns about provisions of this proposed rule that would impede this work and, with it, the safety of patients who depend on accurate clinical communication.<br/>[200.205] Pre-issuance review and the substitution of policy alignment for scientific merit. The proposed pre-issuance review would require senior appointees to evaluate discretionary awards for alignment with policy priorities and the &quot;national interest,&quot; and would forbid them from deferring to scientific peer reviewers. My research addresses a documented patient-safety problem: when clinicians and patients cannot communicate accurately, the result is measurable harm, including diagnostic errors, missed elements of informed consent, and worse cancer outcomes. Determining how to measure clinician language proficiency reliably, and how to deploy interpreters and language-concordant care...

I am a geriatrician, so I am a physician who specializes in caring for older adults. I am commenting to express my concern over the following three sections: Political-appointee review of grants (&sect;200.205), Journal subscriptions and publication costs becoming unallowable (&sect;200.454 and &sect;200.461), and Ban on DEI research (&sect;200.218 and &sect;200.300). I am concerned passing this will cause irreparable harm to our standing as the premier county for healthcare research in the United States. Allowing political appointees to review grants opens the door for weaponization of research dollars by any political opponent of someone else. Research should stay separate from political appointees. Additionally, we should allow for payment to make research freely available through grant funds. This will expand the influence and access of research so any concerned citizen can review research without a paywall. Finally, as a geriatrician, I firmly believe in being able to conduct research on diverse patient populations. We have a difficult problem in geriatrics where many older adults are removed from studies. Without allowing for us to examine the specific older adult population, we will be unable to investigate the benefits and harms of treatments on this vulnerable population.

Comment on Regulation for Federal Financial Assistance (Docket OMB-2026-0034 / RIN, 91 FR 32198)<br/>I am a practicing gastroenterologist and physician-scientist whose clinical and research work focuses on cancer genetics, including the identification and management of patients at hereditary risk for gastrointestinal and other cancers. My research is supported in part by federal funding, and the patients I care for benefit directly from discoveries that federal research dollars make possible. I am writing as an individual to express serious concerns about specific provisions of this proposed rule, which I believe would harm both the scientific enterprise and the patients it ultimately serves.<br/><br/>[200.205] Pre-issuance review and the displacement of scientific peer review. The proposed pre-issuance review process would require senior appointees to evaluate discretionary awards for alignment with policy priorities and would forbid them from deferring to or routinely ratifying the judgments of scientific peer reviewers. Peer review by subject-matter experts is the mechanism that has allowed federal science funding to identify the most rigorous and promising work for decades. In my own field, the cancer-genetics advances that now let me tell a patient whether their family carries a pathogenic variant, and what surveillance can prevent a fatal cancer, came from work selecte...

The proposed changes to the way in which federal grants are selected for funding completely undermines the entire scientific process, in which grants are funded based up the merit determined by a panel of peer-reviewers. The proposed shift, in which officials appointed by the President will weigh in and have the final say on which grants are/are not funded, is a gross misuse of power, and it places the decision on the direction of science in the hands of people who are woefully underqualified to make such decisions. Moreover, it allows the executive branch of government (which has nothing to do with science in a position to completely reshape the entire scientific environment. Granting such power to these individuals is unconstitutional, and it should be avoided at all costs.

I am an associate professor whose research has been supported by the NSF. I am concerned that several provisions of this proposed rule could undermine the effectiveness, fairness, and scientific integrity of the federal research enterprise, making US science less competitive. In particular OMB should strike or rewrite the provisions [200.205], [200.300], [200.340], [200.432], [200.454], and [200.461].<br/><br/>Specifically, the following are ridiculous:<br/><br/>[200.205] Peer review has been a cornerstone of American science for decades. Changing this will weaken our science enterprises and make our country less competitive on the global stage. Moreover, it reduces confidence that funding decisions will be based on scientific quality and potential impact. A generalist appointee is not positioned to assess whether a proposed design is confounded, whether a sample is adequate, or whether an analytic plan supports the inferences drawn. The post-war American research system became the most productive in the world because the allocation of public funds was tied, through peer review, to independent technical judgment rather than to the preferences of whoever held office. A political review forbidden from deferring to that judgment does not add a safeguard atop merit review; it overrides merit with something that is not merit.<br/><br/>[200.300]. Embedding categorical prohibitions...

As a taxpayer and voter, I highly disagree with the proposed rule. Already, as a result of this administration&#39;s slashing of grants due to it&#39;s political ideologies, I have experienced a loss of work, even though I am not a researcher. These constant cuts have far reaching effects that do not only impact grant recipients, but impacts everyone else who works at grant-receiving institutions, and within their communities. While the rules outlined here do not specifically cut funding, I can foresee them having a huge impact on the amount of work available to me in my community, even though I am not a researcher. People from all walks of life work at these research institutions, and they are important parts of the local economy. By taking aim at scientists, you are also hurting general laborers and the every-day people that work at these places helping to keep the lights on. When these large institutions are forced to cut jobs due to federal changes, it upsets the local economy and leaves regular people without jobs. You are taking away people&#39;s livelihood with your political targeting of science/research.<br/><br/>Additionally, having a political appointee (who does not understand the science) deciding if grants are awarded or not is ludicrous. Our country is backsliding and we are becoming the laughing stock of the world. We are hamstringing ourselves and limiting f...

This proposed rule is highly concerning and will dramatically impact the quality, pace, and impact of scientific discovery in the United States, which is already falling behind China and other countries within the past few years.<br/><br/>Specifically, a major concern is that this will politicize science, allowing non-scientists to make major funding decisions that are not based in fact or biology. I expect it will result in reduced funding to major leading research institutions and lead to the redistribution of research dollars for pollical reasons. This will certainly weaken scientific advancements in the United States.<br/><br/>The most problematic points in the proposed rule change include:<br/><br/>&bull;<span style='padding-left: 30px'></span>Peer review becomes advisory only&mdash;&ldquo;senior appointees&rdquo; at NIH would have the authority to overrule scientific evaluations and make final funding decisions <br/><br/>&bull;<span style='padding-left: 30px'></span>A presidential appointee would review all grants and make final funding decisions.<br/><br/>&bull;<span style='padding-left: 30px'></span>NIH must implement pre-issuance reviews for all discretionary grants, evaluating them for alignment with agency priorities and the &ldquo;national interest&rdquo; before awards are issued<br/><br/>&bull;<span style='padding-left: 30px'></span>New requirements mandate incl...

These changes will be disastrous to the research community and to the American public! This is all political. Politics has no place in science. Doctors, researchers, graduate students, and all types of scientists need the freedom to study and collaborate with their peers in other countries. Not all diseases are isolated to just one country, or one gender, or one race. Politicians should not be deciding what gets funded, who gets to go to what conference, or what gets published. Politicians don&rsquo;t understand how indirect cost rates (F&amp;A) works or how it is calculated. These changes should NOT go into effect.

&sect; 300.414 Indirect costs. Page-67. Limitation of indirect costs on training grants to eight percent of MTDC hobbles valuable scientific research. The exclusion of the costs of &quot;tuition and related fees, direct expenditures for equipment, and subawards in excess of $25,000&quot; leaves only a relatively paltry percentage of the overall costs of a training program, which is then the basis upon which the eight per cent allowance is calculated. The percentage needs to be higher, or the exclusions need to be revised, in order for training programs to be funded at a level that makes them effective or even financially feasible.

Docket: OMB&ndash;2026&ndash;0034<br/><br/>[200.202, 200.204, 200.340]<br/><br/>I am submitting this comment as a concerned citizen in opposition to the proposed revisions to the Regulation for Federal Financial Assistance (2 CFR Part 200).<br/><br/>The proposed rule would eliminate grant programs and funding criteria designed to serve LGBTQ+ populations, characterizing them as unlawful DEI preferences. This framing is both legally contested and practically harmful. The data are clear: LGBTQ+ people &mdash; and transgender people in particular &mdash; are among the most economically vulnerable Americans, and are disproportionately dependent on federally funded services for basic healthcare and housing stability.<br/><br/>On healthcare: According to KFF, LGBTQ+ adults are nearly twice as likely as non-LGBTQ+ adults to rely on Medicaid as their primary source of health insurance (25% vs. 15%), and are more likely to lack a usual source of care (19% vs. 12%). The Williams Institute at UCLA estimates that approximately 1.8 million LGBTQ+ adults depend on Medicaid as their primary insurance &mdash; and that cuts would most profoundly impact transgender people and lesbian and bisexual women. More than half of LGBTQ+ adults (51%) report difficulty affording basic necessities including food and housing, compared to three in ten non-LGBTQ+ adults, according to KFF&#39;s May 2025 Heal...

The Regulation for Federal Financial Assistance declares that its aim is to &ldquo;improve transparency, accountability, and oversight for Federal awards across the Federal Government.&rdquo; What it is is a far-reaching regulation which lays a legal path to making the lives of a small subset of Americans, those who are transgender, miserable. It would prevent transgender Americans from gaining employment, getting loans, getting housing, getting a fair education, medical attention, doing research&hellip; in short, prevents them from being active and productive in vast aspects of American life. This Regulation is an expression of the current administration&rsquo;s culture war against our nation&rsquo;s LGBTQ population.<br/><br/>What is the point of targeting transgender Americans? Why not try to lift up the lives of all Americans? Why not concentrate on laws and regulations that would improve our housing crisis, make healthcare affordable, do something meaningful about gun violence, strengthen K-12 education, create a rigorous vocational apprenticeship system, ensure safe drinking water, improve infrastructure, and reduce inflation?<br/><br/>But instead, the proposed Regulation would codify the administration&#39;s anti-trans executive orders into binding federal policy, imposing a blanket prohibition on federal funds going toward &quot;gender ideology&quot;&mdash;with terms...

Sections addressed: [200.205], [200.300], [200.340], [200.432], [200.454], [200.461] <br/><br/>I am a faculty member and principal investigator at the University of Pennsylvania, where I direct a federally funded laboratory studying coronavirus biology and pathogenesis. I have been supported continuously by multiple grants from NIH since 1981. The work I did early in my career contributed important basic information about coronavirus biology and pathogenesis contributing to our ability to understand and combat SARS-CoV-2. I have served as a peer reviewer for full 4-6 year cycles in three NIH study sections and have also participated in many ad hoc reviews as well for NIH. I will state how some of these new regulations would impact my research program in the sections below. These plans will strangle scientific discovery, preventing it from advancing as it should and the result will be American science falling behind that of other nations. <br/><br/>The stated goals of this proposal &mdash; transparency, accountability, and oversight of taxpayer dollars &mdash; are ones I share. But its operative provisions do not serve those goals. They transfer the core decisions of federal research funding from qualified scientific experts to political appointees, at every stage of the funding lifecycle. Several provisions would raise administrative burden rather than reduce it, and the cum...

I am writing to express my strong opposition to OMB-2026-0034. Government policies should be evidence and research based, regardless of any one political agenda. This rule would do precisely the opposite of promoting transparency and accountability by censoring research that does not align with the administrations&#39; policy priorities. I am especially concerned by the following sections of the rule:<br/><br/>Section 200.205: By making peer review advisory and mandating that senior political appointees review discretionary awards to ensure alignment with shifting political priorities, this rule introduces unprecedented political interference into scientific funding. The peer review system, a process widely regarded as the gold standard for evaluating scientific merit and funding decisions, is built on the rigorous evaluation of proposals by independent scientific experts. This ensures that funding decisions are based on mission-driven scientific innovation and potential impact &ndash; not political considerations, which is why the U.S. has consistently led the way in driving breakthrough research and accelerating technological innovation. Shifting final authority to political appointees will significantly undermine the grant review and award system and could distort federal research priorities based on ideological or partisan agendas, stifle innovation, and erode public con...

I am submitting this comment as a university faculty physician and researcher whose work depends on rigorous peer review, stable research funding, and collaboration across institutions and countries. My comments focus on provisions that may affect the independence of scientific grantmaking, the predictability of federal research awards, and the ability of U.S. researchers to maintain productive international collaborations.<br/><br/>Federal research funding has been one of the most successful public investments in American history. American leadership in biomedical research, public health, and scientific innovation has been built on a grantmaking system that relies on expert peer review to evaluate scientific merit, feasibility, innovation, and potential public benefit. I have firsthand experience with the extensive safeguards already built into federal research funding, including scientific review, conflict-of-interest requirements, institutional oversight, and ongoing reporting and compliance obligations.<br/><br/>I am concerned that aspects of the proposed revisions could introduce uncertainty regarding the role of political officials in funding decisions or expand discretionary authority to deny or terminate awards without clearly articulated scientific, programmatic, or legal standards.<br/><br/>The proposal should address several questions. First, what evidence demonst...

I am a post-doc in University of Central Florida (UCF). I already have some scientific papers published in some of the most recognized journals in the world (all of which are American). I came to this country to do research. To be in the heart of where scientific knowledge is built. And this rule change threatens to end American science as we know today, and make it no more than a fa&ccedil;ade to promote the political agenda of whoever is in charge at the grants proposal time. <br/>Actually, I am not against the entire rule. The E-verify obligation seems reasonable to me. But the rule as it is now is extremely dangerous. To remove peer-review and make grant approval dependent on a political appointee is absolutely undesirable and will surely politicize science and grants will not be delivered by merit. Also, not funding publication costs is absolutely unjustified. If scientists cannot publish their findings, science will simply not have an impact in society at all! Going to conferences is also important, and often times expensive. But the rule estates that the conference must be submitted on the original grant submission. The problem is we usually don&#39;t know what conferences will come up when we have important results to show the community. And if we can&#39;t go to conferences, again, we can&#39;t make our results noticeable to the international community and cannot en...

I am a current medical resident undergoing training at an academic institution, and my peers and I often participate in NIH funded research and I also care about federally funded medical research since it directly impacts the care I am able to provide my patients. There are several portions of this regulation that I have concerns about. <br/>1. [&sect;200.205 ] - Political appointees&rsquo; review of discretionary grants, inability to defer to peer review or career staff, and narrowing the purpose of the grants to &ldquo;advance the President&rsquo;s policy priorities&rdquo; creates a biased research system. Having political appointees instead of scientists and experts in the field determine which research is permissible and deserving of grants sets up a system where political will and biases guide scientific research. This is harmful to scientific advancements as the provision risks undermining merit-based grantmaking by inserting political review into funding decisions. These were previously informed by subject matter experts and peer evaluation, allowing for more objective evaluation. It may also reduce public confidence in objectivity of federal funding programs, discourage innovative or controversial research topics, and produce inconsistent funding for projects, thereby decreasing completion rates of projects. NIH studies often span multiple years and takes time to pro...

I am a postdoctoral researcher at the University of California Davis. The proposed changes requiring pre-approval to use federal funding for conference attendance and publication charges would seriously hamper our universities&#39; ability to conduct research. Many of my own federally funded research has started at conferences. Attending conferences is critical for ensuring that science moves forward. It is not reasonable to expect that researchers can budget in advance for all such professional opportunities that may present themselves years in advance. Similarly, requiring pre-approval for publication costs would seriously hamper our ability to share our work. This would lead to less transparency to the American public, not more. Given the long time horizons for publishing papers, again, it is not possible to know years in advance what specific publication charges will be.

I am submitting this comment to urge the withdrawal of the proposed Regulation for Federal Financial Assistance in its entirety as a concerned member of the public. The rule as drafted is procedurally and legally deficient; OMB is obligated to address this in the final rule. I submit the following objections for the administrative record:<br/><br/>1. Several provisions rest on undefined standards and are therefore arbitrary and capricious<br/>[200.205] [200.300] The rule conditions funding on compliance with a &quot;Gold Standard Science&quot; standard that is never defined in concrete or measurable terms, and on criteria such as advancing &quot;the President&#39;s policy priorities&quot; and avoiding &quot;anti-American values.&quot; Under the Administrative Procedure Act, an agency must articulate an intelligible principle that the regulated public can understand and that a reviewing court can evaluate. Standards that exist only as labels, applied at the unguided discretion of political appointees, provide neither. They give applicants no notice of what conduct is required and supply no basis for reasoned, reviewable decisions. These provisions are arbitrary and capricious on their face and should be removed.<br/><br/>2. The rule fails to consider serious reliance interests<br/>[200.340] The rule permits termination of active, multi-year awards because an appointee deems t...

Re: Comments on Proposed Rule, &ldquo;Regulation for Federal Financial Assistance&rdquo; (Docket OMB-2026-0034)<br/><br/>To the Office of Management and Budget:<br/>I submit these comments as a federally funded researcher. While I support efforts to improve accountability, transparency, and research integrity in Federal financial assistance, several proposed revisions to 2 CFR part 200 could undermine objective scientific merit review and create uncertainty for research institutions.<br/><br/>[200.205] Merit Review of Proposals<br/>Peer review should remain the primary mechanism for evaluating scientific merit. Expert reviewers are best positioned to assess scientific quality, feasibility, innovation, qualifications, and potential impact. If senior-appointee review is retained, it should be limited to statutory, regulatory, budgetary, or compliance considerations and should not override scientific peer review without documented justification.<br/><br/>Terms such as &ldquo;national interest,&rdquo; &ldquo;anti-American values,&rdquo; and similar policy-based criteria should be clearly defined or removed. Research applicants should be evaluated using transparent criteria published in the Notice of Funding Opportunity and applied consistently across all proposals.<br/><br/>[200.205(b)(3)] Indirect Cost Rates<br/>The proposed preference for institutions with lower indirect cost ...