Regulations.gov Comments

[200.432, 200.454, 200.461, 200.206, 200.450]<br/><br/>To Whom it May Concern:<br/><br/>I am a physicist and chair of my department, working on high-energy physics experiments of national importance.<br/><br/>I am writing in my personal capacity to oppose the proposed revisions to sections 200.432, 200.454, 200.461, 200.206, and 200.450 that would restrict typical professional expenses, curtail the communication of scientific results, and place excessive scrutiny on the activities of scientists.<br/><br/>I am a member of the American Physical Society. This organization has sponsored numerous opportunities for me to present my research at conference and in publication. It provides crucial information about research directions in physics and data and summaries of trends in physics employment and education which have enabled me to make educated decisions about my own career and in the leadership of my department.<br/><br/>Scientific conferences are excellent opportunities to drive results forward and learn of new trends in the field, and to provide a forum where future leaders in the field can emerge. The pace of science is fast, and it can be difficult to predict when a scientific result will be ready to be shown at conference or to know which venues might be the most important in a given year. Trusting scientists with making the decisions about how to use their travel dollars...

This proposal would create significant uncertainty for federal grant applicants and awardees and increase administrative and compliance costs for recipients. Additionally, the changes proposed raise questions about expanded potential for political involvement in federal grantmaking by Administrations of either party, which may create greater instability in federal programs. Placing all grantees (including formula grants) under constant threat of penalty or termination, would increase the coercive power of the executive branch over its grantees.Taken together, these two changes would allow a grantmaking process so political as to render it unrecognizable and unfit to effectively deliver for our nation&rsquo;s needs.

I respectfully oppose the proposed revision to 2 CFR &sect;200.432 that would limit allowable conference costs to those that are expressly approved by the Federal agency and included in the terms and conditions of the Federal award.<br/><br/>While accountability for federal funds is important, this proposed change would create significant administrative burden for school districts without a corresponding improvement in fiscal stewardship. Districts already operate under extensive federal, state, and local oversight requirements and must demonstrate that all expenditures are reasonable, necessary, allocable, and aligned with program objectives.<br/><br/>Requiring explicit Federal agency approval for conference attendance would add another layer of review and documentation, increasing the workload of grant managers, fiscal officers, and program administrators. District personnel would be required to review award conditions, seek additional guidance from state and federal agencies, document approvals, and potentially amend budgets or grant applications before participating in professional development activities. These administrative requirements would divert limited staff time and resources away from serving students and implementing federally funded programs.<br/><br/>The proposal would also delay access to professional development opportunities that are essential to the effec...

I am a researcher in astrophysics and strongly oppose the proposed changes to federal grant regulations. My work depends on competitive peer-reviewed funding, access to scientific conferences, publication of research results, and collaboration with researchers across institutions and countries. The proposed rules would undermine these fundamental components of the scientific enterprise.<br/><br/>I am particularly concerned about provisions that would allow political appointees to override peer-review recommendations and permit grants to be terminated after awards have been made. Scientific funding should be based on scientific merit, technical feasibility, and potential impact, not changing political priorities. The possibility of discretionary grant termination would create uncertainty for ongoing research programs and discourage long-term scientific projects.<br/><br/>I am also concerned by restrictions on conference participation, publication costs, and international collaboration. Scientific conferences are essential for sharing results, obtaining feedback, building collaborations, and training the next generation of researchers. Likewise, publications are the primary mechanism by which scientific knowledge is disseminated and evaluated. Limiting support for these activities would reduce the impact and visibility of federally funded research.<br/><br/>Modern scientific r...

, June 17, 2026 at 12:36:12<br/>Changes proposed under &sect;&thinsp;200.421 badly misunderand the role of scientific publications. These are very important for conducting science, as they are the main method for making results known so that others can refute them, expand upon them, contact the scientist-authors in order to plan future studies or to correct errors, and countless other aspects. Publications in peer-review articles are the main means for scientists to learn about errors in methods or in inference that they do not recognize in their own work. This proposed change does the opposite of what is intended &ndash; it will not &ldquo;ensure that Federal financial assistance is directed toward achieving the programmatic objectives of the award,&rdquo; but rather it will diminish the effectiveness, accuracy and quality of the research grant award. Exactly contrary to what is stated, publication costs are in fact both inherent and necessary to carry out the core programmatic objectives of most Federal awards. Likewise for changes under Section 200.432&mdash;Conferences; it is unworkable for the scientific team to know years in advance which specific conferences will be most suitable, or even which meetings will be held, when they prepare their funding application and determine the terms and conditions of the award; to obtain permission retroactively is both an infri...

I am writing to comment on the U.S. Office of Management and Budget proposed rule to make journal publication costs unallowable under federal awards, among other outcomes. I am writing as an individual scholar and museum anthropologist.<br/>Federal research funding represents a substantial public investment. Its value is realized not when research is &ldquo;completed,&rdquo; but when findings are shared and therefore open to critique and to build upon. I believe prohibiting the use of federal grant funds for publication-related expenses would create new barriers to disseminating federally supported research, especially for scholars and the interested public with fewer resources; early-career researchers; and those working in disciplines where grant funding is already modest.<br/>The proposal also risks narrowing the range of publication options available to researchers, siloing research and concentrating commercial publishers&rsquo; power. Decisions about where and how to publish should be guided by fit, audience, and peer review, not by whether an individual scholar, or particular publisher, can subsidize costs of dissemination.<br/>Federal agencies invest in research because new knowledge benefits society. Publication is not superficial to that goal. It is the principal means by which that goal is achieved. For that reason, I urge OMB to reconsider this proposed restrictio...

Proposed &sect;&thinsp;200.220 languages prohibits recipients will chill recipient&rsquo;s ability and willingness to engage in support bilateral or multilateral collaborations, agreements, programs, or activities outside of the US. This is said to apply whether the funds are used directly, or whether they are used &ldquo;indirectly,&rdquo; the latter being a completely ill defined and hard-to-understand criterion. It specifically says that &ldquo;The prohibition would apply regardless of whether Federal funds are used for direct programmatic activities, research, technical assistance, travel, or indirect costs allocable to such collaborations.&rdquo; This is clearly an unwise and unworkable policy as it would seem to prohibit freedom of association, freedom of communication, and exchange of ideas, technologies and materials even for projects that fall outside of the scope of the federally funded project. Staff and faculty of research institutions are almost always partially funded through federal and other governmental support, and also through non-grant funds including student tuition, endowments and investment income, clinical income to the medical center, etc. They are not employees of the government nor is it possible for each of their activities, written statements, speeches, presentations, conference-organizing activities, and the like to fully and clearly attri...

The basis is inadequate for claiming that changes in &sect;&sect;&thinsp;200.204 through 200.206 related to funding opportunities, review and selection of recipients, will &ldquo;emphasize the need for merit-based selection of recipients for discretionary awards.&rdquo; The new policy moves away from objective scientific review which has been the bedrock of federal allocation of research funding, to poorly-defined criteria. Several vague terms and standards (&ldquo;divisive ideologies,&rdquo; &ldquo;Anti-American values&rdquo; are completely unrelated to scientific merit per se. Moreover, by instituting a preference for giving discretionary awards to institutions with lower indirect cost rates, this selection criterion has nothing to do with merit.<br/><br/>

[200.461] publication expenses: The language in 200.461 refers to decisions to be made on a &quot;case-by-case&quot; basis, but it is unclear whether each &quot;case&quot; would be each grant award or each instance of a publication of the work funded by the grant award. It is common practice now (at least for the NIH) to set aside funds in the grant budget for publishing and this is approved before the grant is awarded. If this counts as a &quot;case-by-case&quot; decision, that language should be clarified. Alternatively, it can be read in 200.461 that each &quot;case&quot; to be evaluated would be each instance of a publication. If the latter possibility is true, it would pose a major barrier to sharing the results of the work and a huge new burden for the staff at the NIH to review these requests. For scientific work, publications are absolutely essential to distribute the knowledge gained to other scientists and physicians, and to the public. Knowledge that is kept only by the scientists themselves is pointless - the scientific discoveries would be meaningless if the methods, data and outcomes could not be shared for others to evaluate, refine and build upon. Thus, making publication costs unallowable would undermine the entire purpose of government-funded science and render the funds completely wasted. Please clarify this and ackowledge that for scientific research and ...

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The OMB published its 400-page proposal OMB-2026-0034, on a Friday afternoon with a comment window which closes July 13, mid-summer, after most faculty have left campus. Yet these regulations affect scientists&rsquo; ability to conduct research, support trainees, hire experienced researchers, and disseminate results. Following are my objections to each section:

To: Office of Management and Budget (OMB)<br/>Re: Public Comment Opposing Proposed Rule 2 CFR Part 200 (Docket No. OMB-2026-0034)<br/>From: Charles P. Eck, Ph.D., Retired Chemical Professional<br/><br/>The Office of Management and Budget frames Docket OMB-2026-0034 as an administrative update designed to improve oversight and efficiency. <br/>This is a comfortable fiction. <br/>In reality, this proposed regulation is a calculated dismantling of the firewall between objective scientific inquiry and partisan politics, engineered to convert federal research funding into a political spoils system.<br/><br/>Federal research funding is anchored to the inviolable standard of meritocratic peer review. Under the Administrative Procedure Act (APA), agency rulemaking must not be &quot;arbitrary and capricious.&quot; Replacing consensus-based scientific evaluation with the ideological whims of political appointees flagrantly violates this standard, substituting rigorous methodology with partisan compliance.<br/><br/>Specific Provisions Addressed<br/>As currently published, the proposed rule introduces the following immutable structural changes to federal grant administration under 2 CFR Part 200:<br/><br/>Subordination of Peer Review: Scientific peer review is officially demoted to &quot;advisory&quot; status, legally decoupling grant awards from scientific merit.<br/><br/>Political Pre...

I respectfully oppose the proposed revision to 2 CFR &sect;200.432 that would limit allowable conference costs to those that are expressly approved by the Federal agency and included in the terms and conditions of the Federal award.<br/><br/>While accountability for federal funds is important, this proposed change would create significant administrative burden for school districts without a corresponding improvement in fiscal stewardship. Districts already operate under extensive federal, state, and local oversight requirements and must demonstrate that all expenditures are reasonable, necessary, allocable, and aligned with program objectives.<br/><br/>Requiring explicit Federal agency approval for conference attendance would add another layer of review and documentation, increasing the workload of grant managers, fiscal officers, and program administrators. District personnel would be required to review award conditions, seek additional guidance from state and federal agencies, document approvals, and potentially amend budgets or grant applications before participating in professional development activities. These administrative requirements would divert limited staff time and resources away from serving students and implementing federally funded programs.<br/><br/>The proposal would also delay access to professional development opportunities that are essential to the effec...

If a Politically Appointed Administration Staff becomes a requirement, can existing staff be appointed in that role? DD Councils have limited ability to hire non-programmatic staff per the DD Act. Allowing existing staff to fill this role would help.<br/><br/>Regarding the change in Section 200.320&mdash;Procurement Methods, cost reimbursement allows us to deny questionable reimbursement requests. Discouraging cost reimbursement puts federal awarding agencies in a position of paying up front for something that might not be allowable. This potentially removes our ability to deny costs.

I respectfully oppose the proposed revision to 2 CFR &sect;200.432 that would limit allowable conference costs to those that are expressly approved by the Federal agency and included in the terms and conditions of the Federal award.<br/>While accountability for federal funds is important, this proposed change would create significant administrative burden for school districts without a corresponding improvement in fiscal stewardship. Districts already operate under extensive federal, state, and local oversight requirements and must demonstrate that all expenditures are reasonable, necessary, allocable, and aligned with program objectives.<br/>Requiring explicit Federal agency approval for conference attendance would add another layer of review and documentation, increasing the workload of grant managers, fiscal officers, and program administrators. District personnel would be required to review award conditions, seek additional guidance from state and federal agencies, document approvals, and potentially amend budgets or grant applications before participating in professional development activities. These administrative requirements would divert limited staff time and resources away from serving students and implementing federally funded programs.<br/>The proposal would also delay access to professional development opportunities that are essential to the effective implementa...

I&#39;d like to comment on this proposed change as a PhD student in ocean acoustics. The United States is the world leader in scientific output, and that impact on our national security interests is near impossible to quantify. I&#39;d like to take some time to note some of the effects of the different proposals would have on US science. <br/><br/>&sect;200.204 allows for &quot;non-competitive&quot; funding opportunities. This could lead to proposals without scientific merit to be funded at the discretion of appointees; this does not reflect the principles of free market competition.<br/>&sect;200.205 changes how proposal merit is measured. &quot;senior appointees must conduct these reviews and apply specific principles when evaluating proposals. These principles include ensuring that discretionary awards advance the President&#39;s policy priorities, prohibit the use of funds for discriminatory or otherwise impermissible purposes, and emphasize ensuring compliance with applicable law. Additionally, the proposed revisions encourage agencies to broaden the range of recipients, prioritize institutions demonstrating rigorous and reproducible scholarship, incorporate benchmarks for measuring performance of &ldquo;Gold Standard Science,&rdquo; and direct agencies to weigh institutional commitment to research integrity when making award decisions.&quot; Discriminatory or otherwise...

I am writing in EMPHATIC opposition to the proposed rules to put in place OMB overview &ndash; i.e. politics-based review &ndash; of grant funding of scientific agencies like NSF and NIH, along with many other agencies, to prioritize and assert political dominance over otherwise expertise- and merit-based steering of funding for the good of the people. That this is a Project 2025 wish list and far right agenda-derived policy shift is clear immediately in even the Executive Summary of the &gt;400 page document for which just 45 days were allowed for public comment. Even here, in a purportedly official document, are words and phrases of the right and far right, expressing disdain for &ldquo;woke policy agendas,&rdquo; &ldquo;DEI initiatives and activities,&rdquo; influence of &ldquo;far left activists&rdquo; and &ldquo;neoMarxist perspectives.&rdquo; When did serious, scholarly investigations and determinations for funding priorities get replaced with such meaningless and buzz-word driven ideologies?! This must stop, and every bit of this agenda must be stopped in its tracks!<br/><br/>Moreover, restrictions on use of grant funding to support attendance, presentation and collaboration development at scientific conferences, as well as inability to pay large publication fees now in place in part due to the obligation of government-sponsored work to be published &ldquo;open ac...

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I am a federally funded biomedical scientist and principal investigator. I strongly oppose the proposed revisions to 2 CFR Part 200 in docket OMB-2026-0034.<br/><br/>The proposed rule is described as improving transparency, accountability, oversight, and efficiency. In practice, several provisions would do the opposite. They would make federal grantmaking less predictable, less expert-driven, more politically vulnerable, and more administratively burdensome.<br/><br/>First, the proposed changes to &sect;200.205 would weaken expert-driven merit review by adding senior appointee pre-issuance review and emphasizing that peer review is advisory. Scientific peer review is imperfect, but it is the best available system for evaluating complex technical proposals. A political appointee cannot reasonably judge the mechanistic validity, rigor, or feasibility of a microbiology, cancer biology, immunology, engineering, or public-health proposal better than expert reviewers. If applicants believe awards may be approved or denied based on shifting political priorities rather than scientific merit, they will stop proposing the most innovative work and instead try to guess what language is politically safe. That is not accountability. It is politicization.<br/><br/>Second, the proposed changes to &sect;200.340 would make multi-year research awards unstable by allowing termination when an aw...

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I am submitting this comment in strong opposition to the proposed revisions to CFR Part 200 (Docket OMB-2026-0034) as a concerned citizen and early career scientist.<br/><br/>This proposed rule is an attack on American science and the integrity of federal grants, and jeopardizes decades of American intellectual leadership globally. As an early career scientist and an American citizen, I am seriously concerned about the consequences these changes will make to industrial, medical, and academic scientific research and accessibility domestically and internationally. By placing political appointees above scientific peer reviewers, allowing active grants to be terminated for undefined political reasons, and prohibiting scientific discussion and collaboration by limiting international collaborations and banning journal subscriptions and publication costs, these proposed rules undermine scientific integrity and guiding principles of logic.<br/><br/>Additionally, these rules will not only impact scientific grants, but every federal grant across all agencies. Impacted grants include necessary funds for early childhood education, rural health initiatives, transportation, and infrastructure. These grants promote the life, liberty, and pursuit of happiness that ought to be available to all Americans as outlined in the Declaration of Independence 250 years ago. <br/><br/>I urge the OMB to...

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As a retired public school teacher, Returned Peace Corps Volunteer, parent and grandparent, Roman Catholic, and citizen, I strongly oppose the proposed rule titled &ldquo;Regulation for Federal Financial Assistance,&rdquo; recently issued by the Office of Management and Budget (OMB), as it would significantly undermine the ability of: a) educational and research institutions to provide the necessary scientific and technical knowledge for the integrity, effectiveness, and global competitiveness of the United States; b) religious and non -profit advocacy groups that serve the residents of this land who live on the margins; c) institutions that provide the medical research that advances remedies for the maladies of human life; d) groups that lawfully support free and fair elections.<br/><br/>The proposal has received strong condemnation from the scientific and research communities, with stated concerns that the rule would relegate traditional scientific peer review to a purely advisory role, giving senior political appointees final approval on grants. The proposed rule would also provide agency leaders with the authority to suspend or terminate grants with no path for recipient appeals, destroying the financial predictability that research relies on. The rule would also ban the use of grant funds to cover scientific publication costs unless explicitly required by statute, effe...

The stated goals of this proposed rule &mdash; transparency, accountability, and oversight of taxpayer dollars &mdash; are ones I share. But its operative provisions transfer core funding decisions from qualified scientific experts to political appointees at every stage of the funding lifecycle. I urge OMB to withdraw or substantially revise the rule, and in particular to strike &sect;200.205 and &sect;200.340.<br/>I am a Professor of Pathology and Cell Biology and Vice Chair for Research and Training at Columbia University, studying the cell biology of early Alzheimer&#39;s disease to identify new therapeutic strategies. My research has been continuously NIH-funded since 2006, and I have served on at least 12 study sections, including four in 2025&ndash;2026: ZRG1 F05-A (20) Cell Biology, Developmental Biology, and Bioengineering; ZRG1 F05-A 20 L Cell Biology, Developmental Biology, and Bioengineering; ZRG1 F03-C H (21) Fellowships: Neuroimmune and Neuroinflammation in Aging and Neurodegeneration; and ZRG1 NPB-K (51) R Risk Factors for Neurodegeneration.<br/>[200.205] &mdash; Political Appointee Pre-Issuance Review .The existing study section model is not a bureaucratic formality &mdash; it is a carefully engineered system for high-quality, defensible funding decisions. Study sections assemble rotating panels of credentialed experts matched precisely to the science under re...

As an anthropologist and an educator predominantly of undergraduate students in the USA, federal funding has been critical to my ability to not only develop research that was of importance to helping the federal government determine inefficiencies in how federal funding dollars were spent and offer advice for how they might be more effectively allocated, but also in training the next generation of US-based adults through experiential learning opportunities, dynamic learning opportunities, and training on how to make non-profit and philanthropic endeavors more effective, and helping students think more critically about the possibilities for improving overall societal welfare at home and abroad. Further, federal funding was what enabled me to travel to my field site in east Africa, where I was also able to assist President George W. Bush and his administration to understand the role of US assistance in the health care sector there, and enable his visit in 2008 to be tremendously successful. Without that funding, I also would not have been able to publish my research results, some of which I saw reflected in the America First Global Health Plan released in Fall 2025. Federal funding allocations through the previous unbiased process of experts evaluating proposals based on merits, and enabling conference and travel funding as well as publication costs, while ensuring stability o...

Summary<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 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/>About Me<br/>I am a reproductive biologist, and my research has great medical, social, and economic impact on the lives American Citizens.<br/>The provisions that displace expert judgment<br/>[200.205] Pre-issuance review by political appointees, with peer review demoted to advisory. The proposal requires senior appointees to conduct a pre-issuance review of every discretionary award, directs that awards &ldquo;demonstrably advance the President&rsquo;s policy priorities,&rdquo; and specifies that appointees &ldquo;must not ministerially ratify or routinely defer to&rdquo; peer reviewers, w...

As a member of the research community, I am concerned that several proposed changes may increase administrative burden and uncertainty for institutions conducting federally funded research, the results of which positively impact all of our lives.<br/><br/>While accountability and responsible stewardship of federal funds are important goals, I encourage OMB to carefully consider the potential impact of expanded compliance requirements, additional certification obligations, increased scrutiny of collaborative research activities, and broader authority to suspend or terminate awards. These changes may divert resources away from scientific discovery, increase administrative costs, and create barriers to research collaboration and innovation.<br/><br/>I respectfully request that OMB carefully evaluate the implications of these proposed revisions and ensure that any final rule appropriately balances accountability with the need to support efficient, effective, and collaborative research.<br/><br/>Thank you for your consideration.&nbsp;

Please see attached pdf with comments regarding OMB-2026-0034.

This is a comment on the proposed &quot;Regulation for Federal Financial Assistance&quot; rule.<br/><br/>Section 200.432 Conferences. This rule is absurd micromanaging at its worst. How many labs are funded by the federal government, and how many conferences do members of those labs attend in a given year? For my lab alone, members attend on average at least 2-3 conferences a year. Many are local, and only some are international. How would it even be possible for a federal &ldquo;minder&rdquo; to even check on all these conferences? And as research in any lab progresses, it is common to become aware of new conferences that would not have been relevant at the time the grant was first awarded. This rule is also entirely incompatible with mechanisms like the Maximizing Investigators&rsquo; Research Award (MIRA) mechanism at the NIH. The goal of the MIRA program is to provide investigators with &ldquo;greater stability and flexibility, thereby enhancing scientific productivity and the chances for important breakthroughs.&rdquo; See funding announcement: PAR-26-121. How can a lab have any flexibility if it has to comprehensively list potential conferences to attend at the time of writing a MIRA grant application? The answer is it is impossible to have flexibility under this proposed rule.<br/><br/>Section 200.461 Publication and printing costs. Publication is central to the scien...

I write in my personal capacity as a researcher in statistics, machine learning, and artificial intelligence. The views expressed here are my own and should not be taken to be an official position of my employer or any organization. <br/><br/>In particular, I wish to comment on the practical ramifications of two proposed changes: Section 200.432&mdash;Conferences and Section 200.461&mdash;Publication and Printing Costs. Each of these would substantially disrupt the dissemination of research findings, as well as creating considerable paperwork burdens on funding agencies. The financial costs that these proposals target are a small percentage of research outlays, making the disruptive effects of the changes massively disproportionate to the savings they would generate. Modifications to both recommended rule changes can make substantial progress towards their stated goals without jeopardizing the dissemination of scientific results. <br/><br/> Section 200.432&mdash;Conferences effectively requires all conference costs to be enumerated in the proposal budget, or to receive explicit approval from funding agencies. Conferences are not just a (very valuable) opportunity for researchers to learn about developments in their field, they are a key component of research dissemination and peer feedback. In fields such as Computer Science, and Artificial Intelligence, refereed confe...

I am a federally funded (NIH) tenure-track faculty member at a Research I institution in the US. I began my position in 2022 and was awarded an R35 grant from the NIGMS of the NIH in 2024. I conduct fundamental biological research that lays the foundation for future advances in disease diagnosis, treatment, and prevention. I also train the next generation of researchers through mentorship and teaching. <br/><br/>I am writing in strong opposition to the proposed revisions to 2 CFR Part 200 (Docket OMB-2026-0034).<br/><br/>I have substantial concerns that the proposed changes will stifle scientific progress in the United States, abolishing our role as a leader in research, health, and security. This is a serious threat to our national security and the well-being of our citizens. <br/><br/>These concerns arise out of many of the proposed changes, but most significantly those listed below:<br/><br/>&sect;200.205 and &sect;200.205(d) &mdash; Political appointee pre-issuance review and the elimination of binding peer review<br/><br/>&sect;200.340 &mdash; Discretionary termination on undefined &ldquo;national interest&rdquo; grounds<br/><br/>&sect;200.300 &mdash; Replacement of anti-discrimination protections with anti-DEI prohibitions<br/><br/>&sect;200.220 and &sect;200.303 &mdash; Foreign collaboration prohibition and E-Verify mandate<br/><br/>&sect;200.202, &sect;200.202(d), &s...

Comment on Proposed Revisions to 2 CFR Part 200<br/><br/>To Whom It May Concern:<br/><br/>I respectfully oppose several proposed revisions to 2 CFR Part 200 because they would weaken the effectiveness, transparency, and integrity of federally funded research.<br/><br/>Publication Costs (Section 200.461)<br/><br/>The proposal would make publication costs unallowable unless specifically approved by a federal agency. This change would undermine public access to federally funded research. As publishers increasingly rely on Open Access models, Article Processing Charges (APCs) have become a necessary cost of communicating scientific results. Taxpayers who fund research should have access to the knowledge generated by their investment. Restricting publication funding would slow scientific progress, limit dissemination of discoveries, and disproportionately impact researchers at institutions with limited resources.<br/><br/>Conference Attendance (Section 200.432)<br/><br/>The proposal would require explicit agency approval for conference attendance. Scientific conferences are essential for presenting results, obtaining expert feedback, developing collaborations, training students, and generating new research ideas. Many important scientific advances arise from interactions among researchers at professional meetings. Additional approval requirements would create unnecessary administ...

For the last century, American scientific research has been the envy of the entire world, field by investment in research and education at every level. The United States university system is an engine for economic prosperity, bringing in the best and brightest from around the world to work and study. I am a graduate of a Masters in professional counseling and have benefited from the research that went into my field as a counselor. Government STEM funding has led to breakthrough treatments and technologies that improve our health, extend our lives, and grow our economic and political power. I have benefited from govermental funded research both in my professional life as a mental health counselor and in my personal life as an avid gardner and lives and dies by the accurate weather forecast. These proposed changes to the Regulations for Federal Financial Assistance undercut all of this. These changes transfer decision-making authority from scientific experts to political appointees in the grantmaking process [200.205]. Numerous provisions will allow the federal government to exclude individuals and institutions from funding for political reasons. <br/><br/>Science costs money, and transformative scientific research is planned out on the scale of years. When any grant can be terminated at any time for any reason, as would be permitted under these changes [200.340], it is imposs...

I am an associate professor of biology who has been supported by NIH funding in the past. Based on my past experiences and the significant findings I have seen from other NIH-funded research, I urge OMB to withdraw this position. <br/><br/>In particular, the following sections are of concern: <br/><br/>Section 200.205 (p. 15) - this section seems to relegate peer review to a secondary role. Experts in the same or a similar field are the ones who best understand what questions proposed would move the field forward if answered. They will also best understand what is feasible, and the direction the field is headed. They must remain in a primary role in funding decisions to keep the grant system focused on the questions that advance society rather than just serving at the will of the current administration. <br/><br/>Section 200.340 (0. 28) - this section allows easier termination of grants without providing the level of justification traditionally expected. Much research takes time, and scientists are playing a long game in terms of generating results. A lack of confidence that funding will carry through the duration of the grant means difficulty in setting long-term research goals, and a potential waste of federal funds if the grant is terminated before the research project is completed. This will reduce proposals on long-term research studies. Related, the academic world is s...

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<br/> To the U.S. Office of Management and Budget: <br/>Re: OMB-2026-0034, Office of Management and Budget (OMB) Regulation for Federal Financial Assistance <br/>I oppose the U.S. Office of Management and Budget&rsquo;s (OMB) proposed changes to overhaul the set of rules, known as the Uniform Guidance, governing federal grants, cooperative agreements, and other monetary awards to nonprofits, state and local governments, and other grantees. <br/>If implemented, the OMB proposal would create significant financial risk and instability for federal grantees, making it more difficult to provide vital services to communities. If implemented, grantees will be faced with unpredictable financial, legal, and reputational risks that increase the costs of accepting federal awards while decreasing the benefits. Many effective and qualified grantees may be unable to accept those risks. This could lead to disruptions to essential services, including housing, community development, health, education, food, shelter, community services, disaster recovery, and more in communities and states nationwide. <br/>The proposal allows federal agencies to determine discretionary federal awards based on partisan ideology, not community needs or congressional intent. OMB proposes to create a pre-approval process that allows political appointees to exclude grant proposals from consideration if the proposal...

To Whom It May Concern:<br/><br/>I am a Grants Management Specialist (GMS) certified by the National Grants Management Association and a Certified Government Financial Manager (CGFM) certified by the Association of Government Accountants, with 25 years in governmental financial management and the last 17 in federal grants. I comment in my individual capacity, drawing on direct experience with the single audit process, state audit findings, and the referral of suspected grant fraud to law enforcement. I support several proposed changes and urge OMB to use this rulemaking to close enforcement gaps it currently leaves unaddressed.<br/><br/>I. Support for &sect; 200.300(b)<br/>I support the proposed addition of &sect; 200.300(b). One observation is relevant to OMB&#39;s burden analysis: in my experience administering federally funded work in Washington State, recipients have effectively been unable to use grant funds for the activities this provision addresses, because state law restricts discriminatory practices in state contracting and federal funds administered through that authority are subject to those constraints. The provision therefore imposes little or no incremental burden on a substantial population of recipients, while advancing the rule&#39;s stated goals of clarity and consistency. I recommend OMB reflect this low marginal burden in the preamble.<br/><br/>II. The R...

I am writing to strongly oppose the proposed revisions to the Uniform Guidance governing federal financial assistance.<br/><br/>My partner is a federally-funded researcher. His work, (and the company he works for, and the work of hundreds of thousands of scientists around the country) depends on a grant system that awards funding based on scientific merit, not political alignment. If this rule was implemented, it would hurt American competitiveness, the economy, and significantly prevent effective scientific progress.<br/><br/>Replacing peer review with political appointee sign-off (&sect; 200.205) would replace scientific expertise with a review process where the criteria for approval are indistinguishable from the criteria for political conformity.<br/><br/>The panels of researchers who evaluate grant proposals are experts in their own fields and specialists to boot. They can&#39;t be replaced by political middlemen. The vague terminology applied, &quot;Gold Standard Science&quot; is unacceptable and would just enable government agencies to say no for any reason. The arbitrariness gets worse with the &quot;termination for convenience&quot; provision (&sect; 200.340) that allows the cancellation of active grants mid-project for almost no reason with no appeal process. Terminating a multi-year study halfway wastes investment money, and produces nothing.<br/><br/>Lastly, The...

Subject: Comment on Implementation of Executive Order 14332, Improving Oversight of Federal Grantmaking<br/><br/>I respectfully submit this comment as a private citizen concerned with the effectiveness, integrity, and accountability of federal grantmaking.<br/><br/>The federal government has a legitimate responsibility to ensure that taxpayer funds are spent efficiently and lawfully. However, efforts to improve oversight should strengthen evidence-based decision-making rather than replace it with increased political discretion.<br/><br/>Federal grant programs exist because Congress determined that certain public purposes -- including scientific research, education, public health, infrastructure, environmental stewardship, and community development -- serve the national interest. Federal agencies administer these programs through statutory authorities and established review processes designed to evaluate proposals according to merit, feasibility, and expected public benefit.<br/><br/>The Executive Order&#39;s emphasis on political review and alignment with presidential priorities raises concerns that funding decisions may become less dependent on objective evaluation and more dependent on the preferences of a particular administration. While elected officials appropriately set broad policy priorities, grant selection should remain grounded in expertise, statutory authority, a...

I strongly oppose the proposed rule that would make publication costs unallowable under federal research awards.<br/><br/>As an emerging scholar conducting research on migration, race, and belonging, I depend on the ability to publish and share research findings with both academic and public audiences. Publication fees, including open-access article processing charges, are often a necessary component of disseminating federally funded research. Eliminating the ability to use grant funds for these expenses would create significant barriers for graduate students, early-career researchers, scholars at under-resourced institutions, and independent researchers who do not have access to large institutional publication budgets.<br/><br/>Research has little impact if it cannot be effectively shared. Federal investments in research are intended to generate knowledge that benefits the public. Restricting the use of grant funds for publication undermines that goal by limiting researchers&#39; ability to disseminate findings through peer-reviewed journals and open-access platforms that make scholarship accessible beyond universities.<br/><br/>I am also concerned that this proposal could disproportionately affect smaller scholarly societies and independent academic journals that play a critical role in supporting specialized and interdisciplinary research communities. These organizations ...

Please see the attached comments of the Institute for Policy Integrity at New York University School of Law.

These proposals will set scientific research in the USA behind other countries and hinder young American scientists&#39; development. For young scientists to publish, they need financial support in the grants they receive to cover journal publication costs. Experts in the appropriate fields should be engaged in thorough peer review of the grants. Please refrain from changes that will cause continued brain drain in the US and allow other countries to pass us in the scienific fields.

I am a higher education grants administrator at a U.S. research institution, where I support principal investigators in managing federally funded research across multiple disciplines. I am also a doctoral student in urban education whose work depends on federally supported research infrastructure and access to scholarly literature. I write to express strong opposition to several provisions in the proposed revisions to the Uniform Guidance, including 200.205, 200.340, 200.454, 200.461, 200.202, and 200.220.<br/>Section 200.205 introduces political appointee review of discretionary awards and allows those officials to override peer review decisions. This represents a fundamental departure from the evidence-based, expert-driven review process that has underpinned U.S. scientific leadership for decades. Section 200.202 further requires programs to align with shifting administration priorities, embedding political considerations into the design of research funding opportunities themselves. Together, these provisions risk transforming scientific funding from a merit-based system into one subject to political discretion.<br/>Section 200.340 allows agencies to terminate active awards if they no longer align with the national interest, without a stable or clearly defined standard. In practice, this creates uncertainty for every multi-year grant. At the institutional level, this would...

See attached file(s)

I am adamently opposed to this new proposed rule. This proposal echoes provisions in the President&rsquo;s Budget Request that would prohibit the use of federal research funding for anything related to publishing &mdash; blocking funds for subscriptions as well as publishing charges. It would also insert political decision-making into the research and publication process. These changes raise serious concerns for researchers, society publishers, and the sustainability of independent, mission-driven organizations. I am deeply concerned that the proposed OMB regulations would severely prohibit or at<br/>best, restrict the use of federal research grants to support high-quality, peer-reviewed scientific publications. This would irreparably damage American leadership in science and technology, and would put American scientists at a heavy disadvantage. <br/><br/>Instead of prohibiting publishing costs, OMB should consider measures that preserve the allowability of reasonable publication expenses and avoid policies that would undermine research integrity, dissemination, and U.S. scientific leadership. Such measures should also promote equitable funding mechanisms that do not compromise journal sustainability or researcher choice.<br/><br/>I respectfully urge Congress to consider language in Appropriations legislation that preserves researchers&rsquo; ability to recover reasonable, g...

I am a fisheries biologist and natural resources manager with 30 years of professional experience working on aquatic invasive species, Great Lakes ecosystems, and applied fisheries science. I submit these comments in strong opposition to the proposed Federal Financial Assistance Rule.<br/><br/>I want to speak specifically about invasive carp, because I suspect few commenters will, and because this case illustrates with unusual clarity what is at stake.<br/><br/>Silver carp and bighead carp are pressing north through the Illinois River system toward the Chicago Area Waterway and Lake Michigan. If they establish in the Great Lakes, the consequences for the region&#39;s $7 billion fisheries economy would be severe and likely irreversible.<br/><br/>They are also Chinese fish. The body of scientific knowledge about their reproductive biology, spawning cues, and population dynamics has been built substantially through Chinese research institutions and active collaboration between American and Chinese fisheries scientists. That collaboration is not sentiment. It is operational.<br/><br/>Section 200.220 would prohibit federal funds for collaboration with covered foreign countries. Section 200.202(e) makes international research presumptively disfavored, requiring approval by a political appointee. Together, these provisions would sever the partnerships most essential to defending La...

I am a cognitive scientist and university researcher whose federally supported work examines how children learn from others, how social learning develops, and how learning mechanisms relate to later educational and developmental outcomes. My research depends on scientific peer review, long-term planning, pilot studies, conference exchange, publication, and the ability to follow evidence without political interference.<br/><br/>I am writing to oppose the proposed changes to federal grant rules, especially &sect;200.205, &sect;200.340, &sect;200.333, &sect;200.461, &sect;200.454, and &sect;200.432.<br/><br/>Section &sect;200.205 is especially concerning because it would give political appointees final authority over grant funding decisions while making expert peer review merely advisory. Scientific grants should be judged by scientific merit, methodological rigor, feasibility, and public value&mdash;not by whether a project fits the priorities of a particular administration. That principle should concern people across the political spectrum. We should not want research on child development, cognition, health, education, or human behavior shaped by political influence from either the left or the right.<br/><br/>Section &sect;200.340 is also deeply troubling because it would allow active grants to be terminated when the work no longer fits current government priorities, even if ...

I am a retiree, tax payer and concerned citizen who cares about federally funded research. I am grateful for the benefits medial research provides me on a daily basis; immunizations against diseases and viruses as one example. I have family members with cochlear implants, joint replacements, heart disease, cancer diagnoses and type 1 and 2 diabetes. All of them have benefited from government funded medical research. Because of these research efforts they have been able to improve their quality of life. The proposed OMB rule 200 will negatively impact government funded medical research as well as the people who rely on this research to live their lives to the fullest. <br/><br/>The following OMB provisions are of great concern to me:<br/>[209.205 and 200.202] It is alarming to me that political appointees would have the power to make research decisions. It is in the best interest of science to have experts in the field make program and funding decisions, not the political agenda of any given administration.. <br/>I request OMB not to finalize provisions 200.205 and 200.202<br/><br/>As a parent of two young adult PhD researchers, who are just starting their independent research careers, I have concerns about provisions 200.204, 200.432 and 200.454.<br/>[200.204] I am concerned about exempting grant competition from public notice. I see the importance of public notification o...

I have served as a research laboratory manager for almost 30 years at the Tier 1 research institution that is also my undergraduate and graduate alma mater. I spend a great deal of my time collaborating with trainees, staff, and faculty to help them achieve their research goals, but I also perform my own research as a part of our laboratory&rsquo;s NIH and internally funded projects. A certain amount of my time is also spent in training new students in laboratory techniques and sharing with them the excitement of scientific investigation and discovery. <br/><br/>The new uniform guidance proposed by the Office of Management and Budget will be catastrophic for American science. So many pieces of this proposed rule are problematic, but especially upsetting to me is the effect it will have on future generations of scientists. Graduate, undergraduate, and sometimes even younger students are a critical part of a laboratory team. The elimination of DEI programs (&sect;200.300) means that promising young American students from diverse or under resourced communities are not exposed to science and are far more likely to choose more traditional paths like medicine or law to assist their families. The possibility that active grants can be terminated at any time for any reason (&sect;200.340) will mean that ALL students will be less likely to consider graduate school in science as a path...

Comments in opposition to proposed rule: Regulations for Federal Financial Assistance (Docket No. OMB-2026-0034)<br/>To whom it may concern:<br/>I am writing to convey my strong opposition to the OMB&#39;s proposed revisions to the Guidance for Federal Financial Assistance (2 CFR Subtitle A) published on May 29, 2026 under docket OMB-2026-0034. <br/>The overhauls outlined in this proposal will severely compromise United States of America&#39;s scientific research, operations of grant recipients, and add political interference into objective, merit-review systems. In my career as scientific researcher, the stability of grant funds has been essential to planning multi-year projects and disseminating research through journal publications and at conferences.<br/>I urge the OMB to reconsider and withdraw the following provisions:<br/>[200.205] Introduction of Political Review Over Scientific Merit<br/> Having senior appointees review all awards discretionary awards undermines the peer review system. This may lead to short-term political objectives rather than long-term high impact scientific discoveries. Scientific funding should remain insulated from political whims. This will ensure progress in medicine, technology, and national security.<br/><br/>[200.340] Discretionary Termination Authority <br/> Federal agency authority to implement discretionary termination or temporary ...