Regulations.gov Comments

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 ...

As a taxpaying, law-abiding American citizen, I strongly oppose this proposed regulation and demand immediate reconsideration due to the multiple civil rights this violates. Your only sources and citations for each and every claim is based on only the language and content of an executive order less than two years old. This does not fill me with confidence as for the underlying purposes and goals of this regulation.<br/><br/>&quot;These [DEI] policies were inconsistent with basic American values and civil rights laws, including the equal protection principles of the U.S. Constitution.&quot; The demand of appraisal for non-DEI ideologies and policies in order to allow a federal grant is, by definition, unequal and a violation of civil law and equal opportunity.<br/><br/>&quot;All together, these policies wasted a large amount of American taxpayer resources and significantly undermined public trust in government across the country.&quot; What is the direct source of this statement? What are the statistics on the amount of taxpayer dollars that went to DEI programs versus how many of those funded programs were considered &#39;wasteful&#39;? How much sustained financial support did these programs receive in direct comparison to other similarly, federally funded grants NOT DEI focused? <br/><br/>&quot;This rulemaking proposes to institutionalize needed reforms in the Federal grant...

I am a mathematician who has received grants for research and training from the National Science Foundation and National Institutes of Health. The selection process takes into account the scientific merit of the proposal and the likelihood that the research and the awardee will strengthen the scientific and technical innovation capability of our country and enable through the support of researchers at universities the training of the next generation of researchers. As a graduate student at NYU, I was a research assistant supported by my thesis supervisor&#39;s grant. It enabled me to work on my dissertation during the critical last year of study. I became one of the few minority women who attained a PhD that year. This is not simply a matter of labeling and quotas. Indeed the base of American born scientists has weakened and we must seek to support qualified and deserving scientists and students including those born in America. The peer review system presently in place, supported by the professional scientific organizations provide the kind of rigorous non-partisan review that has made the US a leading scientific power for decades.

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...

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...

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....

The proposed rules of OMB-2026- 0034 would limit scientific research in the United States in dramatic and potentially irreversible ways. The United States has been the leader in scientific research for the last 100 years. Graduate students come from all over the world to train in our laboratories and fine, young American students get excellent educations in STEM fields in our public and private universities and colleges. This rule would undermine many aspects of that research by taking away the power of peer review by experts, making science a political tool, limiting networking and exchange of ideas at conferences, and strangling institutional support of grant awardees. One of the most concerning aspects of the proposed rule, in my opinion, is the limitation of research to so-called &quot;gold standards&quot;. In other words, we are forcing maintenance of the status quo. Scientific research does not move forward into new discoveries and new insights by relying solely on the established methods and ways of thinking. New ideas and innovation are the hallmarks of a successful and thriving research system and this is something that has characterized America&#39;s leadership in scientific research for decades. Stifling this innovation and ambitious discovery is against everything that our country stands for. I am surprised that this administration is seeking to put America behin...

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...

RE: OMB-2026-0034-7432, Proposed Rule on Regulation for Federal Financial Assistance<br/><br/>Dear Director Vought,<br/><br/>Thank you for the opportunity to comment on the Proposed Rule on Regulation for Federal Financial Assistance. I am writing as a concerned individual and as a scientist with a doctorate in Biology working in the sciences in the nonprofit sector. <br/><br/>I am deeply concerned about the overtly political limitations the Proposed Rule places on federal science funding and the collaborative activities of funded researchers. America&rsquo;s scientific leadership, built on the foundation of sustained public funding, is key to our economic success and global standing. Placing political pressure on research topics and stifling international collaboration and communication will have a chilling effect on US-based science. We already risk falling behind China and other competitors, and this Proposed Rule will ensure that the United States falters in its leadership in science, innovation, and economic prosperity for generations to come. <br/><br/>Specifically:<br/><br/>[200.205] I urge you to reconsider the &ldquo;pre-issuance review&rdquo; by senior appointees and instead follow standard independent peer review by the scientific community. <br/><br/>[200.220] The prohibition on multilateral collaboration is so broad that it will disrupt existing and foundational...

RE: OMB-2026-0034-7432, Proposed Rule on Regulation for Federal Financial Assistance<br/><br/>Dear Director Vought,<br/><br/>Thank you for the opportunity to comment on the Proposed Rule on Regulation for Federal Financial Assistance. I am writing as a concerned individual and as a scientist with a doctorate in Biology working in the sciences in the nonprofit sector. <br/><br/>I am deeply concerned about the overtly political limitations the Proposed Rule places on federal science funding and the collaborative activities of funded researchers. America&rsquo;s scientific leadership, built on the foundation of sustained public funding, is key to our economic success and global standing. Placing political pressure on research topics and stifling international collaboration and communication will have a chilling effect on US-based science. We already risk falling behind China and other competitors, and this Proposed Rule will ensure that the United States falters in its leadership in science, innovation, and economic prosperity for generations to come. <br/><br/>Specifically:<br/><br/>[200.205] I urge you to reconsider the &ldquo;pre-issuance review&rdquo; by senior appointees and instead follow standard independent peer review by the scientific community. <br/><br/>[200.220] The prohibition on multilateral collaboration is so broad that it will disrupt existing and foundational...

Hello, my name is Jacklyn Asamoah and I am a Medical Laboratory Scientist in Houston, TX. <br/><br/>I am voicing my concern for the severing of funding to programs across the country that hard working people rely on. <br/><br/>This affects community health centers and behavioral health clinics, universities and research institutions, nonprofits serving underserved communities, local and tribal governments, schools and education programs<br/><br/>The communities hit hardest will be Black, rural, low-income, and disabled populations - the people who depend most on federally funded safety-net programs.<br/><br/>This grant funding cut would further disrupt the already unstable foundation that the US calls healthcare with no back up plan to be established. Until a new foundation is established, these programs SHOULD NOT lose funding.

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 am a Ph.D. scientist with decades of experience at academic institutions and start-ups. I strongly oppose five provisions that would lower the quality of publicly funded science, narrow the base of Americans able to contribute to it, substitute ideology for evidence, destabilize research careers, and erode continuity across administrations.<br/><br/>[200.205] Requiring senior political appointees to approve every discretionary award and reducing scientific peer review to &quot;advisory&quot; status replaces expert judgment with political conformity. Peer review is how the research enterprise measures merit: independent experts assess whether work is rigorous and likely to succeed. This also exposes a contradiction. OMB invokes &quot;merit&quot; to justify the prohibitions in 200.218 and 200.300, yet 200.205 dismantles the very mechanism that measures it. The rule uses &quot;merit&quot; in two senses, an expert assessment of scientific quality and selection without regard to protected characteristics, and relies on the second to claim it defends merit while discarding the first. If OMB wants awards made on the merits, it should strengthen peer review, not subordinate it.<br/><br/>[200.218] By prohibiting federal support for &quot;disparate-impact studies&quot; and related activities, this section reaches past a legal standard into research itself. Understanding how a facial...

I am writing to submit my formal public comment in absolute opposition to the proposed regulatory revisions to the Uniform Guidance for Federal Financial Assistance (2 C.F.R. Part 200), published on May 29, 2026. As a veteran who has sworn an oath to uphold the constitutional frameworks of this nation, I am deeply alarmed by this administrative attempt to substitute rigorous, peer-reviewed scientific evaluation with ideological censorship and political gatekeeping.The proposed rule threatens American global competitiveness, introduces extreme economic inefficiency, and paralyzes vital fields of biological, environmental, and ecological research. I strongly urge the OMB to withdraw these specific revisions before the July 13, 2026, deadline.I. The Severe Economic and Operational Impacts of Political Grant FilteringThe proposal to grant senior political appointees the discretionary authority to approve, deny, or terminate active federal scientific grants mid-project based on fluid &quot;administrative priorities&quot; is an existential threat to the integrity of American research.Destruction of Peer-Reviewed Neutrality: For decades, the United States has led global innovation because federal grantmaking agencies (such as the NSF and NIH) have relied on independent, blind peer-review panels of scientific experts rather than partisan directives. Introducing political litmus test...

Political appointees should not have the final say on whether or not a grant receives or maintains funding. This would make said funding wildly susceptible to corruption by appointees who don&#39;t want research funded simply on the basis that they personally dislike it, with no required expertise or valid reasoning, while opening the door for inaccurate and heavily biased research that fits an agenda. The impact this would have on the quality and usefulness of American research, and the downstream effects on our universities, k-12 education system and everyday people, including those who live and work in towns supporting and supported by said universities, would be devastating. Do not pass this rule.

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...

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.

As a postdoctoral researcher and a soon-to-be professor at research universities in the USA, I strongly discourage the adoption of this set of rule changes. The proposed changes will degrade the independence and merit-driven nature of grant awards in this country. By threatening the termination of grants after they have been awarded, these changes will stifle innovation by encouraging through fear researchers&#39; sticking only to the &quot;safest&quot;-seeming, least creative research activities, regardless of whether the results of their work would point them in new directions. They will reduce the applicability of science in the USA by limiting access to the larger public to the results of this work through publications, and it will reduce the sharing of science within the community by making it harder for researchers to attend scientific conferences. Increased bureaucratic hurdles needing to be cleared for compliance with applicant and award recipient review criteria, additional reporting and oversight requirements, and other new rules will waste time and money and slow down the scientific enterprise. Further hampering the ability of the scientific community to support members from as broad a sector of society as possible will weaken the next generation of scientists. All of these changes will make research in the USA less competitive in the global arena, at a time...

I submit this comment as a physician-scientist, educator, and taxpayer who relies on federally supported science to improve patient care, train the next generation, and strengthen American innovation. I respectfully urge OMB to withdraw or substantially revise the proposed rule. This is not partisan; it is civic and practical. The United States cannot remain safe, healthy, prosperous, or globally competitive if scientific decisions are subordinated to political preference rather than evidence, expert review, transparency, and reproducibility.<br/><br/>[200.205] Peer review. Making peer review merely advisory, and directing senior appointees not to routinely defer to peer-review recommendations, would weaken a central safeguard of American science. Peer review is not perfect, but it is the best available system for evaluating technical merit, rigor, feasibility, innovation, and risk across fields too specialized for any single political official to judge. Research on cancer, traumatic brain injury, quantum materials, pandemic preparedness, rural health, or advanced computing should be evaluated by people with the expertise to understand the methods and implications.<br/>Science is not a political party, religious position, or ideology. It is a disciplined process for learning what is true even when the answer is inconvenient. We do not decide whether a bridge is safe by askin...

I strongly oppose proposed rule OMB-2026-0034 because reducing federal support for American scientific research would weaken the United States&#39; position in global science, technology, and innovation.<br/><br/>For decades, federal investment in research has been one of the foundations of American economic growth, national security, and technological leadership. Many of the innovations that drive modern industries&mdash;including advances in computing, medicine, energy, aerospace, and communications&mdash;originated from publicly funded research conducted at universities, national laboratories, and research institutions.<br/><br/>Regulating funding for scientific research in the proposed way will not have the desired effect of reducing government waste; it will simply shift leadership opportunities to competing nations. Countries such as China are making substantial and sustained investments in research and development with the explicit goal of becoming global leaders in critical technologies. If the United States chooses to reduce its commitment to scientific research, it risks losing talented researchers, slowing scientific breakthroughs, and ceding technological advantages to foreign competitors.<br/><br/>Scientific leadership is not something that can be turned on and off without consequences. Research programs take years to build, and interruptions in funding can driv...

I support the stated goals of improving transparency, accountability, and stewardship of taxpayer resources. However, several provisions of the proposed rule may unintentionally undermine scientific research, clinical trials, and the research infrastructure that has made the United States the global leader in innovation. My comments focus on five areas where modest revisions could preserve accountability while protecting scientific discovery, human subjects research, and America&#39;s long-term competitiveness.<br/><br/>1. Section 200.340: Termination of Awards<br/><br/>The proposed rule would expand agency authority to terminate awards that no longer align with agency priorities or interests. While flexibility is important, scientific research operates on multi-year timelines and depends on funding stability. Universities, hospitals, and research institutions invest heavily in personnel, infrastructure, compliance systems, and trainee development based on the expectation that peer-reviewed awards will continue absent misconduct, noncompliance, poor performance, or safety concerns. This concern is especially important for human subjects research. Many federally funded clinical studies involve patients who may be receiving investigational treatments, or are contributing critical follow-up data. Termination for reasons unrelated to safety, ethics, scientific validity, miscondu...

I am writing to express concern regarding the proposed &quot;Regulation for Federal Financial Assistance&quot; (OMB-2026-0034).<br/><br/>While I support efforts to improve transparency, accountability, and stewardship of federal funds, I am concerned that several provisions in this proposed rule could undermine the effectiveness, fairness, and stability of federal grantmaking. The proposed revisions would significantly expand agency discretion in award decisions, grant termination, and program oversight, potentially reducing the role of independent merit review and creating uncertainty for recipients of federal assistance.<br/><br/>Federal financial assistance supports critical services provided by universities, nonprofit organizations, state and local governments, and community-based agencies. In fields such as education, health care, social services, workforce development, and scientific research, recipients rely on predictable and objective grantmaking processes to plan programs, retain qualified staff, and serve vulnerable populations. Changes that increase political or administrative discretion without clear standards could diminish confidence in the fairness and consistency of funding decisions.<br/><br/>I am particularly concerned about provisions that appear to allow greater flexibility to terminate or modify awards based on changing agency priorities after funds hav...

This bill is a dangerous proposition to American basic research and ingenuity. Regardless of which administration is in power, having the president&#39;s own political appointees approve federal grants will create grant gridlock and harm research that may be useful in the eyes of the American public, but not in those of the president. Moreover, these appointees will not understand every proposal that comes across their desk, as not even a *researcher* will understand every such proposal. Instead, this bill will make grant proposals simply a game of including enough hot science buzz-words (e.g. &#39;AI&#39;) to curry favor with an ill-informed audience, while downplaying words that an administration may not like (e.g. &#39;climate&#39;). This won&#39;t give grants to the &quot;best and brightest.&quot; It will give grants to those who&#39;ve learned to game the political system. <br/><br/>I am a researcher collaborating with many scientists in universities across our country, and across the world. This proposed rule and its prohibition of collaboration among scientists from &#39;covered foreign countries&#39; is an immediate threat to our nation&#39;s scientific prowess. I have personally had the privilege to work and converse with scientists from across the globe, from countries including the UK, China, Germany, Japan, Korea, Thailand, Italy, Turkey, and more. We need those ...

New Prairie Press, a library-based open access publishing program at Kansas State University, strongly supports the proposed revisions to 2 CFR &sect; 200.461 making publication costs, including page charges, APCs, open access fees, and similar publication charges, generally unallowable under Federal awards except where required by statute or approved in advance by a Federal agency. Public access and APC-funded publication are not the same thing: federally funded research can be made publicly available through Green OA deposit, institutional and federal repositories, author-accepted manuscripts, Diamond OA publishing, and other no-fee public access mechanisms without routinely transferring grant funds to commercial publishers. The current APC-centered model compounds the serials crisis by asking libraries, universities, researchers, and taxpayers to pay repeatedly for the production, publication, and access to publicly funded scholarship, while also distorting research strategy through overreliance on publication counts, journal placement, and citation proxies rather than deeper measures of accessibility, reuse, preservation, public value, and impact. New Prairie Press supports the proposed rule because it would help redirect attention and investment toward sustainable scholarly communication infrastructure, including repositories, metadata, persistent identifiers, preservat...

My name is Mimi Shirasu-Hiza and I am a Professor of Genetics and Development at Columbia University Irving Medical Center. I am also the Assistant Dean of Mentoring for the biomedical Ph.D. programs. I strongly oppose the proposed rule.<br/><br/>The proposed changes gives control over scientific funding to political appointees who may not understand or respect the scientific process, the goals of scientific research, or the merits of individual grant applications. The proposed changes lead to potential for exploitation or use of federal funding to advance political agendas or stop research because of subjective or ideological opinions not based in fact. The objectivity of the scientific process would be irreparably damaged and the progress of American science will be further inhibited, as it has already.<br/><br/>This affects me because I am primarily NIH-funded. I investigate the role of circadian-regulated physiologies, including metabolic pathways and immune pathways, to different disease states such as aging and bacterial infection. I have two NIH grants from two different institutes. If these proposed changes are enacted, my grants could be terminated at any time or not renewed due to my affiliation with Columbia University or my location in New York, factors that will be deemed more important than scientific merit. <br/>Without these grants, I will not be able...

This set of proposed rules, which are presented under the guise of blocking anything &ldquo;anti-American&rdquo;, will have damaging and lasting consequences on the advancement of science in the United States. I feel the entire document is a blatant overreach of power, but especially allowing political, non-scientist appointees to control which proposals get funded and which don&#39;t as described in &sect;200.205, as well as restricting grant eligibility to institutions described in &sect;200.202(d). As a postdoctoral trainee at an R1 institution, I am commenting anonymously because I am extremely concerned with the possible retaliation against universities that have disagreed with the administration&#39;s stances.

[200.205] It is unclear how the senior appointee who conducts the pre-issuance review is selected and if they have minimum required qualifications. It is also unclear if feedback is provided and if there is an opportunity to respond if an award is rejected at the pre-issuance stage. Also, it is unclear whether peer review will be weighted less or the same than in the past. If weighted less, then there is risk that meritorious applications will slip through the cracks and will be replaced with less meritorious proposals. It is also stated that &quot;discretionary awards must, where applicable, demonstrably advance the President&#39;s policy priorities&quot;. It is not clear what &quot;where applicable&quot; means. These are important considerations, because the NIH R01 is a discretionary grant which has had substantial societal impact, leading to breakthroughs and life-saving treatments across disciplines. If all NIH R01s needed to align with presidential policy priorities, research may be constrained to specific topics in some years and then the constraints may switch to different topics in other years, depending on the administration. This could overall be detrimental and wasteful to the scientific enterprise and the American people as research swings from one topic to the next without sustained or consistent support over time. I think peer review, which needs constant refi...

While the OMB&#39;s stated objectives of transparency and accountability appear reasonable on their surface, this proposal represents a dangerous overreach that will inflict not only substantial damage on both American financial interests and global standing, but is patently unconstitutional.<br/><br/>The proposal&#39;s vague language around &quot;ensuring American principles of equality&quot; masks ideologically-driven restrictions that will destroy the creativity and innovation the USA is now known for. Those Universities, nonprofits, and private institutions who even get the grants they request will face crippling compliance costs as they navigate undefined regulatory standards. The burden of excessive oversight creates a draining effect on grant applications, particularly from smaller institutions lacking compliance infrastructure. This will redirect billions in institutional resources away from productive research and services toward bureaucratic compliance, ultimately harming the very Americans these programs serve. Federal agencies will be forced to hire additional compliance staff, inflating administrative costs and reducing funds available for actual programmatic work.<br/><br/>Globally, this proposal signals American retreat from scientific leadership and institutional autonomy. International research collaborations&mdash;critical to American competitiveness in fie...

[General]<br/>I urge OMB to withdraw this proposal. A government-wide regulation governing grants across more than forty agencies should rest on administrative findings, not political characterization. Much of the preamble&#39;s justification is framed in contested ideological terms rather than documented, program-level evidence. That is an unstable foundation for binding rules that states, universities, hospitals, tribes, and nonprofits must follow for years. I also object that a 45-day comment period for a 108-page rule affecting nearly every federal grant program is inadequate for meaningful public input, and I ask OMB to extend it.<br/>[200.218]<br/>The prohibition on &quot;theories of disparate-impact liability&quot; is both too vague for straightforward compliance and substantively harmful. Disparate-impact analysis is embedded in decades of civil rights enforcement; barring it through grant conditions, without a precise definition, will chill lawful activity and invite inconsistent enforcement and litigation.<br/>More fundamentally, disparate-impact analysis is the primary tool for identifying facially neutral policies that actually produce unequal and often life-threatening outcomes across housing, lending, environmental exposure, employment, and access to health care. Prohibiting federal grantees from examining these effects does not make the underlying disparities ...

I submit this comment in strong opposition to the proposed revisions to the government-wide rules for Federal financial assistance. I am a university researcher with experience effectively using Federal research grants, public-private collaboration, student training, and partnerships to turn research into practical economic and public benefits. This proposed rule should be withdrawn.<br/><br/>Federal grants are a cornerstone of American innovation. They support discovery, workforce development, technology transfer, regional growth, national security, and U.S. competitiveness. The system works because it is built on transparent rules, statutory authority, merit review, fiscal accountability, and stable commitments that can be trusted across administrations.The proposed rule would make Federal awards more political, less predictable, more burdensome, and less effective in producing real-world results.The United States faces intense global competition in advanced technology, manufacturing, energy, agriculture, health, materials science, cybersecurity, and other strategic sectors. This rule would be a self-inflicted wound in a moment of global inflection.<br/><br/>The rule would politicize Federal grantmaking. Awards should not be subject to capricious political tests after applicants have responded to published opportunities, undergone review, and made binding commitments. Reci...

I am a manager of an Alzheimer&#39;s cognition lab at a very reputable US university, and I have done this work for the past 11 years. I work with our research staff and oversee our grant applications, budgets, ethics approvals, vendor contracts, subcontracts, partnerships, and more. I have seen firsthand the rigor with which universities manage funds. And I have seen the hard work and dedication of the scientific faculty who review and score grants. It is essential that science be led by scientists and not by politicians. Science has to move forward and it does so at a slow but steady pace. It cannot do that if it is starting and stopping based on political whim.

[200.340] The proposed expansion of termination authority is highly disruptive to research, innovation, and workforce development. Multi-year research projects require stable commitments to personnel, equipment, subawards, compliance systems, and student support. Allowing termination based on broad discretionary standards injects uncertainty that is fundamentally at odds with the way federally funded science operates. Universities and other research institutions must hire staff, recruit graduate students and postdoctoral researchers, enter into subawards, and make long-term equipment and facility commitments in reliance on the continuity of funding across the approved period of performance. If awards can be terminated whenever shifting program goals, agency priorities, or political judgments are invoked, institutions will be forced to act more cautiously, reduce participation in ambitious federal initiatives, and avoid projects that require long timelines to achieve meaningful results. <br/><br/>[200.340] This approach also conflicts with the missions Congress has assigned to major science agencies. The National Science Foundation was created to &lsquo;promote the progress of science; to advance the national health, prosperity, and welfare; and to secure the national defense.&rsquo; NIH exists to seek fundamental knowledge and apply that knowledge to enhance health, lengthen...

These proposed rule changes are a giant step backwards for our country. Science needs to be reviewed and approved by SCIENTISTS. Politics needs to stay out of this, and political appointees with no scientific expertise have no business in this space. The proposed policy changes will send this country back into the dark ages. China is already surpassing the US in its scientific discoveries and output. Is the intended goal to push that to happen faster? Additionally, the plan to terminate grants at will is completely inappropriate and will result in enormous loss of infrastructure and scientific progress, not to mention the negative effects on universities, scientists, and communities/

I write to strongly oppose the proposed revisions to the Guidance for Federal Financial Assistance.<br/><br/>The proposal is framed as an effort to improve transparency, accountability, oversight, and reduce recipient burden. Those are important goals. However, many of the proposed changes would do the opposite. They would introduce vague and politically variable standards into federal grantmaking, undermine the integrity of scientific and programmatic peer review, increase uncertainty for recipients, and create substantial new administrative burden and financial risk for universities, health systems, nonprofit organizations, and other entities that rely on federal awards to serve the public.<br/><br/>Federal grants should be awarded and managed based on statutory authority, scientific and technical merit, demonstrated public need, feasibility, fiscal responsibility, and compliance with existing law. The proposed rule appears to expand discretionary review based on broad concepts such as alignment with agency priorities, &ldquo;national interest,&rdquo; and administration-defined policy objectives. These standards are not sufficiently specific, stable, or objective. They risk allowing meritorious applications and ongoing awards to be approved, denied, suspended, or terminated based on political preferences rather than expertise, evidence, or the purposes authorized by Congre...

I am a scientist. The US scientific system is the best in the world. Our universities, labs, and companies attract the most brilliant scientists from everywhere in the world to come to the US and keep us as the undisputed world leader in fields from AI to crop science. This creates jobs and wealth for our country. This proposed rule change threatens to obliterate science in the US. Here are reasons that two example specific provisions would destroy our world leadership:<br/><br/>&sect;200.205: Our scientific funding system works so well because it is run by scientists, not politicians. Scientific reviewers do not make decisions based on what is best for the current ruling party but rather what the best science is. Putting decisions in the hands of politicians will cause ideological science no matter who controls the White House.<br/><br/>&sect;200.220: Almost every project I have ever worked on during my career has required working with scientists in other countries. Specialization means that small but important problems often only have a handful of experts working on them in the world, and these experts need to work together to accomplish goals. Disallowing foreign collaborations will not hurt foreign scientists, it will hurt the US by causing international collaborations to continue without US scientists. If top American scientists are forced to choose between trying to do...

Thank you for the opportunity to comment on the Proposed Rule regulating federal financial assistance (Docket OMB-2026-0034). I am a public health researcher with the Oregon Health &amp; Science University &ndash; Portland State University School of Public Health. The views expressed are my own and do not necessarily reflect the views or positions of the Oregon Health &amp; Science University &ndash; Portland State University School of Public Health. As an early career public health researcher, I have serious concerns about how this Proposed Rule will impact the future of scientific research and progress in the United States. <br/><br/>[200.205] My primary concern with the Proposed Rule relates to the elevated authority of political appointees over scientific experts in the issuance of discretionary grant funding. While I support the goal of funding recipients who will be &ldquo;most likely to be successful in delivering results based on the program objectives&rdquo; (200.205), I believe this Proposed Rule puts the final funding decisions in the hands of individuals who are less qualified to determine who will meet this standard than expert peer reviewers. As former President George H. W. Bush once said in a speech given to the National Academy of Sciences: &ldquo;Science, like any field of endeavor, relies on freedom of inquiry; and one of the hallmarks of that freedom is ...

This policy will cause insurmountable harm to many institutions across the country. It will decimate research, universities, and basic public systems based on an inaccurate and discriminatory understanding of human biology. A policy that withholds funding from organizations that acknowledge transgender and intersex people exist is not only a first amendment violation, it is a historical and biological inaccuracy. Across time and across cultures, there have always been people who don&rsquo;t fit into one of two boxes.

I am concerned that the proposed changes may inadvertently worsen the return on investment for American tax payer dollars allocated to scientific endeavors. For example, the Federal Reserve estimates that the total return on investment for funds spent by the NSF on basic science is between 150% and 300%, surely one of the best investments the government has ever made. The NSF funds research that does not yet have a clear application or industrial use, yet the ROI speaks for itself; these high risk high reward investments have paid out handsomely, both increasing the wealth of Americans and their well being. NIH research funding has played out similarly; for example the entire pharmaceutical industry is reliant on NIH funding at universities to identify new disease targets, which the companies can then commercialize into medicines. My fear is that allowing political appointees to manage actively which projects get funded will result in a worse ROI in the long run than the current peer review system, in much the same way that actively managed funds almost always underperform index funds that capture the collective wisdom of many evaluators. The rational course of action, for an administration looking to further bolster the economy of the United States, would be to invest more in science directed by peer reviewed proposals to continue reaping such large ROIs.

The focus with &ldquo;transgender&rdquo; mouse work in big US universities is having unintended consequences as the administration and the 52% who voted for it may not see the agenda as science. Hence the Trump administration team are trying to make sure tax payer money is spent on cancer, autoimmunity, neurodegeneratoin and autoimmune disease etc. Completely understandable.

I have worked in the field of public health for over 14 years. In that time I have worked in State government as an infectious disease epidemiologist, project coordinator, and contract administrator using federal grant funding from the Centers for Disease Control (CDC) and the Substance Abuse and Mental Health Services Administration (SAMHSA). I am an alumnus of and graduate student mentor for one of the top medical and public health research universities in the United States. I am also a person whose family has been affected by cancer and benefited from the scientific and public health peer-reviewed research protocols that have been in place for years. <br/><br/>I strongly urge the Office of Management and Budget (OMB) to withdraw this rule and not implement OMB&rsquo;s Proposed Federal Financial Assistance Rule (OMB-2026-0034). This rule, especially Sections <br/>&bull; &sect;200.205 &mdash; Political appointee review of grants<br/>&bull; &sect;200.340 &mdash; Grant termination<br/>&bull; &sect;200.432 &mdash; Conference attendance pre-approval<br/>&bull; &sect;200.454 &mdash; Journal subscriptions (now unallowable)<br/>&bull; &sect;200.461 &mdash; Publication costs (now unallowable)<br/>&bull; &sect;200.300 &mdash; DEI and gender ideology prohibitions<br/>&bull; &sect;200.218 &mdash; Disparate-impact research banned<br/>&bull; &sect;200.220 &mdash; Foreign collaboration ...

I oppose the new legislation designed to restrict funding for research and programs for diverse people including transgender individuals. prevent any federal funding from going to organizations that acknowledge the existence of transgender people or advocate for health equity (including programs labeled as &quot;DEI&quot;). This rule would affect every government agency and grant, including health and human services, schools, universities, and shelters. It would require all federal discretionary grant recipients to undergo a pre-issuance review by political appointees. This legislation is xenophobic and inhumane.

Just another blatant attempt by the OMB and President to destroy federally funded research at American universities. Decisions regarding the importance and rationale for funding a research study should be left to the experts in the field, not politicians or appointees aligned with the executive branch who have no scientific knowledge or experience in conducting research. The US Congress has repeatedly demonstrated its support for federal funded research with their votes on appropriation bills that support the research mission of NIH, NSF, and other federal agencies. There is no support for the changes outlined under this proposed rule and it should be immediately withdrawn.

The proposed rule is Proposed OMB &quot;Uniform Guidance&quot; (2 CFR Part 200) would affect our ability at our mid sized campus to move from R2 to R1 in the following ways:<br/><br/>Grant awards would be less purely peer-review driven and based on an opaque selection process. As we try to follow traditional rules to accomplish increasing our research portfolio, there is concern that criteria other than scientific merit would be used to determine selection<br/>&nbsp;<br/>Proposals would have to become aligned with the policy of the administration in power. The risk to this change would be two-fold. First that in an institution with a small number of investigators like ours, alignment would not be assured just based on our small volume of submissions. Second is that while our state is aligned with the desires/values of the current administration, assuming an administrative change may take place in two years, that would potentially put funded projects at the time of the transition at odds with the new administration, threatening cancellation. For example, the one center on campus may be placed at risk as their focus on violence prevention may not align with the current administration&rsquo;s priorities. In 2 years, under a new administration, they may be punished for agreeing to have changed this emphasis.&nbsp;<br/><br/>Collaboration would be made more difficult. In smaller i...

I am a senior biomedical researcher with decades of experience conducting federally funded research, mentoring trainees, and serving on NIH peer-review panels. I strongly oppose the proposed revisions to the Uniform Guidance because they significantly compromise the scientific review process, increase uncertainty in federally funded research, discourage institutional investment in research infrastructure, and ultimately undermine U.S. leadership in biomedical science.<br/><br/>The most concerning aspect of the proposal is the elevation of political review over scientific peer review. While peer review is not perfect, it remains the most effective mechanism for ensuring that federal research funding is awarded based on scientific merit, innovation, feasibility, and public benefit. Allowing political appointees to determine whether proposals align with current policy priorities risks replacing scientific judgment with political considerations and will discourage investigators from pursuing important research questions.<br/><br/>Equally important, the credibility of the federal research enterprise depends on both fairness and the perception of fairness. Investigators, institutions, and taxpayers must have confidence that funding decisions are made through objective, transparent, and scientifically grounded processes. A merit-based funding system should not create opportunities ...

I am an american faculty member and scientist who has been partially or fully funded by NSF grants as a student and postdoc. I have concerns with several of the proposed rule changes. The ones most relevant to my experience include:<br/>&sect;200.205 which creates an additional layer of grant review by political appointees<br/>&sect;200.220 which allows the administration to identify countries, such as through executive order, and ban collaboration with researchers from that country<br/>&sect;200.340(2) which allows for arbitrary termination of grants at any time by the funding agency<br/><br/>These all have serious consequences that will harm science in the US. The &sect;200.205 changes add an additional arbitrary layer of review by non-experts. I have received comments from review panels for both funded and non-funded proposals. These panels consist of highly trained relevant experts in the field who seriously consider the benefits and costs, feasibility, and novel nature of the research. Research grants are highly technical and written for reviewers who are familiar with the scientific literature in the area of the grant. Non-experts are not qualified to perform this review. This change will lead to grants being funded or not funded due to arbitrary and non-science related reasons. <br/><br/>The &sect;200.220 changes allow the administration to arbitrarily stop internatio...

I am a professional in the public health field who has administered federal grants under both Republican and Democratic administrations. I am extremely concerned to see this ideological and political document that attempts to control the speech and activities of grant recipients. This level of government overreach is disastrous and would have far-reaching implications that would chill free speech, burden already understaffed and underfunded organizations, and force agencies to adopt a hardline ideology in order to receive federal funds. One can easily see the dangerous precedent this sets for future administrations to exert ideological control over universities, hospitals, and nonprofits. <br/><br/>Grant recipients&#39; performance should be based on whether they are able to achieve the measurable goals and objectives outlined in their work plan, grounded in evidence-based frameworks like SAMHSA&#39;s Strategic Prevention Framework. To attempt to restrict agencies&#39; outreach to subpopulations like the LGBTQ community is dangerous and it is disturbing. The climate of fear it would create cannot be understated, and it would prevent organizations from serving those who need it. <br/><br/>This regulation should not be adopted under any circumstances. It is not a cost effective use of federal dollars and it will only serve to hinder the local organizations that do incredible w...

I am writing to express my strong opposition to OMB-2026-0034, which would threaten the public health in the U.S. and across the world and would undermine the nation as a leader in scientific research and discovery. I write not as a scientist but as a university professor and concerned citizen. <br/><br/>Scientific research and discovery takes time, thought, and focus. Universities and research organizations have built vast infrastructures in order to ensure that the scientists conducting that research and discovery have the time it takes to obtain expertise in their fields. Peer review ensures that science is being evaluated by the scientists who have time to obtain this expertise, not by government bureaucrats who have many other questions to attend to in their daily work. Having government bureaucrats spend their time weighing in on scientific developments about which they know very little is the opposite of the small government that the Republican Party repeatedly promises to deliver.<br/><br/>More significantly, however, this bill will cost lives. In 2020, when the COVID-19 pandemic killed millions of Americans and shut down businesses and schools, the government was admirably quick to respond. Americans had access to some of the first vaccines in part because the science that produced those vaccines was based on previous research--research that, when it was begun, didn...

I am a graduate student at Washington University in St. Louis. I am writing to oppose the proposed revisions to &sect;&sect; 200.205, 200.340, 200.432, and 200.454. As a graduate student, my education and future career depend on access to scientific literature, research funding, and collaboration across institutions.<br/>Science generally, and research specifically, have historically functioned best when insulated from political considerations because of the nature of the work. Many medical breakthroughs required decades of sustained funding, collaboration, and knowledge sharing. One of the reasons it took so long to achieve major advances in cancer treatment was the fragmentation of the research system and the lack of resources needed to support collaboration through scientific publications, conferences, and partnerships across universities, both nationally and internationally.<br/>Scientific research often extends beyond the length of any single political administration. Requiring political appointee review of grants would introduce uncertainty into the funding process and could lead to the halting and restarting of research projects whenever priorities change. This is not always possible, particularly when studies involve participants with terminal illnesses or deteriorating prognoses. Delays and disruptions can undermine years of work and jeopardize the validity of ongoi...

Comment for Sections: 200.205 and 200.340<br/>I am a sociologist with a Ph.D. in Sociology, a researcher, and a licensed professional counselor. I am submitting this comment because I believe federal research funding decisions should be guided by scientific merit and peer review, not political priorities.<br/><br/>As both a sociologist and clinician, I rely on high-quality research to inform my work with adolescents, adults, and families. Federal investments in research have contributed significantly to our understanding of mental health, trauma, family functioning, social inequality, public health, and other issues that affect communities across the United States. The strength of the American research system has been its commitment to evaluating proposals based on methodological rigor, expertise, innovation, and potential public benefit. Political administrations change, but scientific standards should remain consistent.<br/><br/>As a sociologist, I understand that many of society&rsquo;s most complex challenges&mdash;including mental health, family functioning, public health, social inequality, and community well-being&mdash;require sustained, long-term research efforts that extend beyond the priorities of any single administration. Meaningful scientific progress often takes years or decades to achieve and depends upon stable, predictable funding guided by evidence rather ...

As a university professor and Extension professional, I am concerned that the proposed revisions may increase administrative burden and uncertainty for institutions that rely on federal assistance to conduct research, education, and public outreach.<br/><br/>Accountability and responsible stewardship of taxpayer funds are important goals, but additional compliance requirements can divert time and resources away from delivering public benefits and addressing community needs. Federal grant programs are most effective when requirements are clear, stable, and focused on program outcomes.<br/><br/>I encourage OMB to carefully consider the cumulative burden of these changes and ensure that any new requirements are necessary, clearly defined, and do not reduce the ability of universities and Extension programs to serve the public.