OMB proposed rule could reshape federal research funding
What's happening, why it's important to comment, and how to do so.
What is happening?
The Office of Management and Budget (OMB) has proposed significant changes to the federal government's "Uniform Guidance," the rules that govern how federal grants and cooperative agreements are awarded, managed, and terminated. These rules affect funding across the federal government, including research grants from agencies such as NIH, NSF, CDC, DOE, and others.
The Federal Register is the official mechanism through which the federal government proposes regulations and receives public input before they are finalized. The current regulations are open for public comment, giving scientists and others an opportunity to formally express their concerns.
Public comments are due by July 13, 2026. The rule is scheduled to take effect on October 1, 2026. Once the rule is implemented, it has the force of law.
Why does this matter?
The proposed rule would make substantial changes to the federal research enterprise, including:
- Political review of grant awards
- The proposal would require senior political appointees to review discretionary grant awards to ensure alignment with Administration priorities and executive orders. While peer review would remain part of the process, final decision-making authority would rest with political appointees.
- Expanded authority to terminate grants
- Federal agencies could terminate awards if they determine that a grant no longer aligns with agency priorities, program goals, or the national interest. This authority would extend to active, multi-year awards.
- Awards could be terminated at any time due to convenience.
- Restrictions on scientific communication
- The proposal would require agency approval for conference attendance costs and would make publication costs, including article processing charges and open-access fees, unallowable unless specifically approved by the agency.
- Additional compliance requirements
- The proposal includes expanded applicant and award recipient review criteria, additional reporting and oversight requirements, mandatory E-Verify participation for recipients and subrecipients performing work in the United States under federal awards, and provisions tied to several executive orders issued in 2025, including restrictions related to DEI activities.
Why do comments matter?
Under the Administrative Procedure Act, OMB must review and respond to significant public comments before issuing a final rule.
Substantive comments can:
- Create an official public record documenting concerns about the proposal.
- Highlight unintended consequences and implementation challenges.
- Help identify legal, scientific, administrative, and economic issues that OMB must address.
- Inform future oversight by Congress, federal agencies, and the courts.
How do I submit a comment?
Individualized comments are generally more influential than form letters. Comments that explain how specific provisions would affect your work, institution, research community, students, patients, or scientific field are especially valuable.
Deadline: July 13, 2026, at 11:59 p.m. ET
Step 1: Visit the rule docket
Go to Regulations.gov and search for OMB-2026-0034 or visit: https://www.regulations.gov/docket/OMB-2026-0034
Click the "Comment" button on the docket page.
Step 2: Write your comment
A strong comment typically includes:
- Who you are
- Describe your role and connection to federally funded research, education, healthcare, industry, or public service.
- What concerns you
- Identify specific sections of the proposed rule and explain why they are important.
- What impact you anticipate
- Describe potential effects on your research, institution, students, workforce, collaborations, or community.
- What action you recommend
- State whether you support changes, clarification, or withdrawal of specific provisions.
What sections should I look at?
The sections below represent a selection of provisions that may have significant implications for the research enterprise and are of particular interest to our society. Because the proposed rule affects a wide range of federally funded activities beyond research, we encourage members to review the full proposal and raise concerns about any provisions relevant to their own work and communities.
- §200.202 – Program alignment with Administration priorities
- §200.205 – Political review of discretionary grant awards
- §200.218 – Restrictions affecting certain disparate-impact activities
- §200.340 – Grant termination authority
- §200.432 – Conference attendance requirements
- §200.454 – Journal subscription costs
- §200.461 – Publication and open-access costs
When submitting a comment, be as specific as possible. Referencing the section number(s) you are addressing (for example, §200.205 or §200.340) makes your comment more effective and helps ensure OMB addresses the concerns you raise.
Where you can learn more
- Law firm of Ropes & Gray
- The Association of Public & Land-Grant Universities
- ScienceInsider article from Jeffrey Mervis
*More resources will be forthcoming as they become available
Important privacy note
Comments submitted through Regulations.gov become part of the public record. Any name, organization, or information included in your submission may be publicly available. While commenters may submit anonymously, identified comments can help demonstrate the diversity and scale of those affected by the proposed rule. Please refer to your institution's policies and guidance before submitting a comment.