PPC Action Alert: Submit Public Comments on OMB Rule Seeking to Overhaul Federal Grantmaking
On May 29, the Office of Management and Budget (OMB) issued a proposed rule that would implement sweeping changes to the regulatory framework governing federal grants, cooperative agreements, and other forms of federal financial assistance across federal agencies. If finalized, the rule would fundamentally overhaul the process for how federal awards are distributed to universities, large research institutions, non-profit organizations, hospitals, state and local governments, and other organizations that receive federal funding. A helpful summary of the rule’s impact on research can be found here, and an additional overview of other key provisions can be found here.
This proposed regulation represents a significant shift in the rules governing federal grantmaking and other discretionary funding decisions at 42 agencies across the federal government. The implications across the National Institutes of Health (NIH), the Centers for Disease Control and Prevention (CDC), and other federal research agencies would be particularly dramatic. If finalized in its current form, this rule could significantly reshape federal funding decisions by increasing the role of political appointees in making funding decisions, reducing the role of scientific peer review, and imposing specific limitations on how grant funds can be used.
The proposed changes would codify into regulation several policy priorities from Executive Orders (EO) issued at the start of the second Trump administration, most notably EO 14332 “Improving Oversight of Federal Grantmaking,” as well as others addressing diversity, equity, and inclusion (DEI), gender-related issues, and affirmative action. The PPC joined more than 50 organizations in submitting a letter to Congress raising concerns about the grantmaking EO’s changes to merit review and the federal grantmaking process.
A recurring theme throughout the rule text is OMB’s effort to convert federal grantmaking guidance that allowed for individual agencies to operationalize based on their specific programs into binding regulations that cover all discretionary grants across the government, reflected in its retitling of the “Uniform Guidance” as the “Uniform Grants Regulation.” Regulations are considerably more difficult to roll back in future administrations. The rule also clarifies that agencies may not deviate from OMB’s requirements where no discretion is provided, effectively centralizing grants-related rulemaking authority at OMB.
Major Provisions Include:
- Expanded Political Review of Grant Proposals [Sec. 200.205]: OMB proposes establishing a new “pre-issuance review” process in which senior political appointees or their designees would be tasked with determining whether grant proposals appropriately advance the President’s policy priorities or the “national interest” before awarding funding.
- Peer Review Becomes Relegated to Advisory Status Only: While the rule does nothing to prevent the use of peer review for evaluating proposals, it specifically forbids political appointees from routinely deferring to or treating peer review recommendations as binding when deciding whether to award grants. Therefore, grants with high scientific merit could still go unfunded.
- The rule also states agencies are not required to issue awards solely as a result of issuing a Notice of Funding Opportunity (NOFO) and may repost a funding opportunity if doing so would avoid funding “low-quality proposals.”
- Expanded Authority to Terminate Grants [Sec. 200.340]: The proposed rule empowers the government to terminate grants in whole or in part mid-cycle “when the award no longer advances [Federal] agency priorities or the national interest,” a constantly shifting target for grantees given that priorities can change at any time. Grants could be terminated at any time for nearly any reason, regardless of the progress made or the work that would be lost through termination. Additionally, grants terminated under this new authority would be afforded no right to an administrative hearing, making litigation the only recourse.
- Imposition of New Ideological Conditions on Recipients [Sec. 200.300]: The rule would require all agencies to ensure that federal awards do not “fund, promote, encourage, subsidize, or facilitate” DEI, so-called “gender ideology,” or gender-affirming care for adolescents under 19 years of age. These vague provisions could make it more difficult for institutions conducting work on these issues to receive federal awards.
- Restrictions on Dissemination of Research [Sec. 200.432, Sec. 200.454, Sec. 200.461]: The rule would restrict allowable costs under federal grants. The most notable changes include limitations on the use of grant funds for conference attendance, travel, publication costs (e.g., page charges, article processing, open access fees), membership dues, or subscriptions. Funds are only allowed to support these activities if they are expressly approved by the relevant federal agency or if they are specifically included in the terms and conditions of the award. They must generally be necessary to fulfill the award requirements.
- Constraints on International Collaboration [Sec. 200.220]: The rule would impose broad restrictions on using federal funds to support collaboration with foreign nations deemed adversarial to the US or otherwise of concern. It allows exceptions only if the agency head determines the activity is of national interest.
- Agency Review of Risk Posed by Applicants [Sec. 200.206]: The rule would expand the list of risk factors that federal agencies may consider when evaluating applicant risk, including screening for an applicant’s “history of questionable practices;” an applicant’s record of “discredited or non-replicable studies published by the applicant or its staff” is considered a questionable practice under the rule. The rule also lists “affiliation with organizations engaged in activities that violate Federal law, undermine public safety or national security, or advocate for the overthrow of the United States Government” as one of the factors to be considered in the risk assessment.
The full text of the proposed rule can be found on the Federal Register website.
Of particular concern, the provisions in this proposed rule could affect longitudinal pediatric research, the pediatric subspecialty workforce pipeline, research collaborations, scientific meetings, educational programs, and public health initiatives that support child health.
As a reminder, this is a proposed rule, meaning the provisions summarized above have not been finalized. The public comment period for this rule is open until July 13, 2026. OMB has indicated it intends to issue a final rule by October 1. Please consider drafting a public comment highlighting how the proposed rule would undermine the scientific integrity of the federal government’s research grantmaking process.
Submit Public Comments in the Federal Register
Here’s how:
- Go to the Docket for the “Regulations for Federal Financial Assistance” (OMB-2026-0034) proposed rule on Regulations.gov. It will indicate that the comment period ends on July 13 at 11:59 PM EDT.
- Select the blue “Comment” icon underneath the rule’s title in the top lefthand corner of the webpage.
- Draft a public comment using the discussion points below.
- Submit your comments using the form.
Considerations when submitting public comments
- When drafting your comments, identify the specific provision or provisions you are discussing throughout the comment. This can best be done by placing the relevant section number in brackets before each comment, such as [200.205] or [200.340].
- You may submit comments with your name or anonymously. If submitting anonymously, you do not need to provide your name, email address, affiliation, or other identifying information; however, you will not be able to enter an email address to receive submission confirmation.
- Comments may be uploaded as a Word document or PDF, or pasted directly into the docket text box. When uploading a file, remove all personal metadata to preserve anonymity.
- Comments can be brief or comprehensive, but comments are strongest when they connect the proposal to your real-world experience.
- For additional privacy, consider using a VPN or accessing the Internet on a public computer (e.g., at a public library) when visiting Regulations.gov to submit comments online.
- Be aware that public comments, even those submitted anonymously, will be made available publicly. Therefore, the use of personally identifiable information in the text of the comment is not recommended. This includes information about yourself or any patient stories you may consider incorporating into your comment.
- Once uploaded, public comments cannot be edited or deleted.
- If desired, comments can be printed and mailed to the address in the Federal Register notice for the proposed rule.
Discussion points
Consider describing how the proposal would specifically affect you, your work, and the communities you serve.
If the proposal could disrupt current or planned projects, provide as many details as possible whether it would make them more expensive, less effective, or impracticable to administer, and how that would harm the communities you serve. Consider addressing the following in your public comments:
- Identify child health programs, public health initiatives, or research projects that could be put at risk as a result of this rulemaking.
- Describe research funding your institution could lose under the proposed rule.
- Explain how the rule could affect your work as a researcher or your ability to advance discoveries that improve child health.
- Explain whether enhanced political scrutiny under the rule could delay or disrupt your work, or if similar scrutiny under existing Executive Orders has already affected grant awards or project timelines.
- Describe how moving away from traditional peer review may result in scientific merit becoming a secondary factor in grant funding decisions, increasing the risk that highly meritorious research is delayed, deprioritized, or left unfunded.
- Explain whether vague restrictions on particular project topics or activities could chill, delay, or disrupt scientifically meritorious child health research or community-serving programs.
- Provide examples of how limits on travel, conferences, publication costs, or professional memberships could reduce your research’s reach and impact.
- Identify scientific capabilities that could be lost if international collaborations were restricted. Feel free to share examples of any of your work that has been supported by international collaborations and how limiting international partnerships may slow research progress or reduce access to specialized expertise.
- Describe any new administrative burdens the rule could create for your research projects that were previously not in place. For example, describe how provisions would increase costs or require additional staff time to ensure compliance. Be as specific as you can.
Remember: the purpose of the public comment process is to ensure that the federal government has all relevant information before it as it makes consequential policy decisions that impact the public.
- Your perspective is an important part of this process and is input that the agency is required to consider before finalizing a new regulation.
- Draw on your own personal experience and expertise and tell the government what you think it is important for them to know.
- Write as much or as little as you like, and don’t feel compelled to comment on aspects of the rules outside of your expertise. Even a comment expressing your position on the proposed rules will make a difference.
