AAI to Respond, Urges Responses by Individual Researchers
On May 29, the White House Office of Management and Budget (OMB) released a sweeping proposed rule that would substantially revise the federal government’s framework for awarding and overseeing grants, cooperative agreements, and other forms of federal financial assistance. The proposed rule contains some of the most significant changes to the way the federal government makes and manages awards, and would have far-reaching and damaging implications for investigators, institutions, and scientific societies.
There is currently an open comment period through July 13, and OMB plans to issue the final rule as early as October 1, 2026. All interested individuals and organizations have the opportunity to submit comments in advance of the deadline.
Summary of Key Provisions
A central feature of the proposal is to elevate what is currently “Uniform Guidance” to “Uniform Grants Regulation,” giving the rule increased legal authority. It also indicates that future OMB policy changes would automatically apply across federal agencies, centralizing policymaking with OMB and reducing the ability of individual agencies, like the National Institutes of Health (NIH), to implement new policies on their own.
Expansion of Executive Orders
Of significant concern, the proposal expands and codifies several Executive Orders (EOs). The rule would carry out the intent of the EO on “Improving Oversight of Federal Grantmaking” by establishing a new pre-issuance review process to be conducted by political appointees who are explicitly instructed to not rely solely on peer review, which the proposed rule defines as “advisory” only. It also greatly expands the authority of federal agencies to suspend or terminate discretionary awards, at any time, that are determined to no longer align with agency priorities or the national or public interest. Agencies would not be required to allow grantees to appeal these terminations unless the awards were terminated for noncompliance.
Further, the proposal prohibits federal financial assistance from being used to fund, promote, encourage, subsidize, or facilitate diversity, equity, inclusion, and accessibility policies, principles, or practices; gender ideology; or “the so-called ‘transition’ of a child under 19 years of age from one sex to another.”
Greater Administrative Burden
The proposal also contains several provisions that would restrict international collaborations, expand oversight of recipients and subrecipients, cause significant administrative burden and excessive delays in award disbursement, and direct agencies to consider ill-defined factors like “institutional commitment to research integrity” when making award decisions. While the proposed rule does not impose a government-wide cap on indirect cost rates, agencies would be directed to, if all else were equal, select institutions with lower indirect cost rates for discretionary awards.
Barriers to Collaborations
The OMB proposed rule would also have concerning implications for scientific collaboration and exchange. Under this rule, investigators would have to get explicit prior approval to use federal funding to attend conferences, and attendance would have to be included in the terms and conditions of an award. Federal funds for memberships and subscriptions would be allowable only if they are deemed “necessary to fulfill award requirements,” and in most cases, publication costs would become unallowable in their entirety.
For a more detailed summary and additional resources, please visit this resource center developed by the Association of American Universities. To view a breakdown of the proposed rule’s provisions, along with the relevant section numbers, please view this summary prepared by Venable. AAI is especially concerned with the changes to the review process of discretionary awards in section 2 C.F.R. § 200.205 and the enhanced authority to terminate awards described in sections 2 C.F.R. §§ 200.340, 200.341, and 200.342.
Take Action: Tips for Submitting an Effective Response
AAI strongly urges individual scientists to submit comments to the proposed rule through the official submission form on regulations.gov. Collectively, substantial and evidence-based responses from thousands of researchers demonstrating the detrimental impact that this proposed rule would cause will increase the chances of the proposed rule being withdrawn or modified and, if these concerns are not addressed in the final rule, strengthen any future legal or legislative challenges.
Below are tips for an effective response:
- Clearly indicate the section number, in brackets, that you are addressing (eg, include [200.340] before your comment about that provision).
- Provide your unique perspective and include concrete examples of how relevant provisions would impact you. It is not necessary to comment on all provisions that you support or oppose. It is better to make strong and well-reasoned arguments about a few of the things that you are most passionate about rather than trying to briefly address everything.
- OMB is required to consider every original, substantive comment. In this case, it is far less effective to use form letters and templates as these communications may be grouped together and treated as one set of comments.
- Comments are a matter of public record – do not include personal privacy or confidential information. If you are uncomfortable using your name and email address, comments can be submitted anonymously.
- If you choose to use your professional title/organization, check with your institution to ensure you are compliant with internal policies.
- The comment box has a 5,000-character limit. While you need to use this comment box, you can also attach a PDF of more extensive comments. Responses will not be considered if they are submitted after July 13, 2026.
- Comments should focus on the direct substance of the proposal, not on the perceived intentions of the Administration or Administration officials.
AAI Actions on the Proposed Rule
AAI is working diligently on its own and with other coalitions and organizations to confront the proposed rule in a cohesive, united manner. Because data-driven responses are most impactful, AAI released a survey to members on June 17 seeking information on how AAI members pay for conference attendance, membership dues, and publication costs. We urge members to complete the survey before Monday, June 29, and aid us in providing concrete evidence on the potential harms of this rule.
AAI believes that the 45-day comment period provided by OMB is insufficient for a proposed rule of this scope and magnitude, and AAI President Ulrich von Andrian, MD, sent a letter to OMB urging them to extend the comment period by at least 45 days. Unfortunately, that request was denied. AAI will still be submitting comments as an organization in advance of the July 13 deadline and welcomes input from all AAI members. If you would like to share your thoughts on the proposed rule with AAI, please email AAI Director of Government Affairs Jake Schumacher at jschumacher@aai.org.
