As you may know, the Office of Management and Budget (OMB) has proposed sweeping government-wide revisions to grant funding that will have significant consequences for universities and the broader US research community by requiring a ”pre-issuance review” by political appointees of every discretionary grant. Public comments for these changes are due by July 13, and our union is helping to coordinate a response.
Check out resources below to learn more about the issue, then take action by submitting your public comment (due by July 13, 2026).
What are the proposed changes to scientific grant review and award?
- Read the proposal directly here: Regulation for Federal Financial Assistance
- Read the Proposed New US funding rules: We can cancel any grant at any time from Ars Technica.
- Read a Summary of Key Changes in OMB’s Proposed Federal Financial Assistance Rule from Elizabeth Ginexi
- The Planetary Society has a side-by-side comparison of the changes
- APLU has a thorough, if technical, summary: Key Issues within OMB Uniform Guidance Revision Proposal [Docket OMB-2026-0034]
- Or you can find articles nearly anywhere like Science, Nature, The NYT, CNN
What should you do?
- Write a specific, substantive comment to to Stop OMB’s Attack on American Science! through SUFS, who will keep duplicate records of every comment for future lawsuits.
How do I write a comment?
- If you are not a scientist, scroll here for a template you can use.
- If you are a scientist, scroll here for a template you can use.
- Go to The SUFS Guide to Writing Public Comments
- Or to What We Need to do NEXT: OMB’s Proposed Federal Financial Assistance Rule (OMB-2026-0034)
Template (For Non-scientists)
How to use this template. Fill in every field marked [LIKE THIS], then delete this instruction block and any bracketed prompts you don’t use. Submit at https://www.regulations.gov/commenton/OMB-2026-0034-0001. A concrete, real-world detail from your own life experience is the single highest-value thing you can add. Comments are due July 13, 2026.
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. [Have you gone to university? Sent a child? Mention that here.] Government STEM funding has led to breakthrough treatments and technologies that improve our health, extend our lives, and grow our economic and political power. [Have you used any kind of biomedical treatment or device? Did you cry about the moon mission? Do you like weather forecasts and government funded conservation research? Mention that here.] 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. [Do you have strong feelings about letting the government make decisions in any arena, rather than experts? Let it all out…]
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 impossible to hire, plan experiments, conduct field studies or carry out many of the activities required for effective science. [Describe how your own work area would suffer if you could lose your funding any time for any reason] The proposal also makes it nearly impossible to collaborate internationally, undermining our scientific potential and our soft power in the international community [200.220]. [Have you had significant friendships or relationships with international students that enriched your life? Mention that here.]
The changes proposed here are politically motivated, not driven by improved cost efficiency, time efficiency, or improvement of scientific logistics. As a taxpayer, and a beneficiary of the American scientific enterprise, I urge you not to implement the proposed changes but rather to work with the scientific community to draft workable, scientifically motivated measures.
Scientist Template
How to use this template. Fill in every field marked [LIKE THIS], then delete this instruction block and any bracketed prompts you don’t use. Submit at www.regulations.gov under Docket OMB-2026-0034, beginning each comment with the relevant section number in brackets. A concrete, real-world detail from your own work is the single highest-value thing you can add. Comments are due July 13, 2026.
Summary
The stated goals of this proposal — transparency, accountability, and oversight of taxpayer dollars — 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 — most urgently [200.205], [200.300], [200.340], [200.432], [200.454], and [200.461].
About Me
I am a [YOUR ROLE — e.g., research scientist / faculty member / principal investigator] at [YOUR INSTITUTION OR ORGANIZATION], where I [ONE PHRASE ON WHAT YOU DO — e.g., direct a federally funded laboratory studying X]. [ONE SENTENCE OF CREDENTIAL OR STAKE — e.g., I have been supported by FEDERAL AGENCY since YEAR / I have served as a peer reviewer for AGENCY / my institution holds N active federal awards.]
The provisions that displace expert judgment
[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 “demonstrably advance the President’s policy priorities,” and specifies that appointees “must not ministerially ratify or routinely defer to” peer reviewers, whose role is reduced to advisory. This appears to be an attempt to circumvent 42 USC § 289a, which requires that all grants be peer reviewed, by allowing grants to be peer reviewed and then ignoring those reviews in favor of politicizing scientific funding decisions.
· [If you have served on proposal review for any federal agency, note your experience here and how this may not be perfect but does a good job recognizing meritorious, feasible proposals.
· If you have BEEN reviewed and resubmitted, note how reviews improved your submission
· If a score you received could be used as part of bridge funding, performance review, etc. discuss that here].
Review of scientific merit and feasibility is a technical question well-addressed by peer review. A generalist political appointee is not equipped to assess study design or feasibility. The American research system became the most productive in the world because the allocation of public funds was tied, through peer review, to independent technical judgment rather than to the preferences of whoever held office. The legitimate accountability interest can be met without this: agencies already attach conditions, verify statutory compliance, and may decline low-quality proposals. I urge OMB to strike the subsections subordinating expert peer review.
[200.300] Content-based award conditions. Embedding prohibitions on broad, loosely defined subject areas of research will stop important research into areas that are essential for our country. Language that prohibits research on “gender ideology” could be mis-used to block research on diseases that affect women, like complications from pregnancy, on diseases that are more prevalent among men, like melanoma and ALS, or diseases that are more prevalent among women, like lupus and osteoporosis. Prohibitions against “diversity, equity and inclusion” could be mis-used to block programs to help rural students gain access educational opportunities. Anti-DEI language has already been used to terminate research on deafness, and to cut programs that helped disabled teens transition to adulthood. [If you work on any area that has been censored, including grants to your trainees such as IRACDA, EPSCoR, Diversity F31/32s, etc, add specifics here! If you work on a marginal area like sex differences, virology, epidemiology, health disparities, or any disease with disparate impacts by sex or ethnicity, add detail here!]
The provisions that isolate researchers and prevent long-term planning
[200.340] Mid-award termination for shifting “priorities.” The proposal expands the authority to terminate active awards on the basis of “agency priorities,” requiring no finding of noncompliance and only a brief written rationale, and analogizes this to the termination-for-convenience clause in federal procurement. A grant is not a purchase of a deliverable; it is a multi-year commitment around which a laboratory hires and trains staff, enrolls and incurs ongoing ethical obligations to human research participants, and structures years of work that cannot simply be paused and resumed. [How would a premature termination affect your job, your lab, your grad program, the scope of your work?] I urge OMB to restore termination only for cause.
[200.220] Broad ban on international collaboration — sweeping, entity-agnostic restrictions, reaching even allocable indirect costs, would disrupt partnerships foundational to U.S. science. [If applicable describe ways international collaborations have been included in prior funded grants and/or broadened the scope and impact of your research, are necessary to access key resources (patient populations, specialized equipment, fieldwork) or facilitate public health (e.g. epidemiology, public health, virology)]
[200.432] Conferences would be allowable only if pre-approved and written into the award at issuance. [Give a specific example of the value of a conference to you/ your research. Describe a specific example of inability to know what conferences would be beneficial to attend at the start of an award]. A researcher cannot anticipate at award time which meeting in year three will matter, and a discretionary, per-conference approval gate adds an administrative step where none is needed.
[200.461] Publication costs, APCs, and open-access fees would be presumptively unallowable, in direct conflict with existing federal public-access policy — funding the research but not the step that validates and disseminates it for critical evaluation by peers and use by the public who funded it.
In closing
The throughline among these provisions is the replacement of expert, evidence-based judgment with discretionary political control at every stage of the funding lifecycle, paired with cost rules that isolate researchers from the scientific literature and useful scientific conferences. A grants system can be made more accountable without being made less rigorous. These provisions sacrifice the second in the name of the first, and the public — which pays for this research precisely so that it will be sound and usable — is the party that loses. I respectfully urge OMB to withdraw or substantially revise [200.205], [200.300], [200.340], [200.432], [200.454], [200.461], and the related provisions listed above.
Respectfully submitted, [YOUR NAME, DEGREE] [YOUR TITLE] [YOUR INSTITUTION] [OPTIONAL ADDITIONAL AFFILIATION LINES]