Dear Colleagues,
The Office of Management and Budget (OMB) recently on Regulations for Federal Financial Assistance (Uniform Guidance). The goal of the revision, according to OMB, is to 鈥渋mprove transparency, accountability, and oversight for how Federal taxpayer dollars are used in the context of Federal grantmaking,鈥� and the Administration hopes to have a final Rule in place by October 1st, 2026. Among other things, the proposed rule implements several executive orders (EO) related to the federal grantmaking process and DEI, including the August 7, 2025, executive order on 鈥淚mproving Oversight of Federal Grantmaking.鈥�
While the University is continuing to review and analyze the proposal in detail with its national associations, the proposal fundamentally alters how all federal grants are awarded, administered and regulated 鈥� in ways that are of considerable concern.
Below is a high-level overview of some of the provisions in the rule to help the research community understand the proposal, its potential implications, and opportunities to provide feedback during the public comment period to help inform comments from 天美传媒 and our national associations.
Broad Overview of Major Proposed Changes:
- 鈥淧re-issuance鈥� review by a senior political appointee of every discretionary grant before it is made; the peer review process will become 鈥減urely advisory鈥�.
- Preference to give awards to institutions with lower IDC rates;
- 鈥淭ermination for convenience鈥�.聽 The OMB is proposing that federal agencies include language permitting immediate termination of grants if an award no longer advances “agency priorities, or the national interest.聽 The OMB also proposes to remove the ability to appeal such terminations.
- Potential restriction on health disparities research.
- Domestic first framework – may impact all foreign collaborations, and particularly collaborations with 鈥渇oreign adversaries鈥� or related entities.
- New restrictions on publication and related costs
More Detailed Outline of Key Proposed Changes:
Grant Review
In accordance with the August EO, the proposed rule would require senior political appointees, rather than career scientists or program officers, to conduct a 鈥減re-issuance review鈥� of every discretionary grant before it is awarded. It also states that the peer-review process will be purely advisory, and award selection will be at the agency鈥檚 discretion. Furthermore, it forbids appointees from deferring to peer reviewers or routinely ratifying their recommendations.
Also as previewed by Executive Order 14332, the proposed pre-issuance review principles state that, 鈥渁ll else being equal, preference for discretionary awards should be given to institutions with lower indirect cost rates鈥�; and agencies are encouraged to award a 鈥渂road range of recipients鈥� and to prioritize an institution鈥檚 鈥渃ommitment to rigorous, reproducible scholarship over its historical reputation or perceived prestige.鈥�
鈥淭ermination for Convenience鈥�: Codification of grant termination capability, multi-year awards, use of Grants.gov, and streamlined Notices of Funding Opportunity
The proposed rule codifies a number of policies already being implemented across federal agencies by the Administration, making it easier for Agencies to terminate awards, as well as requiring or strongly encouraging research Agencies to use multi-year funding and simplified Notices of Funding Opportunity.聽聽 In addition , the proposed rule removes the ability of institutions to appeal such Terminations for Convenience (which was the basis for prior, successful, appeals by the University).
Publication and Open Access Costs
The proposal would significantly restrict the ability to charge publication costs鈥攊ncluding many open access publishing fees and article processing charges (APCs)鈥攖o federal awards. In many cases, these costs would require advance agency approval or may no longer be allowable.
Expanded Risk Assessments
The proposal expands an Agency鈥檚 ability to consider a number of factors when evaluating applicant risk, including a history of 鈥渜uestionable practices鈥� based on publicly available information, compliance with foreign gift and contract disclosure requirements, and 鈥渁ffiliations 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.鈥�
International Collaborations
The proposal establishes a 鈥渄omestic-first framework.鈥� Awards must be made to U.S. entities, a State, or Tribal government, and awards may not be made to foreign entities unless expressly authorized by statute or where a compelling interest exists. When designing programs, and evaluating applications, 鈥渋nternational elements鈥� may be included only if the Federal agency determines that such elements are justified, consistent with program objectives, and in the national interest of the United States.
The proposal would also prohibit bilateral or multilateral collaborations, agreements, programs, or activities with 鈥渃overed foreign countries鈥� or 鈥渃overed foreign entities,鈥� unless expressly authorized by Federal statute or approved by the Federal agency in accordance with the proposed exception authority and applicable law.
Conference Travel and Professional Activities
The proposal would increase approval and documentation requirements for certain conference, meeting, membership, and professional activity expenses. Researchers may need additional agency approvals before charging these costs to federal awards.
Research Resources and Subscriptions
As stated in聽 200.454: “(b) Costs of the recipient’s or subrecipient’s subscriptions to business, professional, academic, and technical periodicals are unallowable.” Memberships, subscriptions, databases, and similar resources would need to be more clearly tied to a specific award and research objective. Costs that support broad institutional use rather than a particular project may become more difficult to charge to federal awards.
Research Data Management and International Considerations
The proposal places greater emphasis on project-specific data management and domestic data storage. Certain provisions could also affect how federally funded projects engage with international partners, data systems, and research infrastructure.
Increased Oversight and Compliance Requirements
The proposal would expand documentation, reporting, and approval requirements across a range of grant activities and provide federal agencies with broader authority to oversee and, in some circumstances, terminate awards.
Codification of DEI restrictions
There are a number of provisions throughout the proposed Rule that collectively codify the Administration鈥檚 previous Executive Orders and policies aimed at prohibiting federal funding of diversity, equity, and inclusion programs.聽 Moreover, 200.218 may prohibit funds to be awarded for health disparities research.
What This Could Mean for Researchers and Research Support Units:
If finalized substantially as proposed, these changes could represent one of the most significant shifts in federal grant administration. Potential impacts include:
- Determination of which grants are funded by senior political appointees, and use of peer review on a purely advisory basis.
- Immediate termination of grants if an award no longer advances “agency priorities, or the national interest.
- Potential restriction on health disparities research
- Domestic first framework – may impact all foreign collaborations, and particularly collaborations with 鈥渇oreign adversaries鈥� or related entities
- Additional agency approvals for activities that are currently routine components of federally funded research.
- Increased administrative and documentation requirements for publication, travel, memberships, subscriptions, and other project expenses.
- Reduced flexibility in using grant funds to support scholarly communication, including some open access publishing costs.
- New considerations for research data management, storage, and collaboration practices.
What You Can Do Now:
We understand that many of you are disappointed, confused, or angry about these proposed changes. Please know that we are deeply concerned about their potential negative impact on your research and on the University. Because this is a proposed rule, implementation details and final requirements remain uncertain. However, if implemented as proposed, these changes would have a sweeping impact and introduce concerning changes into the process of federal funding of science in the United States.
At this stage, researchers and research support staff may wish to:
- Share questions, concerns, and examples of potential impacts with the Office of the Vice President for Research.聽 The University is developing an institutional response (see below) in coordination with peer institutions and national research organizations and will use feedback from researchers to help inform our formal institutional response.
- Review how publication, data management, conference participation, and other project-related costs are currently incorporated into proposals and award budgets
- Consider how the proposed changes could affect research activities, collaborations, and administrative processes within your area
Next Steps 鈥� Institutional Response:
The University, along with our national associations (Association of American Universities, Association of American Medical Colleges, etc.), is reviewing the proposed rule and will share any additional guidance. The proposed rule is currently open for public comment and may be revised before becoming final. The proposed rule has a 45-day comment period, with comments due by July 13, 2026. With our national associations, we are seeking an extension of that deadline giving the sweeping nature of these proposed changes.
As noted above, we are seeking input from the 天美传媒 research community as we develop our response.
While a number of scientific societies and advocacy groups are encouraging individual comments, it is very important that we get the feedback needed to have the strongest institutional and national response to this proposed rule.聽 Hence this request for your help and input.
Thank you in advance for your help and support in this effort.
Regards,
Steve Dewhurst, PhD
Vice President for Research and Chief Research Officer
Nicole S. Sampson
Provost and Chief Academic Officer
Josh Farrelman
Vice President for Government Relations