What We Need to do NEXT: OMB’s Proposed Federal Financial Assistance Rule (OMB-2026-0034)

What OMB’s Proposed Federal Financial Assistance Rule Means in Practice

Reading the changes together, this is what a researcher or institution would face under the proposed rule:

• A program officer at NIH or NSF wants to solicit applications for a study on health disparities. Before the NOFO is posted, the program must be designed to align with administration policies and priorities. A senior political appointee must approve the NOFO. Applications can be excluded based on institutional affiliations.

• A researcher submits a proposal. It passes peer review. A political appointee reviews it and decides it involves “anti-American values.” It is denied. The peer review recommendation is advisory. There is no appeal right.

• A researcher three years into a five-year NIH grant publishes findings on climate-related illness. A new agency priority memo is issued. The grant is terminated. The researcher has to let go her staff and drop the participants mid-study. The agency needs only provide a brief written rationale.

• A postdoc needs to renew a journal subscription to access literature for her grant work. The subscription is now an unallowable cost. Her institution has limited library access. She reads less, works less efficiently.

• A PI wants to present findings at a major international conference not listed in the original award terms. She needs agency pre-approval. It is not granted.

• A university wants to publish its NIH-funded results in an open-access journal to comply with the 2022 OSTP mandate. The article processing fee is now unallowable. It cannot comply with both rules at once.

How to Stop the new OMB Rule

What Is at Stake in the Comment Period

Under the Administrative Procedure Act, OMB must respond to every significant comment before finalizing the rule. A large volume of substantive comments serves three purposes:

• It creates a record of opposition that courts can review if the rule is challenged

• It forces OMB to defend each provision individually, potentially causing them to drop or narrow the most indefensible ones

• It signals to Congress that the rule is controversial enough to warrant legislative action or appropriations riders

A form letter campaign is far less effective than individual substantive comments. OMB can dismiss 100,000 identical comments as a single comment. A single well-argued comment from a scientist, university, or professional society explaining exactly how a specific provision would harm a specific type of research carries far more weight.

Who Should Comment and What They Should Say

Different audiences have different standing and different persuasive angles:

Scientists and Researchers

• Describe a specific grant you hold or have held and explain precisely which proposed provision would have prevented it from being awarded or would terminate it now

• Explain concretely what journal subscriptions or publication fees you use grant funds for and what the research cost would be if they were eliminated

• Describe international collaborations on your grants and explain what scientific capability would be lost

• Cite the specific section numbers (§200.205, §200.340, §200.454, etc.) — specificity matters

Universities and Research Institutions

• Calculate the dollar value of grants that would be at risk from the discretionary termination provision and include the number in your comment

• Document the administrative cost of E-Verify compliance across your institution and the disproportionate impact on researchers on work visas

• Identify specific ongoing multi-year grants that would be retroactively exposed to termination for “national interest” reasons

• Argue that the guidance-to-regulation conversion violates the APA’s notice-and-comment requirements and that the rule is arbitrary and capricious

Scientific and Professional Societies

• Document the number of members who attend specific conferences using grant funds and the cost of those conferences

• Cite the history of peer review as the basis of U.S. scientific leadership and the specific post-WWII policy history being dismantled

• Identify the specific conflict between §200.461 (publication costs unallowable) and the 2022 OSTP open access mandate (publication required) and demand OMB resolve it before finalizing the rule

• Submit comments as an organization with member signatures attached to demonstrate scale of opposition

Patient Advocacy Organizations and Public Health Groups

• Identify ongoing federally funded research on diseases affecting your community that involves health disparities analysis — research that would be barred under §200.218 (disparate-impact prohibition) or §200.300 (DEI prohibition)

• Explain the real-world consequences of terminating mid-project clinical or community-based research: participant harm, lost data, broken trust

State Governments and Tribal Nations

• Document federal grants to your state or tribe that fund public health, environmental monitoring, or social services research that would be endangered

• Note that the discretionary termination provision applies to pass-through awards to states and tribes, not just direct federal grants

• Raise the Spending Clause argument: Congress appropriated these funds with conditions; OMB cannot unilaterally add new conditions through rulemaking

How to Submit a Public Comment on the OMB Grants Rule

A step-by-step guide for first-time commenters — no experience required

THE DEADLINE IS JULY 13, 2026 AT 11:59 PM EASTERN TIME

You must submit your comment by midnight ET on July 13. Comments received after that time may not be considered. You do not need to be an expert, a scientist, or a lawyer. Anyone can comment. The comment system is free and takes about 10 minutes.

Why Your Comment Matters

The federal rulemaking process is one of the few places where any member of the public has a legally guaranteed right to be heard. Under the Administrative Procedure Act, OMB is required by law to read every comment it receives and respond to every significant one before finalizing this rule. That means:

• Your comment becomes part of the permanent public record

• If enough people raise a specific legal or factual problem, OMB must either fix it or defend it in writing

• Courts can review whether OMB adequately responded to public opposition — a strong comment record strengthens any legal challenge

• Congress watches comment volumes. Thousands of substantive comments signal that a rule is politically contested

⚠️ One good comment beats a thousand identical ones

When many people submit the exact same form letter, the agency counts it as a single comment. A comment written in your own words, about your own experience, carries far more legal weight. You do not need to write much — even three paragraphs in plain language describing how this rule would affect you personally is more valuable than any petition.

STEP 1 Go to the Right Place

The official comment portal is regulations.gov. Go directly to the docket for this rule.

DIRECT LINK: https://www.regulations.gov/docket/OMB-2026-0034

Or go to www.regulations.gov and search for: OMB-2026-0034

When you land on the docket page, you will see the proposed rule document and a blue button at the top left of your screen that says: “Comment.” Click it. That is the button you want.

STEP 2 Fill in the Details of the Comment Form

At the top, you will see a box to type you comment. You have room for 5000 characters. This is a required field. I will give you advice on how to write your comment below in the next step.

Underneath the comment section there is a box that says “What is your comment about?” It has a pull down menu to chose from some options (but this is not a required field).

Underneath that is an upload box where you can add attachments. This could be a written version of your comment or supporting information. This is also optional.

Email address (optional): Providing your email allows regulations.gov to send you a confirmation and notify you when the agency responds in the final rule. Recommended, but not required.

Below that are 3 boxes. Click to indicate if you are an Individual, Organization, or Anonymous. When you click it will give you fields to enter your name.

First name, Last name, and Organization (optional): You do not have to provide your name. You can submit anonymously. If you do provide your name and/or organization, it will be published publicly along with your comment on regulations.gov.

PRIVACY NOTE: Everything you type into the comment form, including your name and organization if provided, will be posted publicly on regulations.gov. Do not include your home address, phone number, or other personal information you do not want made public. You may use just your first name, or no name at all.

STEP 3 Write Your Comment

This is the part people find most intimidating, but it does not need to be. The goal is simply to explain, in your own words, why this rule concerns you and how it would affect you or your work.

The Most Effective Structure (Use This as a Template)

1: First paragraph: Say who you are and why you are qualified to comment. You do not need credentials — being affected is enough. Examples: “I am a graduate student in immunology at [university] who receives NIH funding.” Or: “I am a member of the public who cares about federally funded medical research.” Or: “I am a faculty member whose research on [topic] has been supported by [agency] for [X] years.”

2: Second paragraph: Identify the specific provision(s) that concern you by section number, and explain what they would do. You do not need to quote the rule directly — just explain what you understand it to mean in plain terms.

3: Third paragraph: Explain the concrete harm. What would happen to you, your lab, your institution, your community, or your field if this provision takes effect? The more specific and personal, the better.

4: Closing: State clearly what you want OMB to do. This can be as simple as: “I urge OMB to withdraw this provision” or “I urge OMB not to finalize this rule.”

Section Numbers to Reference

Including the specific regulatory section number shows OMB that you have read the rule. Here are the some key ones:

Section

• §200.205 — Political appointee review of grants

• §200.340 — Grant termination

• §200.432 — Conference attendance pre-approval

• §200.454 — Journal subscriptions (now unallowable)

• §200.461 — Publication costs (now unallowable)

• §200.300 — DEI and gender ideology prohibitions

• §200.218 — Disparate-impact research banned

• §200.220 — Foreign collaboration prohibition

• §200.202 — Programs must align with administration priorities

• §200.204 — Grant competitions can be exempted from public notice

What Makes a Comment Strong

• Specific: Name the section, describe the change, explain the harm. Vague objections (“this is bad”) are easy to dismiss.

• Personal: Describe your own situation. How does this affect your actual work, research, funding, or institution?

• Factual: If you can quantify the harm (“my lab has three international collaborators on a current NIH award”), do so.

• Your own words: Do not copy someone else’s comment. An original comment in plain language is more valuable than a polished form letter.

What Makes a Comment Weak

• Identical to many others: Form letters are counted as one comment regardless of how many people submit them.

• No specific section cited: General opposition without identifying a specific provision is harder for OMB to be required to address.

• No personal connection: Comments that read as purely theoretical carry less weight than ones describing real-world impact.

Example Comments by Audience

These are examples only — write in your own words!

Example: Graduate Student or Postdoc

I am a third-year PhD student in biochemistry at [University], funded through an NIH R01 grant to my advisor. I am writing to oppose the proposed revisions to §200.205 and §200.454. Section 200.205 would require a senior political appointee to personally review and approve every discretionary grant, with authority to override peer review. My training, and my career, depends on the principle that scientific funding decisions are made by qualified experts, not political officials. The proposed rule also makes journal subscriptions unallowable (§200.454). I currently access [X] journals through grant funds that are essential to my dissertation research. If this provision takes effect, I will not be able to read the literature in my own field. I urge OMB to withdraw §200.205(b) and restore §200.454 to its current form.

Example: University Research Administrator

I am a sponsored research administrator at [Institution], where I manage federal grant compliance for [X] faculty investigators. I am submitting this comment to oppose the proposed §200.340 termination provisions. The proposed rule allows agencies to terminate any active discretionary grant if it no longer aligns with “the national interest as they exist at the time of the termination.” This standard is so broad and undefined that it effectively converts every multi-year federal research award into an at-will arrangement. Our institution currently holds [X] active NIH and NSF awards totaling approximately $[Y]. Many of these support clinical studies, longitudinal surveys, and graduate training programs that cannot simply stop mid-project without causing serious harm to participants, students, and the research record. I urge OMB to strike the “national interest” termination standard from §200.340(a)(2) and restore the existing provision that limits termination to noncompliance and mutual agreement.

Example: Member of the Public

I am a [teacher / nurse / parent / taxpayer] writing as a member of the public who cares about federally funded medical research. I do not have a scientific background, but I understand that this rule would give political appointees the power to override scientists in deciding which research gets funded. I have a family member with [condition] who has benefited from treatments developed through NIH-funded research. The idea that future research on diseases like this could be denied funding not because scientists found it unworthy but because a political official decided it did not advance the President’s priorities is alarming to me. Science should be funded based on evidence, not politics. I strongly urge OMB to withdraw the pre-issuance political review provisions in §200.205 and not finalize this rule.

STEP 4 Submit and Save Your Confirmation

At the bottom you must click the “I am not a Robot” button.

Finally, there is a Blue Submit Comment at the very bottom when you are done.

Click it!

After submitting, you will receive:

• A tracking number on screen — write it down or take a screenshot

• A confirmation email if you provided your address

• Your comment will appear publicly on regulations.gov within a few days

That’s it. You have officially participated in the federal rulemaking process.

STEP 5 Spread the Word

The more substantive comments OMB receives, the harder it is to finalize the rule without significant changes. Share this guide and the deadline with colleagues, professional networks, and anyone else who might be affected.

• The deadline is July 13, 2026 at 11:59 PM Eastern

• Encourage people to write in their own words, not to copy anyone else’s comment

• Professional societies, universities, and patient organizations can submit institutional comments signed by their members — these carry additional weight

Frequently Asked Questions

Do I need to be a U.S. citizen to comment?

No. Anyone can submit a public comment. There is no citizenship requirement.

Will my comment be made public?

Yes. Your comment, along with any name or organization you provide, will be posted publicly on regulations.gov. Do not include your home address, phone number, or other information you want kept private. You can comment anonymously.

How long does my comment have to be?

There is no minimum. Three clear paragraphs are perfectly sufficient. Quality matters far more than length.

Can I submit more than one comment?

Yes, but one well-written comment is more effective than multiple short ones.

What if I miss the deadline?

Late comments may not be considered. The rule states they will be considered “only to the extent practicable,” which in practice means they may be ignored. Submit before July 13.

What happens after the comment period closes?

OMB reviews all comments and then publishes a Final Rule. The Final Rule must respond to all significant comments. The administration has indicated it intends to finalize the rule with an effective date of October 1, 2026. If the rule is finalized, legal challenges are expected.

Is there anything else I can do besides commenting?

Yes. Contact your members of Congress — particularly members of the Senate HELP Committee, Senate Commerce Committee, House Science Committee, and the appropriations subcommittees that fund science agencies. Tell them you oppose this rule and ask them to support a Congressional Review Act resolution of disapproval or an appropriations rider that prevents implementation.

Share this guide with anyone else who should comment!