OMB Proposed "Regulation for Federal Financial Assistance" will Permanently Change U.S. Science

Read our comment calling on OMB to reject their proposed revisions to title 2 CFR §200

On July 13, 2026, 27 UNIHTED submitted our response to the Office of Management and Budget’s proposed rule, “Regulation for Federal Financial Assistance.” This rule’s simple title hides the harm that OMB proposed to codify, such as adding political reviewers to scientific research grants and impeding scientists from using grant funds to publish their findings in scientific journals. If enacted, this rule will force political control over nearly every stage of federally-funded research, taking the research enterprise out of the hands of researchers and putting it into unqualified politicians. To learn more about the rule check out our action guide.

Our team read through the entire 400-page rule and highlighted areas in our comment that would cause the most harm to the scientific research workforce. You can read our full comment below.

“27 UNIHTED is a non-profit organization founded by unlawfully terminated NIH employees advocating for an equitable, publicly funded health research ecosystem grounded in scientific integrity and academic excellence. We serve current NIH workers and alumni, the scientific research community, and patients benefiting from new medical discoveries.

In addition to advocating for health research, we provide community support because we believe successful scientific research infrastructure depends on a healthy and stable research workforce. 27 UNIHTED strongly opposes the proposed revisions to rule §200 due to their potentially deleterious impact on the communities we serve and the American public. Our concerns about specific provisions are articulated in detail in the attached document and fall into four categories:

1. Political overreach. Several sections propose putting political appointees in charge of making scientific decisions. Provisions §200.202, §200.205, §200.206, §200.340, §200.342, and §200.343 remove the independence of scientific agencies and operational divisions, taking the locus of scientific decision making out of the hands of those with direct expertise and ability to gauge the potential value of the proposed science. The proposed rule threatens scientific progress by enabling arbitrary grant terminations and interruptions without opportunity to appeal. This will result in an inability to support long-term projects that move science from bench to bedside, a major goal of NIH-funded research. Furthermore, the provisions requiring political review of all awards whenever an administration’s priorities change will impart undue administrative burden on the agencies and operational divisions. Devaluing scientific merit review, requiring scientific endeavors to align with political ideologies, and terminating awards without recourse to appeal will destabilize the United States scientific community and endanger our ability to train and retain talent now and in the future. Changing the entire system drastically in this way will break the structures that have made the United States the world leader in biomedical research for over half a century, opening the NIH and federal government to financial liability, and harming patients in the process.
   

2. Reductions in transparency and communication. Several proposed provisions reduce the ability of the scientific community to present, publish, and discuss their work and results, either with each other or with the general public. Sections §200.432, §200.421, §200.454, §200.450 and §200.461 would disallow conference attendance costs, professional society membership costs, publication costs, and marketing costs. Federal funding requires award recipients to share their results publicly through scientific peer-reviewed publications and conference presentations, and these rules put scientists in direct conflict with the requirements of their funding agencies [1]. In addition, they impede scientists’ ability to receive feedback and hear opposing viewpoints. Publishing, society membership, and conference attendance will become an unaffordable luxury for the majority of scientists. Sections §200.421 and §200.450 disallow costs associated with communicating scientific results to the public and to policy makers, the people most directly impacted by health research. Finally, section §200.202 removes the requirement for community engagement from the design phase of studies, hindering communication and trust between agency scientists and the public.
   

3. Increasing disparities and decreasing equity. Sections §200.218, and §200.300 remove the considerations of disparate impact from federally funded awards, decreasing the ability of federally funded research to find health solutions and treatments that work for everyone. The removal of any diversity, equity, and inclusion considerations will mean that research addressing historical disparities and underserved communities will be disrupted and these communities will be vulnerable to discrimination based on sex, gender, race and other characteristics.
   

4. Reducing international collaboration and global impact. Sections §200.202 and §200.220 reduce the ability to directly fund or collaboratively work with scientists in other countries. Together, these provisions limit the ability of U.S. scientists to collaborate on the global stage and to pool collective knowledge, build large and diverse study cohorts, share epidemiological data, and work together to solve global health crises.

For these reasons, which are elaborated in the attached document, 27 UNIHTED opposes the proposed revisions to rule CFR §200 in the strongest terms and urges OMB to reject these proposed revisions.

27 UNIHTED has reviewed the proposed rule and has serious concerns about the potential loss of scientific integrity and other impacts as a result of the following provisions. We have outlined our concerns with each provision and how it will negatively impact the communities we serve.

Section §200.202 —Changes to Program Planning and Design:

Because administration priorities change between administrations and from year to year (or even month to month) within the same administration, 27 UNIHTED is concerned that this and similar provisions could be extremely destabilizing to the scientific workforce and its efforts to advance biomedical and public health research.

This provision would make it so that programs designed by the NIH and other federal agencies reflect White House priorities. This goes against federal law, where these powers are intended to rest with congress [2], and poses a serious risk to the scientific integrity of our federally funded programs. Additionally, the resulting instability in grant funding will lead to loss of knowledge and data, increased inefficiency, and wasteful government spending.

27 UNIHTED is also concerned by sub-section §200.202 “(f) Multi-year awards.

“When consistent with program objectives, and subject to restrictions in law, Federal agencies are encouraged to design Federal programs to allow for multi-year awards with budget periods longer than one year, rather than issuing separate notices of funding opportunities on an annual basis.”

In 2025, we have seen firsthand that such multi-year funding has reduced the number of awards [3, 4] that NIH have been able to make. This reduction in awards has had a particularly deleterious impact on scientists who are just starting their careers. Early career scientists depend upon their first federal award to build their research groups and to produce their initial, substantial research results. The timing of such first awards impacts the success of early career scientists. Reducing the number of awards in the way proposed by subsection §200.202 will have detrimental effects on workforce development and lead to a loss of talent from up and coming generations. This will erode U.S. competitiveness for decades to come.

Section §200.205 — Federal Agency Review of Merit of Proposals:

27 UNIHTED’s understanding of this section indicates that prior to release of funds, all federal awards, prior to administration, will be subject to pre-issuance review award by a political appointee to ensure awarded funds fit within “applicable law, federal agency priorities, and the national interest.”

1. Alignment with national interest: In the text proposed, national interest is not well defined and opens itself up to the whims of the current administration, putting scientific integrity and public health priorities behind political utility.

2. Banning of certain kinds of work/research subject to pre-issuance review: Another concern with this provision is the concept of banning awardees from facilitating “racial preferences or discrimination… denial by recipient sex binary… illegal immigration… [or] compromise of public safety or promote anti-American values.” Our community is focused on the importance of the research being conducted to best serve scientific needs. At times, this may mean enrolling certain populations, such as individuals from specific racial and ethnic minority groups, as they are more likely to develop certain diseases; studying the health of people from sexual and gender minorities; or studying the behavior and health of immigrants in the United States. We are concerned that grant recipients with legitimate scientific interest in these topic areas will not be able to pursue their research, due to this pre-issuance screening. Additionally, the “concept of anti-American values” is undefined and can be used indiscriminately. One has only to look back on our not-too-distant past and the McCarthy-era blacklisting for evidence of this, raising concern that valuable research may be easily misclassified under this label.

3. Preference for indirect costs: We take issue with the emphasis on preferentially awarding grants to organizations with lower indirect costs, as opposed to funding applications based on scientific merit. This opens the door to discrimination of grantees based upon which institutions they belong to, instead of making funding decisions on the merit of the proposed research.

4. Devaluing of peer review: The language used to demote the value of peer review is concerning to our community. Peer review is the backbone of our scientific institutions. It is not merely advisory, but it is and should be one of the significant bases upon which we decide scientific priorities and what research to fund. The integrity of peer review is already being undermined, and this provision would accelerate the decline in the value of fair and unbiased review in selecting meritorious science to fund [5].

5. Undefined “gold standard science”: Finally, prioritizing institutions that embody “gold standard science” without defining that concept is extremely alarming and may lead to the funding of grants based on political bias rather than scientific merit.

Section §200.206 — Federal Agency Review of Risk Posed by Applicants:

27 UNIHTED objects to section §200.206: Agency review of risk posed by applicants. Specifically, we are concerned with the following language:

“(C) Engaging in activities or initiatives that are inconsistent with Federal civil rights laws, including the equal protection principles of the U.S. Constitution and prohibitions against unlawful discrimination; and/or…

“(D) Engaging in activities or initiatives that are inconsistent with religious liberty laws… (viii) Memberships and affiliations. Based on publicly available and verifiable information, the applicant’s membership in or 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…”

Regardless of the merit of their proposed science, research proposals into issues affecting marginalized groups may not make it past the preissuance phase of federal grant awarding, because, according to subsections §200.300 and §200.218, the researchers could be accused of engaging in activities or initiatives that are inconsistent with federal civil rights laws. As mentioned previously, some research necessitates enrolling individuals from specific groups who are most affected by a disease or condition, and such research would be flagged by this proposed update.

Additionally, we have seen retaliation against legal whistleblowers [6] from this administration. This raises the concern that people may be denied federal funds if they have participated in legitimate legal actions and free speech activities. While these activities do not break any written laws, they may nevertheless be labeled as “violating federal law, undermining public safety or national security, or advocating for overthrow of the US government” by a vengeful administration.

Another concern with this provision is the emphasis on religious freedom. We agree all grantees and federal workers must be free to practice any religion they choose, as is their legal right. However, earlier this year universities that were hosting pro-Palestianian demonstrations – including nonviolent, lawful protests – were targeted and their federal funds were paused due to alleged “anti-semitic behavior” [7]. Our fear is that this language may be used to target various universities or grantees who exercise their own free-speech and freedom of religion rights to pause or terminate federal funding, in the name of “religious liberty.”

Sections §200.340, §200.342, and §200.343 —Termination and Suspension of Grants & Opportunities to Object, Hearings, and Appeals

27 UNIHTED would like to emphasize the harm that would be done by the provisions that allow for political termination of awards (Sections §200.340, §200.342, and §200.343). Currently, a grant can be terminated if the awardee commits fraud or mis-uses funds; these are misdeeds that can be documented and proven. However, under this new proposal, an award can be terminated merely on the basis of a changing political landscape or interests. It is unclear who determines which grants may fall out of the national interest or who defines these categories, making these purely “discretionary terminations.”

Because many awards were terminated in this way in fiscal year 2025 (at the time illegally), we can document the harm that was done as a result of grant interruptions and terminations midstream:

1. Loss of taxpayer dollars: When grants are cancelled, taxpayer dollars are lost. Grants are an investment for the American people. Unfinished projects, and all of the taxpayer dollars that were invested into them, are simply gone when a grant is terminated. For example, a $5 billion grant for 5 years allotted $1 billion a year terminated at year 3 wastes $3 billion with nothing to show for it.

2. Loss of knowledge and data: If terminations can occur due to changes in administrative priorities, previously funded research can be terminated before research results have been obtained. Due to the lack of research results, whether positive or negative, federal funds spent on such truncated projects are effectively wasted. The knowledge gained is lost to the community, and therefore to scientific progress, if results are never finalized, presented, and peer-reviewed.

3. Research restarting: The loss of grant funding can lead to researcher layoffs and the loss of expertise. If similar research is later funded, due to changing “political alignment” of a new award or refunding of the terminated award, new researchers must be trained and, often, need to re-do previously performed research. Similarly, interruptions in clinical trials and studies focused on the implementation of effective treatments in health care settings, which may take years to complete, will result in the need to restart the study, including the recruitment of new patients for the study.

4. Universities and colleges workforce takes a hit: These provisions will create more instability in the research infrastructure because scientists will not be able to depend on the continuation of their research funding. Even when researchers are appropriately conducting their research, using their funds responsibly and making progress, their grants can be cancelled if political priorities change. This has already led to fewer acceptances into PhD programs in the 2025-2026 year [8], along with layoffs at large universities, further impacting the economy [9].

5. Marginalized researchers, workers, and patients hit the hardest: Additionally, due to agency realignment of research similar to the proposed prohibitions in provisions §200.300 and §200.218, researchers of marginalized identities have been hit the hardest. This will impact the future generation of researchers, shrink the talent pool at universities, and lead to less effective science. When science has diverse researchers behind it, it is more effective. The 2025 grant interruptions have already impacted marginalized communities the most [10].

6. Patients face real risk: The interruption of clinical trials mid-stream leads to adverse events for real patients, including death. As a result, universities and researchers will more than likely be less inclined to conduct high risk clinical trials. This will lead to less translational research, and ultimately, less benefit to the American public [11].

27 UNIHTED is concerned not just about grantees, study participants and the general public being served by NIH research, but also about effects within the federal government. The proposed requirement that applications and funded grants be “aligned with administrative priorities” greatly expands the time it takes for program officers and grants management staff to evaluate and administer grants. Given reductions in the federal workforce, the requirement already has, and will continue, to overwhelm the federal workforce. Increased time and stress are likely to lead to the funding of fewer grants, thereby decreasing American competitiveness on the global stage [11].

Sections §200.432, §200.461, §200.450, §200.454, and §200.421 — Reductions in transparency and communication

The mission of the NIH is “to seek fundamental knowledge about the nature and behavior of living systems and the application of that knowledge to enhance health, lengthen life, and reduce illness and disability.” In order for science to be conducted properly and for the NIH mission to be achieved, there needs to be communication, both within the scientific community and also to the people that the science serves. It is important that the outcomes, benefits, and health guidelines that occur as a result of biomedical research are communicated to the public in a way that they can understand and act on.

The proposed changes to communication-based regulations are of particular concern to 27 UNIHTED. 27 UNIHTED represents many former federal communications staff. They have expressed their deep concern about the impacts of these proposed provisions. Communications-based provisions will lead to censorship of scientists and universities/research institutions, and adversely impact their ability to communicate with the public and other scientists. This represents a significant loss of transparency for how researchers use taxpayer dollars to advance scientific knowledge. These main concerns are broken down into the following:

1. Sharing of scientific ideas with other scientists:

   1. Conference attendance (§200.432): The OMB guidelines propose new restrictions on scientists’ ability to attend conferences by disallowing federal research funds for conferences not given explicit permission from the federal government. This will create undue administrative burden for federal agencies and for federally funded researchers, and will discourage attendance from conferences. With this change, only those who can afford to pay their own way will be able to attend conferences, as well as those who choose to cater to this administration’s priorities, regardless of their scientific merit. This also raises the concern that there may be conferences that an administration does not like and so does not allow, as there is no definition for what will or will not be approved by federal agencies.

   2. Journal publications (§200.461): This provision will add undue burden to administrators and researchers by requiring advanced approval by each federal agency prior to submission. There is no defined metric for approval, and therefore, there is significant concern that researchers will be barred from publishing their results in reputable scientific journals. This will lead to only well-off researchers and universities being able to publish scientific papers, and further harm researchers and the American public by limiting access to potentially life-saving results.

2. Lobbying (§200.450): This proposes to “prohibit using Federal funds to engage in issue advocacy or public messaging that promotes or opposes a particular social, political, or public policy position unrelated to the statutory objectives or performance requirements of the Federal award, including messaging designed to influence public attitudes on matters not necessary to accomplish the purpose of the Federal award.” Similarly to other ill-defined provisions, this calls for programmatic alignment with White House priorities, and creates the ability for political appointees to terminate grants at any point in time. This can lead to awardees being fearful of exercising their legal rights to participate in the political process and is another example of potential censorship proposed by this administration.

3. Professional memberships (§200.454): Costs of membership and subscriptions are only allowable if needed to fulfill award requirements and will require written consent of the federal agency. Because no rules or guidelines are laid out for who will approve these memberships and on what basis, this also leaves open the ability of an unscrupulous administration to exert undue influence, and favor or disfavor professional societies for political rather than scientific reasons. This creates additional undue administrative burden on agencies and award recipients to receive prior written approval.

4. Advertising and Public Relations (§200.421): This proposes to prohibit scientists from engaging in “issue advocacy or public messaging” related to their research. These are essential functions for the practice of doing science. Public science is done in order to benefit the public and requires policy advocacy and public messaging to ensure the benefits reach the public. These changes to the rules would make it difficult for researchers to communicate with other scientists and will stall science as we know it. Additionally, Congress mandated that the public be informed of federally funded research that uses taxpayer dollars. Rule §200.421 threatens university and institutional science/health communications by prohibiting federal research funds from covering public relations costs, with limited exceptions. Aside from keeping the lights on in labs, federal grant funding traditionally covers other indirect costs, including the communications work required to translate and promote federal research findings across websites, magazines, social media, and press releases. If this rule goes into effect in its current form, universities and research institutes stand to lose critical funding to continue supporting their crucial communications functions, and institutional communicators could face unemployment.

Impeding public communication of science will prevent effective scientific collaboration and innovative discovery through limitations on publications, memberships, and conference attendance funds, and will create undue burden on administrators for potential allowances. It will keep taxpayers in the dark, leaving them unaware of new breakthroughs or cures that could directly impact their lives or those of their families because grantees will be unable to use funds for public relations and marketing. This also is counter to some of the stated goals of these new provisions, such as increasing transparency. Limiting communication of scientific findings and efforts to limit transparency run counter to the core mission of the NIH, which seeks to apply knowledge to improving the health of the citizens.

Sections §200.218 and §200.300 — Increasing disparities and decreasing equity

27 UNIHTED is concerned about the language included in the OMB proposed rule related to reducing discrimination in the workforce and in research, provisions §200.218 and §200.300. Notably, the following language raises several concerns:

• Ban on use of DEI and disparate ideological impact liability may prevent vital research from being conducted: The use of “diversity, equity, and inclusion and accessibility (DEIA)” is not well-defined in this document. By law, NIH has a mandate for the inclusion of individuals from racial and ethnic minority populations, as well as women in research, including clinical studies and trials. These two proposed provisions risk conflating programs that seek to attract diverse individuals into research training programs, as opposed to research on health in diverse populations, such as racial and ethnic minority populations, sexual and gender minority populations, and individuals with disabilities, low-income populations, and populations from underserved regions or localities. Many of the diseases or health conditions within NIH’s mission are more common in individuals from racial and ethnic minority populations, sexual and gender minority populations, individuals with disabilities, low-income populations, and populations from underserved regions or localities. In addition to differences in the incidence of diseases in these diverse populations, they are disproportionately more likely to suffer from worse outcomes associated with these diseases, a concept known as health disparities. Considering the ill-defined language in this proposed rule, it has the potential to limit the ability to develop and implement programs, many of which are Congressionally mandated, which address health disparities and seek to improve the health of all Americans. This rule, as written, will also have implications for understanding the social, behavioral, and environmental factors that underlie differences in health outcomes across diverse populations. We have already seen many of these programs diminished or put at extreme risk under Executive Orders that used similar language.

• Harms to the scientific workforce: Training programs at NIH have existed for years to promote diversity in science and scientific research populations. This provision will codify the damage done in the last year by unlawful and premature termination of these vital research programs [12]. These programs were designed based upon decades of research and data stating that disparities within the scientific workforce existed. They were created to solve a problem of racial discrimination within the workplace, and to promote new voices within the scientific ecosphere. By implementing provision §200.218, it will further narrow the scientific workforce, and ban any meaningful evaluation and implementation into broadening it once again.

• Gender ideology language: In both provisions, focusing on gender ideology language will harm people within the queer community. It may make it more difficult to conduct research on the queer community, to understand and research the best treatment for trans youth and people experiencing gender dysmorphia. Additionally, in neither provision is the language clear or well-defined. Although discrimination on the basis of sexual orientation or gender identity remains unlawful, these changes may actually result in encouraging discrimination against transgender individuals. It also may result in preventing federal agencies from recognizing and supporting research enrolling transgender individuals, including children.

• Policing of language leading to overcompliance: Similar to a note in Lobbying §200.450, overcompliance is an unfortunate side effect of the issue, as individuals may not propose important and impactful scientific studies if they are fearful that anything they may be interested in researching may lead to a grant termination or a lack of funding.

Foreign Collaboration §200.220 — Prohibition of Using Federal Funds for Covered Foreign Collaborations

The OMB proposed rule will prohibit federal funds from being used to support collaboration with a covered foreign country or covered foreign entity, unless required by statute or approved by a political appointee.

While legitimate national security concerns may exist in some areas of science, 27 UNIHTED views the broad application of this provision to all areas of federally funded science as unnecessary, overly cumbersome, and counterproductive to both scientific advances and foreign policy. This may be particularly true given the administration’s prior actions [13] to interrupt any research with any foreign country, regardless of the country’s relationship to the United States, suggesting restrictions on international collaboration may be based upon misguided “America First” policies that do not understand the international nature of science, rather than any national security interests.

Foreign collaboration is often critical to scientific advances. When science produces knowledge, that knowledge is typically shared openly, informing science conducted around the world. The top expert in a given field may reside in any country, requiring partnership across borders to optimize that expertise. Resources that enable science, including technology platforms or data sets, may only be available in certain countries. For rare diseases, global recruitment may be necessary to identify sufficient numbers of patients. Pathogens may emerge in any country, and mounting a rapid response to an emerging pathogen requires existing in-country relationships. Thus, interruption to international collaborations could undermine scientific progress and risk public health in the United States and across the globe. As data becomes the currency on which we all rely, establishing international data standards so that datasets can be combined and are interoperable is an important collaborative effort. If U.S. scientists are left out of these global conversations and collaborations, they will be left behind in the scientific endeavors of the future.

For these reasons, and for the long-term harm these provisions would do to the U.S. biomedical research enterprise and the American public health and safety, 27 UNIHTED opposes the proposed revisions to rule CFR §200 in the strongest terms, and urges OMB to reject these proposed revisions in their entirety.

Citations:

1. https://grants.nih.gov/policy-and-compliance/policy-topics/sharing-policies

2. https://www.congress.gov/crs-product/R45442

3. https://www.science.org/content/article/nih-likely-award-fewer-grants-it-races-spend-2026-budget

4. https://substack.com/@scienceandfreedomalliance/note/p-169501471?utm_source=notes-share-action

5. https://27unihted.substack.com/p/the-quiet-attack-on-science-subverting

6. https://www.science.org/content/article/fired-nih-institute-head-sues-trump-administration

7. https://www.pbs.org/newshour/education/trump-administration-freezes-2-2-billion-in-grants-to-harvard-university-over-campus-activism

8. https://www.insidehighered.com/news/government/science-research-policy/2026/05/27/nihs-use-multiyear-funding-grants-poses-research

9. https://www.highereddive.com/news/johns-hopkins-lays-off-110-employees-in-the-wake-of-federal-research-cuts/823929/

10. https://today.ucsd.edu/story/NIH-grant-terminations-disproportionately-impact-minority-scientists

11. https://www.27unihted.org/bethesda-declaration-one-year-later

12. https://kffhealthnews.org/race-and-health/nih-mosaic-diversity-grant-canceled-young-scientists-science-research-careers/

13. https://www.statnews.com/2025/05/01/nih-halts-research-funding-for-projects-involving-foreign-collaborators/

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Public comments are now closed for this proposed rule. Thank you to each and every one of our community members who have contributed to this comment and submitted your own comments. OMB must read each of the 496,769 comments that were submitted and respond. The action is not done though! Although we have spoken out; now, the responsibility to fix these proposed rules lies with OMB and Congress.

Action you can still take:

• Call your legislators: tell your legislators about your concern if this proposed rule passes

• Add your voice (named or anonymously) to the letter urging Congress to impeach Russell Vought from his role as Director of the OMB. He is responsible for this proposed rule and will continue to implement harmful, anti-science policies as long as he remains in power.

• Check out our advocacy menu: learn all the different ways you can take action to advocate for health research