Today (July 13) Is the Last Day to Comment on a Rule That Could Reshape American Science
You don't need to have a PhD, be a scientist, OR be a Democrat to make a public comment on OMB-2026-0034-0001
Full PDF of OMB-2026-0034-0001
Elizabeth Ginexi’s excellent ‘cheat sheet’ for writing an impactful comment
Link to submit your comment on the rule
Today, July 13, 2026, is the last scheduled day to comment on a proposed federal rule that could change how research grants are selected, supervised, suspended, and funded across the U.S. government. The official comment page lists the deadline as 11:59 p.m. EDT tonight. The notice says late comments will be considered only “to the extent practicable,” so the safe course is to submit before the portal closes.
The proposal, titled Regulation for Federal Financial Assistance, is a proposed rewrite of the US government-wide framework for grants, cooperative agreements, and other federal financial assistance. It comes from the Office of Management and Budget (OMB) and participating grant-making agencies. It is not a bill before Congress, and it is not yet a final rule.
It is enormously consequential.
The same framework governs money supporting biomedical research, energy technology, agriculture, public health, education, environmental monitoring, infrastructure, rural programs, nonprofit services, and much more. For science in particular, the proposal would alter the relationship among expert review, political oversight, long-term grant stability, research security, institutional costs, and publication.
You do not have to be a scientist to comment. If you are a patient who depends on clinical research, a taxpayer concerned about waste, a small-town official who has administered a federal award, a farmer who relies on publicly funded agricultural research, a parent, a student, a veteran, a nonprofit employee, a business owner, or simply a citizen who cares about how executive power should work, you may have information OMB needs to hear. And unlike a social-media post, a substantive public comment becomes part of the formal rulemaking record.
Your public comment has legal force
The Administrative Procedure Act (APA) requires an agency to give interested people an opportunity to submit “written data, views, or arguments.” After considering the relevant material, the agency must explain the basis and purpose of the final rule.
The Supreme Court has described the duty to consider and respond to significant comments as part of the agency’s procedural obligation. A significant comment raises a relevant point that, if accepted, would require the agency to change its proposal or its reasoning. Agencies must confront material objections, which matters in court, as a reviewing court can set aside agency action that is arbitrary, capricious, contrary to law, or adopted without required procedure, and failing to address a significant comment can become part of a legal challenge to the final rule. Comments also help establish the administrative record.
Your comment will not bind OMB, but a well-supported comment can require OMB to confront a serious problem in public and provide a future reviewing court with something concrete to examine.
What the proposal would (and would not) do to science
The proposal’s stated goals include stronger taxpayer oversight, transparency, accountability, reduced burden on recipients, compliance with the law and administrative policy, research rigor, and protection against national security risks. Those are legitimate government concerns. Several parts of the proposal could improve grant-making, including an emphasis on reproducibility, measurable benchmarks, a mixture of near-term and potentially transformative research, and merit rather than institutional prestige.
The proposal would not abolish peer review, prohibit scientists from publishing, or cap negotiated indirect-cost rates. It also would not give a president legally unlimited power: statutes enacted by Congress, appropriations restrictions, the Constitution, and judicial review under the APA would still constrain agencies.
What it would do is change several important decision rules.
Senior-appointee review of discretionary awards (§ 200.205)
The change: Every discretionary award would receive a pre-issuance review by senior appointees or authorized designees. Reviewers must exercise independent judgment rather than routinely defer to other recommendations. Peer review may continue, but its recommendations are explicitly advisory. Where applicable, awards must demonstrably advance the President’s policy priorities.
The impact: Expert review would remain an input, but every award would pass through a more explicit political-policy checkpoint. The central question is how much individual funding decisions should depend on the current president’s agenda rather than expert merit and durable program criteria.
Termination and stop-work authority (§ 200.340)
The change: Where permitted by law and included in the award terms, an agency could end an award because it no longer serves program goals, agency priorities, or “the national interest as they exist at the time of termination.” A written stop-work order could generally last up to 90 days.
The impact: Multi-year experiments, clinical cohorts, field seasons, graduate training, and long-running datasets depend on continuity. A pause or termination can waste prior spending and produce losses that cannot simply be reversed by restarting. The authority can also help stop genuinely misaligned projects; the issue is whether the standard and review process are sufficiently clear.
Publication costs (§ 200.461)
The change: Journal page charges, article-processing charges, and open-access fees would be unallowable unless a statute requires them or the agency approves them in advance, case by case. Printing costs would remain allowable.
The impact: This is not a publication ban, and researchers could use other money. It would, however, place a common cost of sharing federally funded results behind an advance-approval gate.
Lower-overhead preference (§ 200.205)
The change: If competing applicants are otherwise equal, agencies should prefer the institution with the lower indirect-cost rate. OMB says this proposal does not change how those rates are negotiated and does not ask for comments on that separate system.
The impact: Lower overhead can leave more money for direct project work and may help some new entrants. But indirect costs also pay for shared laboratories, utilities, safety, cybersecurity, libraries, compliance, and grant administration. The effect will depend on how “all else equal” is applied.
“Gold Standard Science” criteria (§ 200.205)
The change: Research awards should favor rigor, reproducibility, benchmarks, useful long-term work, and less reliance on institutional prestige. Applicants would also commit to applicable administration policies and guidance for “Gold Standard Science.”
The impact: Many of the present principles (transparency, sound statistics, disclosure of uncertainty, reproducibility, and unbiased review) are conventional scientific safeguards. The governance question is how an evolving executive-branch policy will be interpreted now and by later administrations.
Covered foreign collaborations (§ 200.220)
The change: Federal award money generally could not support collaboration with legally designated adversary countries or covered entities unless a statute authorizes it or the agency grants an exception based on national security and the US. national interest. Work financed entirely with nonfederal money would not be prohibited by this section.
The impact: This research-security measure doesn’t ban all foreign collaboration or all work with individual foreign scientists; however, its practical effect will depend on changing designation lists and whether legitimate exceptions are clear and timely.
The biggest change is who gets the final checkpoint
Under existing legislation, the NIH and NSF already do more than mechanically follow peer-review scores. The NIH considers scientific merit alongside mission, portfolio needs, strategic priorities, workforce sustainability, geographic balance, and available funds. The NSF combines outside expert review with programmatic judgment, including portfolio balance and the potential for high-risk, transformative work.
Agency officials already make funding decisions; the proposal would instead create a government-wide requirement for senior-appointee-level pre-issuance oversight, expressly identify peer-review recommendations as advisory, and make presidential priorities part of the review where applicable.
Reasonable people can support more democratic accountability over federal spending… and also ask whether decisions about individual studies should turn on a political appointee’s independent judgment after expert review (and what standards should constrain that judgment).
Scientific work is vulnerable to midstream changes
Biological samples degrade, clinical cohorts scatter, specialized staff take other jobs, research animals age, and long-term datasets develop gaps that no later appropriation can fully repair because continuity is lost.
The proposal’s termination language is important because the relevant priorities and national interest are assessed “at the time of termination”; thus, changing executive priorities are relevant during the life of a grant.
Republican Senator Susan Collins of Maine, chair of the Senate Appropriations Committee, has asked OMB to withdraw portions of the proposal and extend the comment period, saying she agrees with the transparency, accountability, and oversight goals but believes the proposed termination authority could create uncertainty and financial loss, including in multi-year clinical trials. She also warns that new administrative requirements could burden small and rural communities and that presidential-priority review could conflict with Congress’s funding decisions.
Notably, her objection highlights that concern about this proposal is not inherently Democratic, anti-Trump, or anti-accountability.
The question to ask if you support the rule
Presidents are elected to direct the executive branch, and taxpayers are entitled to know where grant money goes. The government should be able to stop fraud, weak performance, unlawful discrimination, ideological add-ons unrelated to a program, unsafe foreign entanglements, and spending that does not advance an authorized public purpose. And scientific prestige should not shield bad methods: reproducibility matters, and smaller, less ‘famous’ institutions shouldn’t automatically lose out to universities with professional grant-writing processes. These arguments appear throughout the proposal and the executive order that preceded it.
Many will find those premises compelling. The 2024 Republican platform emphasized reining in wasteful spending, equal application of law regardless of political affiliation or belief, constitutional freedoms, American strength, and ending the weaponization of government. The administration has also declared that taxpayer resources should not be used to impose a government-preferred narrative on constitutionally protected speech.
But ask yourself this question:
Would you be comfortable handing the same authority to a future president whose priorities you strongly oppose?
This rule is not written only for the officials in office right now. The next administration (and the next) would inherit the same structure. A future progressive administration could define its presidential priorities differently. Its appointees could apply a different conception of the national interest, and it could revise executive-branch science guidance. It could use the same pre-issuance checkpoint to favor its policy agenda and the same termination clause to reassess grants approved under a Republican president (subject, again, to statutes, constitutional limits, and APA review).
The rule wouldn’t let a future president do anything, but it would establish a reusable set of government-wide levers whose substantive direction can change when presidents change.
That should matter to conservatives who distrust concentrated administrative power and everyone who believes a rule should still look good when it’s your political adversary that’s administering it. Canceling a partially completed project after laboratories have hired staff and purchased equipment can result in wasted sunk costs. Requiring additional payment justifications may prevent abuse, but it may also favor large institutions with compliance departments over rural towns, community organizations, and smaller colleges, i.e., those an anti-elite reform is supposed to help. Furthermore, while the proposal’s anti-prestige and reproducibility provisions may strengthen merit, a broad presidential-priority test may weaken it. Both statements can be true at once.
You don’t have to oppose the entire rule to submit a valuable comment
A useful comment can support OMB’s goals while asking for narrower language, stronger safeguards, clearer definitions, or a different implementation process. You can:
Oppose one provision and endorse another
Explain an unintended consequence OMB may not have considered
Ask the agency to retain the reproducibility requirements while revising termination standards
Support political accountability while requesting written reasons and a meaningful appeal process
Support research-security restrictions while asking for predictable exceptions
The most useful comments do four things:
Name the provision. Place the relevant regulatory section in brackets at the beginning—for example, [200.205], [200.340], [200.461], or [200.220]
Explain the concrete effect. Describe what would happen to a patient cohort, a rural grant office, a small business, a laboratory, a journal budget, a field season, or a taxpayer-funded project
Show your reasoning. Supply data if you have it (it’s not only technical evidence that counts! A clear operational example from lived experience can reveal a cost or conflict that abstract regulatory language misses)
Offer a fix. Propose narrower wording, a definition, notice and appeal rights, transition rules, a deadline for agency decisions, or an exception standard
A short, original comment can be valuable. For example:
[200.340] I support allowing agencies to stop grants involving fraud, nonperformance, or clear legal violations. However, I am concerned that termination based on priorities or the national interest “as they exist at the time of termination” gives recipients too little ability to plan multi-year work. In my experience, a 90-day interruption would result in the loss of [samples, a field season, trained staff, patient follow-up, or other concrete consequences]. OMB should define the standard, require a written project-specific explanation, provide a meaningful opportunity to respond, and require agencies to consider sunk costs and irreversible scientific losses before termination.
Do not include private personal information or confidential business information; submitted comments become part of the public record.
Comment before 11:59 p.m. Eastern tonight
The official docket is OMB-2026-0034-0001. Use the official Regulations.gov comments page and submit before 11:59 p.m. EDT on July 13, 2026.
For help with crafrting your comment, download Elizabeth Ginexi’s excellent ‘cheat sheet’ for writing an impactful comment.
You don’t need to have a PhD or be a scientist; you don’t have to be a Democrat. You need a relevant concern, a concrete explanation, and, ideally, a proposed solution.
If you care about scientific merit, taxpayer accountability, rural access, executive power, research security, free inquiry, or just the principle that the government must explain what it is doing, today is the day to put that concern into the record.
Sources:
https://www.appropriations.senate.gov/news/majority/sen-collins-asks-omb-to-withdraw-parts-of-grant-rule-extend-comment-period
https://www.federalregister.gov/documents/2026/05/29/2026-10817/regulation-for-federal-financial-assistance
https://www.acus.gov/sites/default/files/documents/40_Responding%20to%20Rulemaking%20Comments.pdf
https://www.acus.gov/document/statement-19-issue-exhaustion-pre-enforcement-judicial-review-administrative-rulemaking
https://www.federalregister.gov/documents/2025/05/29/2025-09802/restoring-gold-standard-science
https://grants.nih.gov/grants-process/award/funding-decisions
https://www.nsf.gov/funding/merit-review
https://www.federalregister.gov/documents/2025/08/12/2025-15344/improving-oversight-of-federal-grantmaking
https://prod-static.gop.com/media/RNC2024-Platform.pdf
https://www.whitehouse.gov/presidential-actions/2025/01/restoring-freedom-of-speech-and-ending-federal-censorship/