The comment period closes on July 13 – share your thoughts and submit your comments today.
White House Office of Management and Budget (OMB) a Proposed rule which significantly changes the administration of federal research grants. The proposal revises 56 sections of 2 CFR (Uniform Guidance) and adds four new sections. More importantly, the guidance, which was historically advisory, is becoming mandatory regulation, centralizing authority within OMB and limiting the agency’s discretion in administering awards.
The main provisions affecting researchers and institutions are:
- Political review before the award (200.205 (AD)): All discretionary awards require approval by a senior designee before funds are committed. Proposals will be reviewed for compliance with content restrictions, preference will be given to institutions with lower indirect costs and applicants who must demonstrate adherence to the “Golden Sciences” as set out in Executive Order 14303.
- The authority for peer review has been limited (200.205(d)): Peer review recommendations remain advisory and cannot be routinely deferred or treated as binding, which undermines the traditional merit-based review process.
- Right to extend termination (200.340): Agencies may terminate awards at any time if they determine that the grant no longer advances program goals, agency priorities, or the national interest.
- Restrictions on international research (200.220; 200.202(e)): Federal funds cannot support cooperation with foreign countries or institutions. Awards to foreign organizations must require legal authorization or a high-level designation from an enforcement agency and national interests.
- Publication costs are prohibited (200.461): Publication costs are generally non-refundable, except as specifically authorized or required by law.
- Conference and journal expenses are limited (200.432; 200.454(b)): Conference attendance requires express permission of award and journal subscriptions are not considered direct or indirect costs.
- Multi-year awards are encouraged (200.202(f)): Agencies are encouraged to make single-year rather than multi-year awards.
- A research classification is required (200.202(d)): Research awards are categorized as basic research, applied research or experimental development, as appropriate OMB Circles A-11.
The American Society for Nutrition (ASN) is preparing a response to the proposed rule. We encourage ASN members to share any contributions with them Sarah OlhorstMS, RD, ASN’s Chief Science Policy Officer, for helping shape ASN’s response.
ASN also encourages all members to submit individual comments. Responses must refer to the relevant section number (eg (200.461)) and must be sent via regulations.gov from July 13, 2026, (Document ID: OMB-2026-0034). OMB stated that comments on indirect cost negotiations are outside the scope of the proposal and will not be addressed. Because similar proposals may be viewed as a single comment, ASN encourages members to describe the specific personal and institutional impacts of these changes on their research. A A sub-message by Elizabeth Ginexi, PhD, provides step-by-step instructions for submitting comments.
In addition, ASN members are encouraged to contact their members of Congress directly to describe the specific personal and institutional impacts that proposed changes in OMB’s proposed rule would have on your research. Please get in touch Sarah OlhorstMS, RD, ASN’s Chief Science Policy Officer, for assistance in Congressional communications.
