On May 29th 2026 a rule was proposed by the Office of Management and Budget called “Regulation for Federal Financial Assistance.” It’s a 400-page rule outlining changes to the Code of Federal Regulations (CFR), which provides the rules that govern how departments and agencies of the Federal Government operate, including outlining all federal grantmaking regulations. These changes would negatively impact federal grant funding to universities, non-profits, and industries. In addition to codifying many of the concerning changes that have already occurred at the NIH, this rule would permanently, substantially, and legally alter the federal grant making process for federal funding as we know it. This goes beyond science, and will impact all facets and areas of our lives as this impacts FEMA funding, programs like Head Start, and others.
In January 2025, NIH began terminating grants mid-award due to misalignment with “agency priorities”, cancelling funding announcements and awards by political will.
In August 2025, The President of the United States issued an executive order that would give political oversight to federal grantmaking.
In September 2025, NIH announced that grants submitted with a foreign subaward would no longer be accepted.
In November 2025, NIH started issuing all awards with a term and condition of award which allowed the grant to be terminated at will, making award termination legal.
The proposed rule changes would codify all of these activities into law.
OMB must read every comment and respond to every “significant” comment in writing before the rule finalizes. Leaving a comment will build a record for the courts when there are legal challenges to the implementation. It also shows courts and legislators the scope and degree of public dissatisfaction with the rule.
ANYONE! Researchers, advocates, members of the public, anyone can comment and anyone can leave multiple comments. Organizations can also leave comments.
You comment can be structured as so:
Who you are
Which provision (or provisions) you’re opposing
What the harm is to you
That you request the provision is not finalized
Comments should be personal (no template or copying someone else’s comment, in which case the comment will be ignored).
It helps if you can name a specific provision and how it will directly impact your research, your condition, your life, or the future of your country.
There is a 5,000 character limit, but there is an option to upload a longer document.
§200.205, Federal Agency Review of Merit of Proposals: Political appointees override peer review
§200.340, Termination and Suspension: Grants terminated for political reasons
§200.202, Program Planning and Design: Programs must align with White House priorities
§200.220, Prohibition of Using Federal Funds for Covered Foreign Collaborations: International collaboration prohibited
§200.432, Conferences: Conference attendance requires pre-approval
§200.454, Memberships, Subscriptions, and Professional Activity Costs: Journal subscriptions categorically banned
§200.461, Publication and Printing Costs: Publication costs banned
§200.450, Lobbying: Public communications restricted
Directly on the Federal Register’s website: https://www.federalregister.gov/documents/2026/05/29/2026-10817/regulation-for-federal-financial-assistance#open-comment
Call your representatives. They can take action against this through a joint resolution that can be added to appropriations bills or stand alone. However; a joint resolution would need to pass both houses.
Contact your professional societies if they have not yet commented publicly and ask them to encourage their members to comment.
Participate in a joint comment with a university if you don’t want to comment alone, although we recommend individual comments as the number of comments is incredibly important.
Comment anonymously! If you are afraid of retaliation, you can comment anonymously.
Check out Elizabeth Ginexi’s Substack for more resources and a breakdown of the rule.
Look out for upcoming webinars and events to help you finalize your comment such as comment Q&As, town halls, or workshops by other similar organizations.
Contact us with questions concerns or thoughts at info@27unihted.org
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