By Kritika Agarwal
Last month, the White House Office of Management and Budget published a proposal that would make significant changes to how federal agencies administer financial assistance, including research grants. If allowed to go into effect, the changes would seriously harm the American scientific research enterprise.
OMB’s Uniform Guidance (2 CFR Part 200) establishes the standardized, government-wide framework of administrative requirements, cost principles, and audit standards for federal awards to universities, states and localities, and other nonprofit organizations. It directly governs how universities and other nonprofit research organizations manage federal research grants – setting rules for allowable costs, indirect cost (F&A) rates, financial reporting, procurement, and compliance for funding from agencies such as the National Science Foundation, the National Institutes of Health, NASA, and the Departments of Energy, Agriculture, and Defense.
OMB’s recent proposal would fundamentally reshape this framework in ways that are both far-reaching and deeply concerning. It would elevate the Uniform Guidance, effectively transforming it from “guidance” to “regulation.” Once finalized, the regulations would apply to all government agencies and carry the force of law. Because of this, the proposal represents a significant expansion of the executive branch’s authority.
The revisions would greatly increase regulatory red tape for scientists and institutions that conduct research on behalf of the federal government. They would also require research institutions to bear more of the costs associated with doing research intended to benefit the American public and would expose researchers to the risk of having their grants revoked midway through with no explanation or opportunity for appeal. It is also important to note that federal grant awards made to states, localities, and other nonprofit organizations to improve public services such as education, public health services, roads and bridges, and to assist local farmers will be subject to the proposed rules.
In total, OMB is proposing more than 320 changes to the existing Uniform Guidance. A recent brief prepared by AAU, the Association of Public and Land-grant Universities, and COGR highlights five key issues in OMB’s proposed revisions that stand out as the most concerning for research institutions. The associations are advising their members and all research institutions to review OMB’s proposal and to submit comprehensive comments by the OMB’s comment deadline of July 13, 2026. (As of Friday, June 12, OMB has received nearly 16,000 comments from the public in response to its proposal.)
Here are the five key issues the associations are highlighting relating to how these changes would impact scientific research:
Politics could play a bigger role in who gets grants: OMB’s proposal would push federal agencies to weigh the policy priorities of whichever administration is in office more heavily when making decisions regarding which research projects to fund.
It would require politically appointed officials to make grant funding decisions and require agencies to scrutinize proposals using vague new criteria such as whether they adhere to “Gold Standard Science” or promote “anti-American values.” Researchers would also be scrutinized for their activities outside labs, including memberships or affiliations with certain organizations.In practice, this would mean that decisions about which projects get funded could hinge more on shifting political priorities and less on traditional peer review and scientific merit.
Agencies could cancel awards midway: The proposal would significantly expand agencies’ power to suspend or terminate grants midway, even if the science is on track and the projects are moving forward as expected.
Agencies could end awards based on changing goals or shifting administration priorities. They could also terminate entire classes of awards – not just individual grants. Researchers would not be able to appeal agencies’ decisions to terminate awards midway.Not only would this result in a colossal waste of taxpayer money (imagine all the lost work, lost science, and lost personnel hours if a clinical trial is canceled midway because the government no longer agrees with its focus or findings), but it would also create immense uncertainties for any researcher embarking on multi-year projects.
Researchers would not be able to charge necessary research costs to grants: OMB’s proposal classifies several routine research costs as unallowable, including most costs associated with publishing the results of federally funded research. Subscriptions to professional, academic, and technical journals that are necessary for researchers to conduct their work would become unallowable across the board; conference travel would only be allowable when expressly approved by the agency; and professional membership fees would only be covered if they are strictly necessary to meet award requirements.
And, while the proposal would not directly cap negotiated indirect cost rates, it tells agencies to favor grant applicants from universities with lower indirect cost rates when all other factors are equal. Indirect costs are the shared behind-the-scenes expenses that make research possible; OMB’s changes would have direct implications for the building and maintenance of institutional research infrastructure. The changes would also mean that, rather than funding the best scientific proposals, federal agencies would consider which institutions can conduct scientific research at the lowest cost. This would result in the funding of the cheapest science as opposed to the best science.
Researchers would face broad new limits on international collaboration: Instead of targeting clearly defined, verified risks involved in specific international collaborations, OMB’s proposal would create broad constraints on international research partnerships, co-publication of scientific research with international partners, and greatly chill the willingness of U.S. researchers to collaborate with leading scientists overseas.
For example, OMB’s proposal would expand the “Wolf Amendment” (which currently prohibits NASA from using government funds to partner with Chinese entities) to university researchers receiving federal research funds from all federal agencies, greatly hampering their ability and willingness to collaborate and co-author papers with top scientists in other nations outside the United States. The proposal would also add more paperwork for institutions that work with international organizations or researchers (also known as foreign subrecipients) who receive portions of a federal award to carry out part of a research project.
- Researchers would no longer receive fixed-amount awards or subawards: A fixed-amount award is one where researchers receive payments based upon their achievement of pre-negotiated milestones. OMB’s proposal would largely eliminate fixed-amount awards in favor of cost-reimbursement arrangements where researchers would have to submit detailed documentation of their expenses to get reimbursed for research costs. This would greatly increase the amount of university staff time spent on paperwork and would increase administrative costs across the board.
As AAU President Barbara R. Snyder wrote in a recent letter to OMB, “Taken together, the changes in the guidance have the potential to reshape the framework within which universities, federal agencies, and other stakeholders conduct and support America’s scientific research.”
OMB’s proposal completely resets the basic terms under which universities, hospitals, and research institutions partner with the federal government to advance science, train students, and serve the public. If it goes forward as written, OMB’s proposal would slow scientific discovery in the United States and ensure that we continue falling behind in the global race for scientific and technological leadership.
Kritika Agarwal is assistant vice president for communications at AAU.