By Rob Marus
AAU has submitted comments to the Office of Management and Budget (OMB), urging it to rescind or seriously modify a set of changes the agency has proposed that would affect the entire system for federal grants and other federal financial assistance. The letter argues that OMB’s proposed rewrite of the Regulation for Federal Financial Assistance (commonly known as the “Uniform Guidance”) would upend the longstanding federal-university research partnership by prioritizing political considerations over scientific merit; removing assurances of federal commitments and creating unsteady, volatile sources of funding; and imposing unworkable compliance burdens that ultimately weaken America’s scientific research enterprise – and the innovation, economic growth, and national security that stem from American science.
Overarching Concerns
AAU’s comments note that America’s world-leading research enterprise requires a stable, merit‑based, rational funding framework – but that the proposed rule would seriously compromise this model.
Many of the proposed changes go far beyond grants management into ideological regulation of science, exceed OMB’s authority, conflict with congressionally mandated statutory language, and provide broad discretion for political appointees to terminate grant funding prematurely — based solely on political motivations and with no appeals process. This would put the health, security, and economic benefits the public receives from university research at serious risk, the comments argue.
Rushed Process, Legal Overreach
The letter expresses concern that OMB’s 45‑day comment period and implementation window of less than three months provide insufficient time for adequate review and execution of a government‑wide rule that touches almost every aspect of grants administration.
It argues that OMB is improperly converting previously nonbinding guidance into binding regulation, stripping away agency‑level rulemaking and public input, and relying for its legal authority on executive orders that are currently involved in litigation without identifying any separate statutory authority.
AAU also warns that several of the changes conflict directly with existing laws or regulations – including programs in which Congress has ordered agencies to fund particular kinds of research or expand participation of underrepresented groups, creating irreconcilable legal obligations for universities and agencies without offering any clear way for them to comply legally. For example, Congress recognized the importance of studying differential outcomes among demographic groups in the NIH Revitalization Act of 1993. But under the proposed rule, research examining sex-based differences in cardiovascular disease or demonstrating racial disparities in chronic kidney disease would be prohibited.
Politicizing Research Decisions Will Destabilize U.S. Science
Among AAU’s most serious concerns, the comments note, is that the rule would shift funding decisions for research grants away from the existing system of relying on impartial panels of experts evaluating each application’s scientific merit toward a more politicized system.
This would include new pre‑issuance reviews by political appointees in the granting agencies. AAU’s letter argues that the changes would impose vague new standards like “national interest,” “anti‑American values,” and “Gold Standard Science” onto grant determinations.
Combined with OMB’s proposed expanded ability for political appointees to terminate grants mid-stream and without appeal, this would allow awards to be halted or canceled for political reasons, undermining long‑term projects, human‑subjects research, and the training pipeline for graduate students and postdocs. Financial uncertainties are already impacting our future STEM talent, with new data showing that U.S. universities accepted 15% fewer applicants to doctoral programs for fall 2026 compared to fall 2025. This uncertainty will grow worse if OMB’s proposal goes into effect.
This would also create fiscal uncertainty, threatening grantees’ credit ratings and thus driving up borrowing costs.
“Under this process, individual grant awards would be subject to review by politically appointed officials to assess whether proposals are ideologically consistent with the ‘President's policy priorities,’” the comments note. “This would slow funding decisions, inject uncertainty into the research pipeline, and weaken the merit-based system that has long been a cornerstone of U.S. innovation.”
Increasing involvement by political appointees in grant decisions has already had negative impacts for federal science funding. Earlier this year, AAU Universities raised the alarm over how slowly the nation’s federal science agencies are spending congressionally approved research dollars. As AAU recently reported (based on data from the nonprofit group Grant Witness), the National Science Foundation is currently on track to issue the fewest grant awards in more than 50 years.
Unclear Grant Requirements Could Undermine Research and Compliance
Similarly, the comments contend that OMB is injecting ill-considered and ill-defined terminology into the grantmaking and review process, imposing bans on research related to what the administration labels as “DEI” and “gender ideology.”
These terms, AAU says, are opaque, legally unstable, and impossible to reconcile with existing legal requirements regarding civil rights and human‑subjects research that universities must follow. These provisions would chill or prohibit lawful and often mandated research on health disparities, gender dysphoria, and similar topics while exposing institutions to termination risk based on unclear and legally shifting definitions.
Likewise, AAU says, a provision that would ban grant recipients from engaging in what the administration terms “issue advocacy” is dangerously vague in a research context, because it would effectively penalize scientists for communicating policy‑relevant research findings to Congress or the public – and it conflicts with existing statutes and regulations requiring agencies and advisory bodies to share scientific knowledge to inform public decisions.
Onerous New Administrative Burdens and Limitations on International Collaboration Would Impede American Science
The comments also cite problems with the proposal’s numerous operational changes that would increase administrative burdens and compliance costs while doing little to achieve OMB’s stated objective of reducing burdens and increasing transparency, accountability, and oversight of federal grants.
These problems include requiring new written justifications for each disbursement from an award, creating unnecessary additional paperwork for integrated institutions like hospitals, and eliminating fixed‑amount awards. AAU’s comments also warn that broad, poorly defined restrictions on international collaborations and foreign entities would duplicate existing research‑security requirements, disrupt legitimate global partnerships, and make U.S. universities less attractive to top talent at a time of intense global competition.
Many organizations and individuals in the research community as well as other organizations have spoken out forcefully against the changes – including some of the country’s most prominent researchers themselves. Federal Register data show that nearly 300,000 comments had already been submitted on the proposed rule before the July 13 comment deadline, with additional last-day submissions likely still being processed.
AAU President Barbara R. Snyder, in a cover letter to OMB Director Russell Vought accompanying the comments, said: “Together, these changes risk undermining the predictability, stability, impartiality, and collaboration upon which America’s entire research-and-innovation system depends. At a time of increasing global competition in science and technology, policies that reduce certainty and impede collaboration threaten the nation's capacity for discovery, economic competitiveness, and national security.”
Rob Marus is deputy vice president for communications at AAU.