The comment period closes July 13—share your feedback and submit your comments today.
The White House Office of Management and Budget (OMB) has released a Proposed Rule that would significantly reshape the administration of federal research grants. The proposal revises 56 sections of 2 CFR (Uniform Guidance) and adds four new sections. Most notably, guidance that has historically been advisory would become binding regulation, centralizing authority within OMB and limiting agency discretion in administering awards.
Key provisions with implications for researchers and institutions include:
- Pre-award political review [200.205(b-c)]: All discretionary awards would require approval by a senior agency appointee before funds are obligated. Proposals would be reviewed for compliance with content restrictions, preference given to institutions with lower indirect cost rates, and applicants required to demonstrate adherence to “Gold Standard Science” as defined in Executive Order 14303.
- Peer review authority curtailed [200.205(d)]: Peer review recommendations would remain advisory and could not be routinely deferred to or treated as effectively binding, weakening the traditional merit-based review process.
- Expanded termination authority [200.340]: Agencies could terminate awards at any time if they determine a grant no longer advances program goals, agency priorities, or the national interest.
- Restrictions on international research [200.220; 200.202(e)]: Federal funds could not support collaborations with covered foreign countries or entities. Awards to foreign entities would require statutory authorization or a senior appointee determination of compelling agency and national interest.
- Publication costs prohibited [200.461]: Publication expenses would generally be unallowable except when specifically authorized or required by statute.
- Conference and journal costs restricted [200.432; 200.454(b)]: Conference participation would require explicit award authorization, and journal subscriptions would be unallowable as either direct or indirect costs.
- Multi-year awards encouraged [200.202(f)]: Agencies are encouraged to issue multi-year rather than single-year awards.
- Research classification required [200.202(g)]: Research awards would be categorized as basic research, applied research, or experimental development, consistent with OMB Circular A-11.
The American Society for Nutrition (ASN) is preparing a response to the proposed rule. We encourage ASN members to share any input with Sarah Ohlhorst, MS, RD, ASN’s Chief Science Policy Officer, to help shape ASN’s response.
ASN also encourages all members to submit their own individualized comments. Responses should reference the relevant section number (e.g., [200.461]) and must be submitted through regulations.gov by July 13, 2026, (Docket ID: OMB-2026-0034). OMB has indicated that comments on indirect cost rate negotiations are outside the scope of the proposal and will not be considered. Because identical submissions may be treated as a single comment, ASN encourages members to describe the specific personal and institutional impacts these changes will have on their research. A Substack post by Elizabeth Ginexi, PhD, provides step-by-step instructions for submitting comments.
Additionally, ASN members are encouraged to reach out directly to their members of Congress to describe the specific personal and institutional impacts the proposed changes in the OMB proposed rule will have on your research. Please contact Sarah Ohlhorst, MS, RD, ASN’s Chief Science Policy Officer, for assistance with reaching out to Congress.
