The Office of Management and Budget (OMB) issued a proposed rule that would overhaul the Uniform Guidance into a set of binding regulations that govern federal financial assistance, including all federal research grants. This page contains background information and recommendations for AAMC-member institutions.
Background
The OMB on May 29, 2026, published a proposed rule to significantly revise the Uniform Guidance, a set of regulations that govern federal financial assistance awards and sponsored research programs, including all federal research grants. The proposal represents a significant update to 2 CFR Part 200 (2026) and other key provisions that serve as the primary regulatory framework for federal awards and other forms of assistance distributed to research universities, nonprofits, and other recipients.
The AAMC has expressed concern about the impact of these proposed regulations on the academic medicine community and on federally funded research.
Key Proposed Revisions
The AAMC is focused on those proposed revisions that would fundamentally change how grants are awarded and managed and will share its letter in advance of the July 13 deadline. The letter will be posted here when available and emailed directly to relevant AAMC affinity groups. While the association will not lead in a sign-on letter, we encourage institutions to submit their own comments. The volume and specificity of comments is important as it provides substantive feedback to the OMB as it considers changes to the proposal prior to issuing a final rule.
Institutions may want to consider addressing the following provisions in comment letters, in addition to any others:
- Change in regulatory structure.
- Pre-issuance review of grant decisions that could allow political considerations to override scientific recommendations(2 CFR § 200.202, §§ 200.204 - 206).
- Broad discretion to terminate grants based on considerations unrelated to the scientific progress of the research with limited opportunity to appeal (§ 200.340).
- Restrictions that could impact global collaborations (§ 200.202, § 200.220).
- Disallowing costs that facilitate professional development and dissemination of research results, such as conferences, memberships and subscriptions, and publication costs (§ 200.432, § 200.454, § 200.461).
- Assessing the risk posed by researchers (§ 200.206).
- Limitations on the use of funds for specific policy issues (§ 200.300).
- Prohibitions on using federal awards to “promote or support theories of disparate-impact liability” (§ 200.218).
- Elimination of fixed amount awards (§ 200.333).
Guidance on Submitting Comments
Comments are due July 13, and the OMB has indicated that it intends to finalize the rule for an effective date of Oct. 1. The AAMC encourages institutions to submit comments to the OMB on the proposed rule and notes the following key guidelines from the office:
Comments on this proposal must be submitted electronically before the comment closing date to regulations.gov. In submitting comments, please search for recent submissions by the OMB to find docket OMB-2026-0034, which includes the full text of the proposed revisions and submit comments there.
Please provide clarity as to the section of the regulation that each comment is referencing by beginning each comment with the relevant section number in brackets. For example; if the comment is on § 200.414, include the following before the comment: [200.414].
Public comments received by the OMB and federal agencies will be posted at regulations.gov as a matter of public record. Accordingly, please do not include any confidential business information or personal privacy information in your comments.
In consideration of this legislative and report language (on indirect costs), the OMB is not proposing updates to the indirect cost rate negotiation system through this proposed rule. The office may consider issuing a request for information on this topic in the future, but commenters should not submit comments on the indirect cost rate negotiation system in response to this proposed rule. As no changes are proposed on that topic, the OMB does not intend to consider or respond to any such comments in the final rule.
The AAMC additionally recommends the following:
- Include an introductory paragraph describing your institution’s experience with receiving and managing federal awards (e.g., volume, length of time) and the importance of the principle of responsible stewardship of federal funds that the community shares.
- You do not need to reply to every provision in the rule. Select those that would have the greatest impact on your institution.
- Create a compelling argument by connecting practical, identifiable impacts of the rule with the stated goals of the rule and administration.
- Data to support your arguments on why a particular change will be harmful, or not be effective in accomplishing the stated goal, is one of the most important tools that an individual institution has to strengthen its letter. Provide specific examples and numbers wherever you are able.
- Your comment has multiple audiences — not only the OMB, but also your congressional delegation, future administrations, and your faculty, staff, and students. This is an opportunity to highlight the principles and provisions that matter the most to your institution.
For further information on the rulemaking process and logistics of commenting, please refer to the regulations.gov FAQ page.