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.
See the AAMC’s letter to OMB as submitted and the executive summary of the letter.
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.
The AAMC has concerns with some specific provisions that institutions may want to consider addressing in their comment letters, in addition to any others:
- Change in regulatory structure. The transformation of the Uniform Guidance to Uniform Grant Regulations would curtail necessary agency discretion in the awarding and management of grants. The balance of harmonization and agency discretion can be modulated through periodic revisions to the guidance as needed to address specific concerns without entirely shifting to a system in which all agencies are expected to function exactly the same way, no matter their stated mission.
- "Pre-issuance review of grant decisions" that could allow political considerations to override scientific recommendations (2 CFR § 200.202, §§ 200.204 - 206). The current provision §200.205 provides sufficient direction to Federal agencies to establish an effective, merit-based system through which to evaluate scientific proposals. In the proposal, the merit review process would include a new requirement that is wholly separate from the scientific review and recommendations. In it, a senior political appointee would need to apply seven principles to make determinations about whether grants should be funded, including ensuring that grants “demonstrably advance the President’s policy priorities,” that federal funds are not used advance specific concerns of the current administration, reward institutions that have lower indirect cost rates, award grants through an assessment of the likely timing of results of the research, and award grants to institutions who demonstrate commitment to “Gold Standard Science,” an undefined and unmeasurable concept. Taken together, these principles could drive an unpredictable and politically-motivated set of federal research awards. We ask that the OMB retain § 200.205 as it reads in the Uniform Guidance and eliminate the pre-issuance review. We address specific concerns with implementation of each of the seven principles.
- Broad discretion to terminate grants based on considerations unrelated to the scientific progress of the research with limited opportunity to appeal (§ 200.340). As was demonstrated through the sudden termination of thousands of research grants in early 2025, the abrupt termination of grants can halt active clinical trials, set back scientific progress for years, and disrupt research programs and career trajectories. We recommend that OMB retain termination as a remedy only for circumstances related to failure of the research to progress, to avoid harm to human participants, of for material failure to comply with the terms of the award. We urge to OMB to include a requirement for a written explanation of any termination, the right for administrative appeal of all terminations, and assurances that participants will be protected in the event of the termination of human subjects research.
- Restrictions that could impact global collaborations (§ 200.202, § 200.220). Broad prohibitions on certain foreign collaboration risk undermining essential international collaborations designed to address global disease threats. We ask that these prohibitions and restrictions be removed or significantly narrowed, especially when existing statutes and regulations already govern international collaborations and data security.
- 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). These opportunities for dissemination of research results are often unavailable to those without support from federal funding.
- Prohibitions on using federal awards to “promote or support theories of disparate-impact liability” (§ 200.218). The complex and concerning language of this provision could have a chilling effect on all health equity and health disparities research, leaving federal agencies unsure of what can be funded and researchers reluctant to propose research that might be seen as being prohibited by this proposed provision. We ask that OMB remove this provision because it is likely to lead to inconsistent interpretation across agencies and grants, an overbroad implementation that could halt the funding of all health disparities research, and a chilling effect on applications from researchers who assume that the provision is intended to prohibit all health equity and health disparities research.
- Assessing the risk posed by researchers (§ 200.206). The proposed rule expands the items that Federal agencies already consider in assessing the risk factors agencies should consider when evaluating applicants, proposing to add four items for evaluation, including financial capacity for managing grants that are larger than those typically awarded to the applicant, a "history of questionable practices" including plagiarism, and “discredited or non-replicable studies published by the applicant or its staff.” The proposed provision also includes assessment posed by the risk of an applicant's "membership in or affiliation with organizations engaged in activities that violate Federal law, undermine public safety or national security, or advocate for the overthrow of the United States Government," a provision that raises concerns about inconsistent application of undefined terms that require agencies to determine the nature of various organizations and an applicant's affiliation with the organization. We ask that all four newly proposed sections be removed or substantially narrowed.
- Effective date and speed of implementation. We express concern with the speed with which the sweeping set of changes is being enacted and with agency activity that indicates the OMB is expecting the rule to be implemented with few or no changes from the proposed rule. We ask again that the proposed rule be rescinded and urge that if a revised final rule is issued, the implementation timeframe be no less than 12 months from the final rule’s publication.
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.