The Office of Management and Budget (OMB) has proposed significant changes to Uniform Guidance and related federal financial assistance regulations, with the target implementation date of October 1, 2026. If finalized, the changes would apply government-wide to federal financial assistance, including grants and cooperative agreements, and would affect recipients and subrecipients across sectors, including colleges and universities, nonprofits, state and local governments, small businesses, companies, and other entities that receive, administer, or participate in federal assistance awards. The reaction from affected communities has been swift and forceful, garnering national media attention and sounding the alarm that federal grantmaking, and especially the federally-sponsored research enterprise, would be significantly harmed by these changes.
Research administrators should act now to (1) understand the OMB proposed changes and their organization’s risk exposure if the proposed changes are enacted and (2) submit public comments to OMB in their individual capacity and, if possible, through their organization which identify and explain their concerns with specific proposed changes. The comment period is open now, with comments due by July 13, 2026. Read the Federal Register notice of proposed changes and submit public comments here.
Overview of proposed changes
Several of the most important proposed changes would reshape the relationship among federal agencies, award recipients, and subrecipients. Recent analyses of the proposed changes have flagged issues including expanded agency discretion to terminate or suspend awards, greater emphasis on alignment with administration priorities, changes to proposal review processes that would emphasize alignment with Administration priorities and deprioritize expert merit review, and new conditions and limitations affecting foreign collaborations. Notably, OMB chose not to pursue changes to indirect cost rate negotiation in this rulemaking.
Some of the proposed policies are already being implemented through President Trump's executive orders, agency guidance, revised award terms, and internal agency review processes. Many grantees are already experiencing aspects of this shift through delayed awards, additional review layers, revised NOFO language, termination threats, certification requirements, and agency-specific implementation guidance.
Submit comments to OMB by July 13
Participating in this comment period really matters: it is an opportunity to challenge, narrow, clarify, or document the consequences of policy changes before they are embedded more firmly across federal financial assistance. The most important thing is to submit a public comment so that the public record reflects the breadth and depth of concern about the proposed changes. The second most important thing is to submit a ‘substantive’ public comment. A substantive comment is one that articulates how and why a specific proposed provision would cause a specific harm. The goal is to create a public record that identifies legal, operational, administrative, and policy concerns.
Research administrators are well-positioned to submit substantive public comments because they have essential operational knowledge about the anticipated impact of implementing the proposed rule changes. A substantive comment does not need to be long or complicated or in a particular format. It should be specific, grounded, and as unique as possible. The most effective comments identify the provision being addressed, explain how the change would affect real institutional processes, and describe the likely consequences for award administration, faculty communication, student support, compliance, budgeting, subrecipient monitoring, project continuity, and/or institutional risk. General statements of concern are fine, but comments that explain how a proposed rule would work in practice are more likely to help OMB understand the consequences of their proposal. A step-by-step guide for developing and submitting a substantive public comment for this OMB proposed rule is available here.
Since some of the proposed changes to Uniform Guidance are already being implemented, is it worth the effort to develop and submit a substantive public comment? …YES!
While the policies in question may reflect policies that are already in effect, there are a few differences between the current patchwork of Trump Administration executive orders/agency policies and the proposed OMB rulemaking.
- Executive orders and agency guidance can be created, revised, or rescinded relatively easily so they often remain tied to the priorities and timeframe of the presidential administration that issued them. Agencies often have some implementation discretion as well. In contrast, OMB rulemaking is a more laborious and time-intensive process designed to create a more stable framework of government-wide regulations that are consistently applied across federal agencies. The resulting framework is in effect for years, until it is revised through a subsequent rulemaking.
- OMB is required to consider and respond to substantive public comments before issuing a final rule. Therefore, it is especially important for affected organizations and individuals to submit substantive comments to ensure OMB goes on the record addressing the public’s concerns. In contrast, the president and agency leadership are generally not required to engage the public before issuing an executive order or agency policy change so there is no formal avenue for affected communities to register concerns.
- The legal frameworks for challenging a formal rulemaking and an executive order are different. Having a robust record of public comments and OMB responses as part of the rulemaking process is important for future legal challenges to the final rule.
What happens next?
OMB. After the public comment window closes on July 13, OMB must consider and respond to substantive comments before issuing a final rule. OMB may group similar comments together and issue a single response to a category of concerns. OMB is not required to make changes to the proposed rule, even if many commenters raise the same issue. Once OMB has issued its response to substantive public comments, it can proceed to issuing a final rule. OMB’s goal is to issue a final rule by October 1, 2026 to ensure the new requirements apply to all federal awards made in Fiscal Year 2027.
Congress. An option on the table is incorporating language into the FY2027 appropriations legislation which would limit some of the provisions proposed by OMB. That strategy was successful in FY2026 for halting Administration attempts to constrain indirect cost rates, and OMB cites this legislation as a reason for why they are not modifying indirect cost rate negotiation in this proposed rulemaking. However, as discussed in the What We’re Watching section, it is unlikely that FY2027 appropriations legislation will pass into law before October 1, 2026.
Stakeholder Organizations. If the proposed rule is finalized largely as written, legal challenges are expected. To date, much of the litigation challenging the Trump Administration’s actions harming the research enterprise has been led by higher education institutions, scholarly associations, and related organizations. Because the Uniform Guidance applies across federal financial assistance, the potential plaintiff base is much broader, which may matter legally, politically, and strategically as the grants community responds.
Research Administrators. Submit a public comment, preferably a substantive public comment. Work with colleagues at your organization to begin scenario-planning for implementation in the likely case that the final rule substantially resembles the proposal.
Research administrators are not bystanders in this process. The proposed rule is about the structure, conditions, oversight, and termination of federal awards. Those issues live every day in sponsored programs offices, compliance offices, finance offices, academic departments, and research leadership teams. The comment period is the moment to make that operational reality visible.
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