A quick note from me up front: Today’s post is about a proposed change to U.S. Office of Management and Budget (OMB) and regulations. This might sound dry, or boring, or irrelevant to you if you’re not a legislator or a policy wonk. I promise you, this is not boring and it is extremely serious. It is unheard of and would permanently reshape our entire country’s relationship to science. I am not being alarmist. Please read now, and please take action—including sharing widely and encouraging others to act.
In case you missed it, on May 29, 2026, the U.S. Office of Management and Budget (OMB), which sets financial management policies and requirements for federal funding, released a draft regulation that would, if finalized, leave decisions about ALL discretionary federal grants up to the President’s political appointees—and let them cut your funding anytime. (If you’re not a scientist who receives federal funding, this still affects you. You benefit from federal funds that flow to researchers, public health workers, and medical providers every day, whether you know it or not—and this rule goes far beyond the world of public health and medicine, as I detail below.)
Public comments are due July 13.
Q: So much is going off the rails these days—what can we really do?
A: THIS. If you do one thing, DO THIS.
Called the bland-sounding “Regulation for Federal Financial Assistance Docket (OMB-2026-0034),” the nearly 400-page draft rule is truly breathtaking in scope. It has a lot of parts we’ll get into later but in short, it 1) revises 2 Code of Federal Regulations (CFR) Subtitle A to, among other things, require political loyalty tests for all federal grants and assistance, and 2) revises 2 CFR Subtitle B to codify those rules one by one for each of 41 federal departments. The affected departments touch all aspects of our lives, including what we eat, (Department of Agriculture), how we learn (Department of Education), what care we receive (Health and Human Services, Veterans Administration), where we live (Housing and Urban Development), where we play (Department of Interior), how we work (Department of Labor), what we study (National Science Foundation), and where we save (National Credit Union Association) and spend money (Small Business Administration).
As Dr. Megan Ranney, Dean of Yale School of Public Health put it in an apt LinkedIn post: “I was on a call today where a very staid, non-alarmist person said, ‘this proposed uniform guidance is a five-alarm fire.’” The draft rule has a lot to unpack, but here I highlight three key themes to describe how it would cause so much harm. (If you want more, see this googledoc for a summary of sections by theme [look at the multiple tabs]; see regulations.gov for the full text of the proposed rule.)
Theme 1: Rewarding Subservience, Punishing Dissent
The draft rule would create a system of patronage, where only Administration allies get federal funding. It requires political appointees (read: not career scientists) to pre-review organizations and applications for ALL federal funding (not just research) and to make sure both the organization and the application align with federal priorities (read: political beliefs on everything from race and gender to immigration). Once a federal agency awards funds to an organization, it can delay, reduce, or terminate the funding at any time, without explanation. The federal agency could also bar an organization from receiving future federal funding. These rules would apply not just to grantees but also to their subcontractors. For example, grantees would be required to notify their federal funders if subrecipients do anything that could “damage the reputation” of a federal agency or the federal government. This prohibition alone could have far-reaching chilling effects on free speech.
Theme 2: Making the U.S. Stupider and Less Competitive
The draft rule would undermine learning, knowledge-sharing, and innovation. The draft rule attacks expertise in multiple ways: first, it changes our longstanding system to make peer review of federal funding advisory, and not binding. Without peer review (read: review by other scientists who have similar expertise in the work being proposed for funding), federal agencies could be more likely to fund interventions that are ineffective at best and harmful at worst (like the National Cancer Institute studying ivermectin’s “ability to kill cancer cells,” alarming career scientists). The rule prohibits funds from being used for advertising, conferences (unless approved), international collaboration, subscriptions, publications, or memberships. These prohibitions could negatively affect medical journals and trade publications and prevent U.S. and global innovators from being able to share their ideas, collaborate, and innovate.
The draft rule appears written to specifically undermine universities and nonprofits. It requires federal agencies to fund applicants with a) the lowest indirect cost rates (these indirect costs pay for shared infrastructure, like laboratories and libraries), b) a commitment to “Gold Standard Science” (an Executive Order that has some valid critiques of the COVID-19 pandemic response but selectively scrutinizes Biden-era scientific policies), and c) the ability to yield “immediate [study] results” (good science takes time). To make matters worse, the draft rule undermines civic participation by specifically prohibiting nonprofits and institutions of higher education from using federal funds for voter registration drives. It’s unclear how an uninformed public puts America First, unless the point is to stifle voting and dissent.
Theme 3: Creating Uncertainty and Busy Work
The draft rule would it make it harder for federal grantees to know if they will get paid or how much. It prohibits fixed amount awards and subawards, so grantees can no longer apply for, say, $1 million over five years and expect to receive $200,000/year to pay their staff, rent, and expenses. The draft rule discourages cost reimbursement contracts, requires grantees to generate income and spend all of that income before requesting additional funds (which will almost certainly lead to gaps in funding, endangering the ability to pay and retain employees). It also requires grantees to justify every single payment request in writing. In effect, federal grantees could ask for what they needed in their proposals but, because funds can be delayed or terminated at any time, they will be left uncertain if they will ever get paid what they need to sustain the work.
If that wasn’t enough, the draft rule requires all federal grantees and subrecipients to participate in E-Verify (to check job applicants’ eligibility to work in the U.S.) and to report to their federal funding agency if a job applicant is found to be ineligible—i.e. to directly participate in the effort to identify and deport people applying for jobs who do not have green cards or valid work visas. If the organizations do not report this their funding can be terminated, despite the known risk of false negative matches.
The draft rule has a couple provisions that seem reasonable on their face, but it’s hard to trust that they would not somehow be used against federally funded programs. For example, § 200.202(f) encourages federal programs to issue multi-year awards rather than issuing separate annual notices of funding opportunity (NOFOs). That seems good, right? But would it be used to lock in grantees handpicked by federal appointees? Similarly, § 200.204 encourages NOFOs that “reasonably allow for all applicants to compete and succeed against institutions that have historically received consecutive awards in prior years.” This could promote equity, but it could also bias funders against existing grantees who received funding under prior administrations.
A big picture question this raises is what, exactly, is the revenue saved by terminating federal grants going to be used for? Launch more wars? Build more ballrooms? And if not to save money, then what? In her astute analysis, Sarah M. Trimmer observes that the proposed rule goes far beyond OMB’s statutory authority to set financial rules. In a Defend Public Health statement, Harvard’s Nancy Krieger called the draft rule a “power grab.” Perhaps OMB is trying to get around hundreds of court rulings halting its funding cuts?
What can I do?
1. Submit public comments on the proposed Regulation for Federal Financial Assistance by July 13. It’s truly easy! You can type comments into a comment box (5,000 characters max), write a letter and upload it, or do both. When you submit public comments, you can oppose the entire draft rule and/or specific sections; if you do, please list the specific section numbers. § 300.106 would apply this general rule specifically to HHS so please oppose that section! Be sure to personalize your comments because regulations.gov may disregard comments that are identical to those already submitted. Elizabeth Ginexi has posted a great example you can use for inspiration, and Jeremy Berg also has a comment template you could use as a starting place.
2. At your summer barbecues,[1] tell your friends, families, and communities what this policy would do (leave all federal funding decisions up to political appointees and let them legally cut funding whenever they want, with no explanation), what your concerns are, and what they can do if they are concerned, too. (Remember, this rule would stay true for any future presidential administrations, so people on all sides of the aisle, including people who don’t believe in the political aisles at all, may have cause for concern.)
3. Subscribe to What in the Health?! for more opportunities for public comment, and ask others you know to do this, too.
Why bother?
You may be wondering, “Why bother when the Administration is not going to listen anyway?” My response: YES, AND. Yes, the Administration might ignore your comments. AND, it still matters. Public comments can:
A. Signal to the Administration they have gone too far afield and need to backtrack. The law requires federal agencies to consider public comments in their rule-making.[2] This happened when the U.S. Drug Enforcement Agency (DEA) proposed rules restricting access to medications, including buprenorphine for opioid use disorder, via telehealth. After receiving 38,000+ comments, DEA changed course.
B. Create a written record of public sentiment that community groups, lawyers, and judges can reference during lawsuits challenging rules as illegal or unconstitutional.
C. Show the public that they have a voice and that voice matters so they should use it!
As of this posting, the draft federal rule has 22,954 comments—keep ‘em coming!
[1] Thanks to Daniel Raymond for the summer BBQs idea in another context!
[2] The Administrative Procedures Act of 1946, 5 U.S. Code § 553 – Rule making. 2 CFR § 200.202 also encourages federal agencies to “(b) develop Federal programs in consultation with communities benefiting from or impacted by the program.”