I strongly oppose the proposed OMB rule as written.

By centralizing authority in political appointees to review, approve, suspend, or terminate discretionary grants, the rule undermines merit-based peer review and academic independence and risks ideological screening of research.

Expanded pre-award reviews, pre-issuance checks, and broad new termination authorities will create unpredictable administrative burdens that divert time and funds from research.

Narrowing allowable costs—potentially restricting publication, conference, and collaboration expenses—and favoring institutions with lower indirect cost rates will weaken the research infrastructure that supports compliance, safety, training, and knowledge dissemination.

Reclassifying 2 CFR Part 200 from guidance to a binding regulation removes agency-specific rulemaking safeguards and reduces transparency and stakeholder input for future changes.

The proposal’s provisions restricting international collaboration threaten U.S. scientific competitiveness and the free exchange of ideas essential to discovery.

Additional reporting requirements for subawards and pass-through entities, plus expanded SAM.gov obligations, will increase compliance costs and further erode funds available for actual research.

The rule also establishes broad, discretionary grounds for suspension and termination, creating legal and contractual instability for ongoing projects.

If the goal is improved accountability and transparency, targeted, consultative reforms—such as clearer conflict-of-interest policies, streamlined reporting, and strengthened audit guidance—would achieve those aims without the disruptive centralization proposed here.

I urge OMB to withdraw or substantially revise this proposal, preserve merit review and negotiated indirect cost support, protect allowable costs critical to dissemination and collaboration, and provide a full, meaningful public comment process with adequate time for stakeholder engagement.