Comment on Office of Management and Budget proposed rule for federal financial assistance

Relevant sections: 2 CFR § 200.205 (Merit Review) and § 200.340 (Termination and Suspension)

• Political oversight: Establishes a centralized "pre-issuance review" where federal agency heads must designate senior political appointees to independently review discretionary award proposals to ensure they align with federal law, presidential priorities, and specific national criteria like scientific rigor and public safety. These officials must exercise independent judgment rather than routinely deferring to peer reviews, and agencies retain the discretion to repost funding opportunities if proposals do not meet these standards (§ 200.205). Awards must “...demonstrably advance the President’s policy priorities,” giving political appointees a veto over any science that conflicts with an administration’s ideology.
• Sudden defunding risk: Introduces contract-style "convenience terminations" allowing agencies to suspend or terminate active grants at any point if a project no longer aligns with perceived federal priorities (§ 200.340). The agency would not be required to provide a detailed analysis of why the grant was terminated.

Relevant sections: 2 CFR § 200.202(e) (Research Eligibility) and § 200.220 (Covered Foreign Collaborations)

• Blanket foreign restrictions: Extends rigid restrictions like the Wolf Amendment — which prevents bilateral NASA collaboration with China — government-wide. For bilateral and multilateral collaboration, prohibits spending federal funds on direct programmatic activities, research, technical assistance, data-sharing, travel, or indirect costs with "covered foreign countries” or other foreign entities unless expressly authorized by federal statute or federal agency head (§ 200.220).
  
  Covered foreign country means any country designated by statute, Executive Order or other Federal law as a foreign adversary, a country of particular concern, or a country subject to sanctions or restrictions related to national security, defense, or intelligence activities. Broad interpretations of this section could prevent international collaborations without express approval.
• "Domestic-first" restraints: Generally restricts R&D awards to U.S. entities (§ 200.202(e)). Exceptions for international program elements may be included only when authorized by federal statute or approval by a senior political appointee. U.S. researchers could therefore be isolated from global projects like CERN through additional bureaucratic red tape.

Relevant sections: 2 CFR § 200.432 (Conferences), § 200.454 (Memberships and Subscriptions), § 200.461 (Publication Costs), § 200.206 (Risk Assessment), and § 200.450 (Issue Advocacy)

• Conferences and professional memberships: Conference costs are unallowable unless explicitly written into the grant's terms (§ 200.432). Professional society membership costs require prior written approval, are only allowable if necessary to fulfill the award requirements, and are banned entirely if the organization’s primary function is issue advocacy (§ 200.454).
• Publication and subscription costs: Limits researchers’ ability to widely disseminate research results by generally making publication costs -- including page charges, article processing charges and open access fees -- unallowable under Federal awards (grants). Exceptions require advanced approval by the agency on a case-by-case basis or specifically required by Federal statute (§ 200.461).
  
  Potentially limits researchers’ ability to access the scientific record by making subscription costs unallowable (§ 200.454).
• Vetting and autonomy: Broadens pre-award risk assessments to scrutinize applicants' professional and extracurricular affiliations (§ 200.206).
• Public and civic engagement: Bans "issue advocacy" on politically sensitive topics labeled by the preamble as "divisive ideologies" (§ 200.450).

Relevant sections: 2 CFR § 200.300 (Statutory and national policy requirements) and § 200.218 (Disparate-impact liability)

• DEI ban: Blocks federal funds from supporting or promoting Diversity, Equity, and Inclusion (DEI/DEIA) initiatives that are perceived to conflict with applicable Federal anti-discrimination laws (§ 200.300). Lawful, established efforts to increase participation in science may be put at risk of elimination.
• Disparate-impact restrictions: Bans the use of federal funds for disparate-impact studies, related litigation, or operational policies aimed at mitigating systemic disparities (§ 200.218), severely limiting topics like education research.
• “Gender ideology:” Federal funds may not be used to promote “gender ideology” as defined in Executive Order 14168 (e.g. denying “the biological reality of sex or the sex binary in humans” or endorsing or advocating for “the notion that sex is a chosen or mutable characteristic”).