Comment from Kari Nejak-Bowen

June 25, 2026 The Honorable Russell T. Vought Director, Office of Management and Budget Executive Office of the President 725 17th Street NW Washington, DC 20503 Re: Comments on the Proposed Rule, Regulation for Federal Financial Assistance Docket No. OMB-2026-0034; RIN 0348-AB81 (lead) 91 Fed. Reg. 32198 (proposed May 29, 2026); Comment Deadline: July 13, 2026 Proposed Effective Date: October 1, 2026 Dear Director Vought: I am a mid-level Principal Investigator whose research is supported by NIH. I write with serious concern regarding OMB's proposed rule revising 2 C.F.R. Part 200 (Docket OMB-2026-0034), open for public comment through July 13, 2026. I have significant concerns about the following provisions: • § 200.205 — Political pre-issuance review • § 200.340 — Discretionary termination authority After careful review of the provisions identified below, I am requesting that OMB withdraw this rule entirely. The Uniform Guidance exists as guidance, not regulation, for good reason: it provides a flexible, governmentwide framework for managing federal financial assistance that agencies and recipients can adapt to their specific circumstances. The proposed transformation of this guidance into binding regulation removes that flexibility at a moment when the research enterprise is already navigating significant uncertainty. Beyond the specific provisions at issue, this structural change imposes new legal obligations on every institution and investigator receiving federal research support — obligations that many recipients simply do not have the capacity to meet. The institutions that will struggle most are precisely those that federal research policy has long sought to bring into the funding ecosystem: small colleges, minority-serving institutions, and community-based organizations. [§ 200.205 — Political pre-issuance review] U.S. scientific leadership has long rested on the principle that funding follows merit, not politics. The proposed pre-issuance review by senior political appointees (§ 200.205) abandons that principle entirely. As PI whose research is supported by NIH, I am concerned that this provision will redirect funding away from the most scientifically promising work and toward projects that align with current political priorities — an outcome that wastes taxpayer investment and erodes the independence that makes American science credible globally. [§ 200.340 — Discretionary termination authority] The federal government has spent decades building a system for managing research grants in which termination is a remedy reserved for compliance failures, scientific misconduct, or program discontinuation — not political disagreement with a research topic. The proposed rule (§ 200.340) abandons that system entirely, replacing a standards-based termination framework with open-ended discretion to end awards whenever political priorities shift. Institutions cannot use a cancellable, politically conditioned commitment as the basis for hiring decisions, infrastructure investments, or long-term strategic planning. The proposed rule converts federal grants from durable scientific investments into month-to-month political arrangements. My institution has made long-term investments predicated on continued federal grant support; thus, unreliable or uncertain funding will adversely impact my work and the work of many others. I respectfully urge OMB to withdraw this proposed rule in its entirety and to refrain from finalization. The structural change it proposes — converting the Uniform Guidance from advisory to binding — is itself a change of sufficient magnitude to warrant a full notice-and-comment rulemaking with an adequate comment period and genuine engagement with the scientific community. The additional substantive provisions at issue compound the urgency of that engagement. A 45-day comment window and an October 1, 2026 effective date are not consistent with good-faith administrative process for a rule of this scope. If OMB is committed to reforming the administration of federal financial assistance, that reform should be pursued through a deliberate, transparent, and consultative process. Sincerely, Kari Nejak-Bowen, MBA, PhD University of Pittsburgh School of Medicine knnst5@pitt.edu