Comment on OMB-2026-0034-0001

SDBP Statement on the Proposed OMB Rule: Regulation for Federal Financial Assistance On behalf of the Society for Developmental & Behavioral Pediatrics (SDBP), we strongly oppose the proposed rule from the Office of Management and Budget (OMB) to revise the Guidance for Federal Financial Assistance related to the management of grants, cooperative agreements, and other forms of assistance published in the Federal Register on 5/29/2026. As a group of clinicians and researchers, we are highly concerned that the proposed rule would fundamentally alter the ways in which federal grants are awarded and administered. Members of our organization conduct or learn about patient care through research, much of which is federally funded, to understand the developmental and behavioral conditions that impact a large proportion of the nation’s children,1-3 as well as the factors that contribute to healthy development. Our affiliated research journal, the Journal of Developmental and Behavioral Pediatrics, is a leading resource for clinicians, teachers, and researchers involved in pediatric healthcare and child development.4 Members of our society, including researchers as well as consumers of pediatric research, would be harmed by the proposed rule. Several of the proposed changes will undermine the independence of scientific review and publication, eroding public trust in the scientific process and the outcomes of scientific research. 1. Section 200.205: New agency review process. The proposed rule establishes a new agency review of grants, during which grants that are not consistent with the administration’spriorities and policy proposals can be denied. Peer review of grants is deemed “advisory,” meaning that an administration can deny a grant that has been successful in the peer review process. This would mean that review of scientific grants could be politicized. Rather than letting experts review the quality and importance of a proposed project, political appointees would have the final word on grant funding. 2. Section 200.340: Expanded authority to terminate existing grants. Existing grants can be terminated for discretionary reasons, including on ideological grounds if the award is deemed not to align with shifting political priorities determined by unelected officials. This would contribute to waste, when projects that use grant funding are not permitted to continue to completion. 3. Section 200.220: Prohibition on foreign collaboration. The proposal would prohibit the use of federal funds to support international collaboration by disallowing certain collaborations, agreements, programs, or activities involving designated foreign countries or entities. As an organization with international membership and collaboration, this rule would limit our ability to collaborate with colleagues conducting high quality research. 4. Sections 200.454, 200.461, 200.467, 200.432: Limitation on allowable costs. The proposal would place new limits on certain costs charged to federal grants. Grant funds could no longer be used for certain memberships, subscriptions, publication expenses, and conference attendance unless expressly approved by the federal agency. This would fundamentally change the ability of researchers to make sure that findings are shared publicly and with the people most likely to be impacted. In summary, if this rule is affirmed, worthy, high-quality research that can revolutionize care and improve outcomes for youth with developmental and behavioral conditions may never be funded, may be abruptly terminated, or may never be shared with the children and families most impacted. SDBP strongly urges OMB to continue to support high-quality scientific research that can help children with disabilities and their families by rejecting the proposed rule. www.sdbp.org info@sdbp.org References: 1. Patrick ME, Shaw KA, Dietz PM, Baio J, et al. Prevalence of intellectual disability among eight-year-old children from selected communities in the United States, 2014. Disabil Health J. Apr 2021;14(2):101023. doi:10.1016/j.dhjo.2020.101023 2. Wallis KE, Adebajo T, Bennett AE, Drye M, et al. Prevalence of autism spectrum disorder in a large pediatric primary care network. Autism : the international journal of research and practice. 2023/08/01 2023;27(6):1840-1846. doi:10.1177/13623613221147396 3. Shaw KA, Williams S, Patrick ME, Valencia-Prado M, et al. Prevalence and Early Identification of Autism Spectrum Disorder Among Children Aged 4 and 8 Years - Autism and Developmental Disabilities Monitoring Network, 16 Sites, United States, 2022. Morbidity and mortality weekly report Surveillance summaries (Washington, DC : 2002). Apr 17 2025;74(2):1-22. doi:10.15585/mmwr.ss7402a1 4. Journal of Developmental & Behavioral Pediatrics. https://journals.lww.com/jrnldbp/pages/aboutthejournal.aspx