Comment from Chris Doe

July 2, 2026 Submitted electronically via www.regulations.gov 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 PI who has run a NIH-funded research lab for over 30 years; my research is supported by NIH and HHMI. I offer the following comments objecting to 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 • § 200.202(e), § 200.220 — International collaboration restrictions • § 200.205 & § 200.300 — Training grants (T32, F31, F99) As described below, the appropriate response to this proposed rule is full withdrawal. It is difficult to overstate the significance of transforming the Uniform Guidance — a policy framework deliberately designed to be guidance — into binding federal regulation. Guidance can be updated as the research enterprise evolves; regulation locks in today's political priorities as permanent legal requirements. The research institutions that depend on federal funding have built their compliance systems around the flexibility that guidance allows. Replacing that flexibility with rigid regulatory requirements will impose costs that fall disproportionately on those with the least capacity to absorb them: small liberal arts colleges, community-based research programs, and historically underrepresented institutions. The predictable consequence is not a more accountable research enterprise. [§ 200.205 — Political pre-issuance review] Federal research funding decisions have historically been insulated from political interference because Congress has recognized that political judgment about scientific merit is not reliable. The proposed pre-issuance review provision (§ 200.205) reverses that judgment, creating a mechanism through which scientific peer review recommendations can be overridden by political appointees without any requirement to demonstrate technical deficiency. As a senior lab head whose research is supported by NIH, I urge OMB to recognize what this provision would destroy: not just individual grants, but the entire system of trust — among investigators, institutions, international partners, and the public — that makes American federally funded science the most credible in the world. [§ 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. [§ 200.205 & § 200.300 — Training grants (T32, F31, F99)] Federal training grants represent a direct investment in the next generation of American scientists. The proposed rule's DEI restrictions and political pre-issuance review (§ 200.205, § 200.300) create significant uncertainty for training programs. We have trained between 5 and 9 grad student trainees per year, and the vast majority off these students get their PhDs and remain in the STEM workforce. Disrupting the training grant pipeline now will produce a shortage of trained biomedical researchers that will take a generation to correct. I urge OMB in the strongest possible terms to withdraw this proposed rule before it is finalized. The research enterprise that this rule would govern has taken decades to build and could be significantly damaged in a matter of months if this rule takes effect as proposed. The 45-day comment period, the compressed timeline to an October 1, 2026 effective date, and the breadth of the provisions at issue all suggest that the rule making process has not included the deliberation that a change of this magnitude requires. If OMB believes that reforms to the Uniform Guidance are warranted, I encourage it to begin that process with appropriate stakeholder engagement, a realistic implementation timeline, and a commitment to preserving the merit-based peer review system. Chris Doe, Institute of Neuroscience University of Oregon cdoe@uoregon.edu 541-346-4877