Comment from Bapu Vaitla

,PUBLIC COMMENT IN OPPOSITIONDocket No. OMB-2026-0034Regulation for Federal Financial AssistanceI write in strong opposition to the Office of Management and Budget's proposed rule, "Regulation for Federal Financial Assistance" (Docket OMB-2026-0034), published in the Federal Register on May 29, 2026. As a lecturer at a public research university, a public official, and a citizen who depends on the integrity of federally funded science, community development, and public services, I urge OMB to withdraw this proposal in its entirety.I. The Proposal Replaces Merit-Based Review with Political ControlThe proposed rule would establish a centralized "pre-issuance review" in which 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. 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). This is an apparent departure from the post-World War II practice of funding approval traditionally being determined by apolitical experts who assess awards based on scientific merit. Peer review is not a bureaucratic formality; it is the epistemically sound mechanism by which the federal government has built the most productive scientific enterprise in history. Replacing expert evaluation with political approval corrupts that mechanism at its root.II. The Proposed Termination Authority Is Arbitrary and Economically DestabilizingOMB proposes to revise Section 200.340 to codify and expand the authority to terminate active grants at the discretion of the federal agency or pass-through entity, to the extent permitted by law, "including if a Federal award does not effectuate program goals, Federal agency priorities, or the national interest as they exi[st]."The proposed change to Section 200.341 on notification of termination adds: "A brief summary of the reason or reasons for finding that termination is in the interest of the Federal agency or pass-through entity. The reason or reasons may apply to an individual award or class of awards. The Federal agency or pass-through entity is not required to provide a detailed or exhaustive analysis."This provision would allow agencies to cancel grants with no meaningful justification. The proposed termination and suspension provisions could make federal award revenue less predictable, especially for organizations that build staffing, research infrastructure, service delivery, or capital planning around multiyear grants. Universities, hospitals, nonprofits, local governments, and small businesses would be forced to operate under a perpetual threat of arbitrary defunding — undermining the long-horizon investments that basic research and community development require.III. The Proposal Conditions Funding on Ideological ConformityThe "anti-American values" criterion in §200.205, the issue advocacy prohibition in §200.450, and the DEI prohibition in §200.300 all would condition federal funding on ideological conformity rather than programmatic compliance. Researchers whose work directly informs public policy — such as climate scientists, public health researchers, and behavioral and social scientists — would be effectively prohibited from communicating their own federally funded findings publicly without risking their awards.This is a content-based restriction on federally funded expression. It would distort the scientific record, suppress findings inconvenient to current political leadership, and structurally compromise the independence that makes publicly funded science trustworthy and useful.IV. The Proposal Raises Serious Legal ConcernsPerhaps the most structurally significant change is the introduction of a mandatory pre-issuance political review for all discretionary awards. A related change would stipulate that — in the event of a conflict between OMB government-wide regulations and an individual agency's regulations — the government-wide regulations would apply to the greatest extent permissible by law, centralizing more federal grantmaking powers with OMB. Under West Virginia v. EPA, the Major Questions Doctrine requires that agencies have clear congressional authorization for decisions of vast political and economic significance. Restructuring the entire federal grant enterprise — which represents approximately $1.1 trillion annually across every agency, every program, and every recipient — through a single OMB rulemaking, in ways that conflict with dozens of s