Comment on OMB-2026-0034-0001

The Akron Zoo has concerns over Docket No. OMB-2026-0034, the Office and Budget and Management’s proposed changes to 2 CFR 200, The Uniform Guidance. We support federal commitments to transparency, accountability, and stewardship of federal funds, yet the proposed modifications to the Uniform Guidance add intolerable risks and uncertainties for awardees seeking to partner on federal projects or initiatives. We urge your reconsideration and withdrawal of the proposed rule. The Akron Zoo has benefited from federal funding awards or subawards to carry out projects or programs in K-12 education, youth leadership development, job training, and animal research. Generally, the proposed modifications to Uniform Guidance would discourage us from pursuing federal funding opportunities to benefit students and young people in our region, or to support wildlife populations. Language in 200.450 (disallowing issue-advocacy or public messaging) lacks the definition and clarity that we need to fully understand what statements are permissible under federal funding. Other concerns include: -Section 200.205, 200.205(d)- Political Appointee Review, Dismantling of Peer Review This provision deprioritizes the role of experts and merit-based review in federal funding decisions. Section 200.340- Discretionary Termination Allowing funding terminations at any time for any reason, this section would expose us and other federal awardees to extreme financial risks that could result from the loss of expected and budgeted revenue, financial outlays without reimbursement, and possible snowball effects like having to break contracts, lay off employees, or disband services. Section 200.303- E-Verify Mandate The provision creates additional record-keeping and grant management burdens for relatively small organizations like ours in those instances when contractors cycle their employees in and out of long-term projects. Section 200.220- Foreign Collaboration Prohibition In the zoo and aquarium field, foreign collaboration enhances research and field projects to conserve wildlife populations and species that cross national borders. Prohibiting federal spending on projects involving foreign collaborators could reduce the status of U.S.-based zoos and researchers in international associations. Taken together, these and other provisions of the proposed rule make federal financial assistance uncertain and risky. We urge you to withdraw the rule.