Comment on OMB-2026-0034-0001

As the oldest multispecialty organization of women physicians, the American Medical Women's Association (AMWA) is dedicated to improving the health of women through education, advocacy, and evidence-based medicine. On behalf of our membership which represents physicians, trainees, healthcare professionals, and supporters, AMWA respectfully requests clarification regarding the continued eligibility of federally supported research, education, workforce development, and healthcare initiatives focused on women's health and biological sex differences in health and disease. AMWA recognizes the significant contributions that federally supported research has made to advancing our shared understanding of maternal health, menopause, autoimmune diseases, Alzheimer's disease, reproductive health, cardiovascular disease in women, and other conditions in which biological sex influences disease risk, presenting symptoms, treatment response, or outcomes. Accordingly, AMWA requests clarification that activities examining biological sex differences in health and disease, as well as programs designed to improve the health of women across the lifespan, remain eligible for federal support when conducted in accordance with applicable scientific, ethical, and legal standards. AMWA also requests clarification that the proposed rule does not restrict federally supported scientific research examining health needs, health outcomes, healthcare utilization, disease burden, or clinical management in areas where important evidence gaps remain. Physicians rely on high-quality evidence to provide appropriate care to all patients, and continued research in these areas is essential to advancing medical knowledge and improving health outcomes. AMWA further encourages OMB to provide clear guidance to federal agencies and funding recipients regarding the application of the proposed rule to activities that advance evidence-based medical knowledge related to biological sex, women's health, maternal health, reproductive health, and patient health outcomes. One suggestion is to provide examples or guidance confirming the eligibility of women's health research, sex-based medical research, maternal health programs, and clinical outcomes research addressing areas in which important evidence gaps remain. Such clarification would help ensure consistent implementation across agencies and reduce uncertainty among researchers, educational institutions, healthcare organizations, and healthcare professionals. In addition, research, workforce development, and educational programs often operate on multi-year timelines. Abrupt changes in funding or program requirements can affect staffing, data collection, training pipelines, and long-term planning. AMWA is concerned that converting government-wide grant guidance into binding OMB regulations may establish a framework in which future policy changes are implemented more broadly and rapidly across agencies – especially as administrations and policy priorities change over time -- increasing uncertainty for recipients that depend on long-term planning and sustained investment. AMWA also encourages OMB to consider the potential impact of changes to federal financial assistance administration on programs that support access to healthcare in rural and medically underserved communities. As agencies implement this rule, clear guidance should be provided to minimize unintended disruptions to federally supported health programs that serve populations with existing barriers to care. Finally, AMWA recommends that OMB clarify the scope of proposed § 200.477 (Abortion) by defining the phrase "costs associated with elective abortions" and explicitly stating that the provision does not apply to evidence-based patient counseling, physician education and training, scientific research, public health activities, or emergency pregnancy care otherwise authorized under federal law. Without these clarifications, institutions may interpret the provision more broadly than intended, creating unnecessary uncertainty for physicians, academic medical centers, and grant recipients while potentially limiting evidence-based care, medical education, and research that are essential to improving women's health.