My Comment on OMB-2026-0034
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I posted1 the following comment to OMB’s proposed rule changes to 2 CFR 200. If you’ve never heard of OMB or 2 CFR 200, I’ve included a few links at the end that explain what this is about and why this is bad for the American scientific enterprise.
I am submitting this comment in opposition to the proposed revisions to 2 CFR Part 200.
I write in my personal capacity as a research-active faculty member, not on behalf of my institution. I am an associate professor at a leading school of data science at an R1 university, where I also hold a leadership role in research administration. I have held multi-year federal awards from agencies including DoW, IARPA, DARPA, NIH, NIJ, and others, and I develop and review federal proposals as part of my regular work. My comments below describe concrete operational harms I expect from specific provisions.
I share the broad concern that converting decades-old guidance into binding regulation across hundreds of sections in a single action, with one government-wide effective date, leaves grantees little ability to assess and respond to each change. Several specific provisions warrant withdrawal.
Sec 200.205 (political review of awards). Requiring politically appointed officials to review awards and forbidding them from deferring to peer reviewers removes the quality control that protects the public’s investment. Merit review by qualified scientists is the mechanism that screens proposals for technical soundness and feasibility. Undefined criteria such as “anti-American values” add unpredictability that no investigator can plan around and invite inconsistent application.
Sec 200.340 (discretionary termination). A standard allowing termination mid-project for shifting “national interest” reasons, with only a brief written rationale and no appeal, converts every multi-year award into an at-will arrangement. I cannot responsibly hire a postdoc on a 4-year award, or commit a doctoral student’s dissertation to it, if the award can be canceled at any time for reasons unrelated to performance. The cost falls on staff, trainees, and in some cases study participants.
Sec 200.432, sec 200.454, and sec 200.461 (conferences, subscriptions, publication costs). These have been routine allowable costs for decades. Making journal subscriptions categorically unallowable cuts researchers off from the literature their projects require. Requiring agency pre-approval for each conference removes the venues where findings are presented and collaborations form. Most directly, disallowing publication costs contradicts the 2022 OSTP public-access requirement, which obligates these same researchers to make federally funded articles publicly available. A rule cannot require open-access publication and disallow the cost of achieving it.
Sec 200.220 (foreign collaboration). Fields including pathogen genomics and biosecurity depend on international data and partnerships, because infectious disease surveillance does not stop at a border. A broad prohibition on collaboration with covered foreign entities, rather than targeted restrictions tied to verified risk, would weaken the work that protects public health and national security while competitor nations face no equivalent constraint.
For over 15 years I’ve worked in defense of the American people, applying genomics to biosecurity and national security problems under federal contract from the Department of War and other federal agencies. That work made this crystal clear to me, that our nation’s security and its prosperity rest on the same foundation: a research enterprise free to follow the evidence, recruit the best talent wherever it is found, and publish openly. The provisions above weaken that foundation and would slow the discoveries that protect public health and keep the United States and its allies and partners ahead of its competitors and adversaries. I share the goal of responsible stewardship of federal funds, but that comes from merit review and stable, transparent commitments, not from political control over which science gets done.
I urge OMB to withdraw this rule. At a minimum, I request that the provisions identified above not be finalized.
Respectfully,
Stephen Turner, Ph.D.
Associate Professor of Data Science
If you haven’t been following what’s happening here, Elizabeth Ginexi (former NIH program official for 2 decades) has a few recent posts laying out what this all means. You can leave a comment as well, anonymous if you wish. As I’m writing this over 140,000 comments have been submitted.
My Public Comment on Proposed OMB Rule: Regulation for Federal Financial Assistance
A Rule Nobody Voted On Could Cut Federal Funding to Your Community
What We Need to do NEXT: OMB’s Proposed Federal Financial Assistance Rule (OMB-2026-0034)
Summary of Key Changes in OMB’s Proposed Federal Financial Assistance Rule
As an individual citizen scientist, not affiliated in any way with my employer.