The Public Rejects OMB's Federal Financial Assistance Rule

On May 29, the White House Office of Management and Budget (OMB) proposed a comprehensive overhaul of 2 CFR Part 200, commonly known as the Uniform Guidance for Federal Financial Assistance. Since 2013, this framework has governed how federal agencies administer federal grants, cooperative agreements, and financial assistance across the United States. With over $1 trillion in such federal assistance subject to 2 CFR 200—much of that going towards programs that support state and local governments, tribes, universities, nonprofits, public authorities, school districts, healthcare organizations, small businesses, and research institutes—the outcome of the proposed rule affects a large sector of the US economy. About $150 billion of the assistance takes the form of research and development grants that support America’s investment in science and technology.

The proposed rule seeks to elevate the text from administrative guidance to a binding government-wide regulation, centralizing rulemaking authority within the OMB itself. Key provisions introduce mandatory pre-issuance reviews of all discretionary awards by political appointees to ensure alignment with administration policy priorities. Additionally, the proposal expands agency discretion to terminate existing awards and restricts funding for collaborations with specific foreign entities.

The response of the science and technology community

In a June editorial titled "Another red alert for American science," Science Editor-in-Chief Holden Thorp argues that the proposed White House Office of Management and Budget rule change represents an effort to bypass congressional intent and starve federal research. Thorp states that by introducing political review into the funding pipeline, the rule effectively overrides the established scientific peer-review process. He emphasizes that allowing political appointees to select, cut, or terminate research awards threatens the structural foundations of American scientific discovery, turning independent research allocation into an instrument of executive policy.

The scientific and academic communities responded with widespread concern, organizing advocacy campaigns to highlight the risks these changes pose to research independence and administrative stability. Organizations such as the American Physical Society and the American Geophysical Union mobilized their members to submit public feedback using custom platforms to assist the public with writing their responses.

So, how did the public respond, and how effective were these campaigns? To find out, we analyzed every comment on the docket with an open-source pipeline we built for reading public comments at scale. We downloaded all of the comments from regulations.gov, including the text of attached letters and PDFs, and used an LLM to process each one and record its position on the rule, the specific concerns it raised, and what kind of person or organization submitted it. A second pass double-checked those labels, while a separate step grouped near-identical submissions into form-letter campaigns, and another linked each comment to the sections of the rule it cites. The results feed the interactive dashboard we draw on below.

Between May 29 and July 9, roughly 51,000 comments were posted to regulations.gov (and over 200,000 more had been received but not yet published). The verdict on public sentiment is clear and lopsided: about 94 percent oppose the proposed rule and only 6 percent support it, with fewer than one percent marked as unclear. The opposition is overwhelmingly grassroots rather than orchestrated. Form letters make up only about 16 percent of all comments (roughly 8,400 comments across 210 distinct campaigns), and only about one in eight opposing comments came from a form-letter campaign. Support for the rule, by contrast, was almost entirely organized: nearly nine in ten supportive comments (about 2,500) came from a single form-letter campaign. Opponents mostly wrote their own comments; supporters mostly signed the same form-letter.

The commenters span many sectors, but individuals dominate: about 39,000 comments (77 percent) came from unaffiliated individuals, and another 7,900 from individual researchers and academics. Roughly 3,300 came from patients, families, and health advocates. Organized institutions were a small share by count but a notable one by voice, including scientific and professional societies (about 70), universities and research institutions (about 30), and advocacy nonprofits (nearly 280). The offices of at least 14 elected officials sent in letters of opposition, including one by Rep. Jamie Raskin (D-Md.) with 125 co-signers. The letter sent by Sen. Susan Collins (R-Maine) directly to OMB Director Russell Vought was not included in the collection.

When we look at what commenters actually objected to, two themes dominate: the politicization of grant decisions, raised in roughly two-thirds of all comments, and the fear that the rule would sideline scientific peer review, raised in more than half. The counts alone understate the intensity of the objections by the community.

One federally funded scientist wrote that: “scientists doing the vetting of projects is the core of a non partisan program, allowing partisan non-scientists oversight is a mistake our research communities will take generations to recover from.” The American Society of Naturalists warned that the rule “would require that senior political appointees personally review and approve every discretionary research grant for consistency with presidential policy priorities.” Objections often named specific provisions: one physician-researcher singled out §200.205, “which would require a senior political appointee to personally review and approve discretionary grants, with authority to override the outcome of scientific peer review.”

Not every objection was about science. The Southern Environmental Law Center focused on process, arguing that “only 45 days for public comment on a rule of this magnitude … is inadequate,” noting the proposal runs more than 400 pages and binds 41 other federal agencies. One concerned citizen, a food-bank volunteer, highlighted the economic significance of the proposed rule: “The proposal affects well over $1 trillion in annual Federal grants and cooperative agreements, and affects every State, every Tribe, and most major nonprofits, universities, hospitals, and federally funded private industry. OMB has not even attempted to quantify the impacts on any of them. I fear that many of the small, local food banks that I work with would get lost in this new structure, and because of it, thousands of people in my city would go hungry.” We note that the Office of Information and Regulatory Affairs (OIRA) within OMB determined that the rule was economically non-significant when it completed its review.

Supporters were not only fewer but narrower: almost all of the roughly 2,900 supportive comments cited preventing waste, fraud, and abuse (WFA) and little else—the Immigration Accountability Project, for instance, applauded the rule’s new requirement that federal grant recipients use the E-Verify program. The relatively few supporters that wrote their own comments offered nuanced perspective, with a mixture of support for reducing WFA and recommendations for revisions, such as those submitted by the City of Lago Vista, Texas: “The City supports efforts to improve oversight of federal expenditures. However, reimbursement procedures should be administered in a manner that does not unnecessarily delay payments...”

The comments cluster around a handful of provisions. Section 200.205, the pre-issuance review of discretionary awards by political appointees, drew the most attention, cited in about 6,900 comments. Section 200.340, which expands the authority to terminate active awards, was second with about 5,900. Other frequently cited provisions set new limits on allowable costs, including Sections 200.461 and 200.432 (each cited in more than 3,000 comments).

The resounding public response is a categorical ‘no’, so what’s next?

Taken together, the record is striking. Tens of thousands of scientists, clinicians, and ordinary citizens wrote in their own words to warn OMB that putting political appointees in charge of which research gets funded would erode the quality and independence of federally funded science. The comments in support were far fewer and narrower. Under the notice-and-comment process, OMB is now required to review these comments and respond to every substantive argument they raise before it can issue a final rule. The timeline is aggressive for OMB to analyze and respond to comments with only a few weeks between the close of comments on July 13 and the proposed effective date of October. We encourage reviewers to use our tool to simplify analysis.

Finally, there should be an opportunity for the public to request meetings with OMB under Executive Order 12866 to discuss the rule when the OIRA starts its final review. Interested parties should monitor reginfo.gov should that option become available to the public.