The integrity of science in the United States is under threat and we need your help. The Office of Management and Budget (OMB) “Regulation for Federal Financial Assistance” poses drastic challenges to the scientific enterprise because it puts all federal research funding at risk of political interference. If codified into law, these changes will affect your research projects and your ability to choose and attend conferences, collaborate with international researchers from certain countries, pay publication charges, and more.

GSA remains committed to advocating for sustained research funding and scientific integrity, and supporting our genetics community.

What can I do to help?

We urge members of our genetics and genomics community to submit a public comment on the recently proposed regulations byJuly 13, 2026. Please do not wait until the deadline as servers could crash and OMB has stated they will not grant a deadline extension. All comments must be submitted directly through https://www.regulations.gov/document/OMB-2026-0034-0001.

How will the proposed revisions affect me? 

These proposed revisions will:

  • Give political appointees, rather than apolitical expert committees at agencies like NSF and NIH final approval on federal research grants to ensure compliance with presidential policy priorities. Scientific peer review of research proposals would remain “advisory and does not replace agency discretion.” 
  • Prohibit the mention of gender/sex differences in grants, making it difficult for scientists studying evolutionary and population genetics, genetics of sex, developmental biology, and doing biomedical research, to describe their work. This change would also pose challenges for scientists studying genetics in model organisms like Drosophila, C. elegans, Zebrafish, and mice, among others, as this research frequently touches on sex-specific biological differences to explain fundamental genetic and evolutionary processes.
  • Place restrictions on foreign collaborations, prohibiting the use of federal funds for partnerships with certain foreign countries or entities (which remain undefined). 
  • Eliminate reimbursement and payment for publication, conference attendance, and membership expenses, unless prior federal approval in select cases is granted.

These regulations, if codified, will extend far beyond this current Administration, having longer-term far-reaching implications and affecting the entire federal government, all agencies, and anyone who operates on federal funding. 

Why should I submit a comment? Isn’t GSA submitting one?
Yes, GSA will submit one as a Society. However, to have a true impact, the government must receive as many individual comments as possible. It is common for proposals of such magnitude to receive comment numbers in the millions or tens of millions. This is why we encourage you to submit a comment independently from GSA’s or other organizations’ comments. Do not assume that your voice will be heard through GSA’s letter alone, because grouped comments or sign-on letters will only be counted as one comment by OMB.

How do I write an effective comment?

A former NIH program officer has written an excellent guide on how to efficiently write and submit a comment that could have a true impact. Highlights of this guidance include:

  1. List the specific section number (e.g., §200.205) of the Notice of Proposed Rulemaking (NPRM) in brackets and if addressing multiple sections, list each section’s number at the beginning of each distinct paragraph.
  2. Explain who you are and why you can provide this perspective (e.g., a federally funded scientist, a scientific society).
  3. Explain how the proposed language in the section will specifically affect you and your research. You’ve likely felt these impacts for the past 15+ months, which is another reason it’s so important to submit public comments, as this rule would codify these previous changes first proposed through Executive Order.
    • Give clear examples that demonstrate impact to your lab, graduate students, and ability to continue the research 
    • Outline waste of already spent research funds if grants are abruptly terminated
    • Detail what happens if you cannot use federal grant funds to publish your NIH- or NSF-funded research or present it at scientific conferences
    • Share the impacts both to your lab and to the scientific enterprise of an inability to collaborate with researchers outside of the U.S. 
    • While emotional appeals are helpful for advocacy with elected representatives, in this case, regulatory reviewers will look for objective, straightforward evidence; avoid using statements lacking evidence or hyperbolic language 
  4. OMB has cited three goals with these changes: increasing transparency, clarifying regulatory status, and reducing burden on award recipients. Refer back to these goals and state how many of these proposed changes would actually reduce transparency and increase burden on awardees.
  5. Do not copy/paste comments from a form letter, sign-on letter, or public petition. Comments written in your own words, sharing your own experiences, carry more legal weight and OMB is required to respond to them.
  6. Avoid the use of large language model AI tools to craft your comment. If you use tools like ChatGPT or Claude to organize your thoughts, use them with caution; fact check the results and read carefully through the proposed text to adjust any incorrect information and ensure your experiences are accurately portrayed and the final product does not read as generic, heavily automated text.
  7. While the comment box limits you to 5,000 characters (including spaces), you can upload a file with additional text.
  8. Be specific and factual; provide quantitative data of the impacts, where possible. 

Why does my comment matter? Isn’t it a waste of time and effort?
It is of utmost importance that we continue advocating to protect science. OMB is required by law under the Administrative Procedure Act to read and respond to every substantive comment submitted through the formal rulemaking process before finalizing the rule. Your comment will become part of the permanent public record, rendering OMB and the Administration unable to argue that there was no opposition from the public. Additionally, a record of comments sets the foundation for future legal and legislative action. When reviewing cases, the courts can see whether OMB adequately responded to public opposition, and a strong record of opposition strengthens any legal challenge of the proposed revisions. Finally, Congress watches comment volumes. Seeing many thousands of detailed comments signals that a rule is politically controversial, possibly warranting legislative action. 

Additionally, midterms are coming up—elected members of Congress, from either party, care about keeping their jobs. Therefore, after leaving a detailed comment, continue calling your Senators and Representative and urge them to vocally oppose these regulations too. 

Can I submit a comment anonymously?
Yes. If you wish to remain anonymous, make sure you indicate you are submitting as an “Anonymous” entity and do not enter your name or organization in the provided fields, which are optional. OMB gives more weight to comments from individuals or organizations that identify themselves but by law, they must consider all comments that come in, including anonymous ones. As mentioned above, Congress takes into account the volume of comments and this may also matter if and when this issue lands in the courts, so it’s important that scientists show up in great numbers. Please note that everything you include in your form when submitting your comment will be posted publicly on regulations.gov.

Can I use my professional or institution email address?
Make sure you obtain guidance from your employer. Some institutions may oppose you using your institution address to leave a comment. 

Can I submit multiple comments?
Yes, you can submit multiple comments and the more comments recorded, the better; however, make sure your comments each address different sections in a substantive manner. Do not repost others’ comments or post the same comment multiple times as OMB will not count those.

I am not a U.S. citizen or do not live in the U.S. Can I leave a comment?
Yes. OMB must also consider these comments. We encourage you to share how these regulations impact international collaborations and the standing of the U.S. scientific enterprise on a global scale. Additionally, it’s important to share how scientific research will be disrupted by proposed restrictions on international collaborations and how that will ultimately hurt the U.S.’s economic interest. 

Is there anything I shouldn’t include in my comment?

Your comments should not touch on the indirect cost rate negotiation system. This is because even though the revisions point to a preference for lower indirect costs to institutions in the review process, OMB has stated they will not consider or respond to such comments in the final rule.  

I was sent a link to another platform to submit my comments to.
Comments will only be accepted if posted directly to regulations.gov. Do not post elsewhere or on external sites. 

Are there any resources I can use to form my comment or articles I can read to better understand the revisions?

White House seeks to tighten political oversight of grantmaking in ScienceInsider

What We Need to do NEXT: OMB’s Proposed Federal Financial Assistance Rule (OMB-2026-0034) by Elizabeth Ginexi 

Proposed Changes to the OMB Uniform Guidance (breakdown per section/area of focus) by the Council of Nonprofits

GSA is hosting two one-hour virtual working sessions on Monday, June 29 (4:00–5:00 p.m. EDT) and Friday, July 10 (9:00–10:00 a.m. EDT), where participants can independently work on their comments, or collaborate with peers and discuss comments with others in a breakout room. Register to secure your spot; come in and out as needed—there is no need to join for the full hour. 

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