Instructions to Submit Comments

June 24, 2026

What is Being Proposed? 

On May 29, 2026, the Office of Management and Budget (OMB) proposed sweeping changes to the federal government’s “Uniform Guidance” — the rules that govern how federal grants and cooperative agreements are awarded, managed, and terminated (2 CFR Part 200). These rules affect funding across the federal government, including research grants from agencies such as NIH, NSF, CDC, and DOE.

We are deeply concerned that, if implemented as written, the proposed regulation would fundamentally disrupt the medical research enterprise and create an existential crisis for science in the United States.  While the Endocrine Society is submitting an organizational response, substantive, original comments from individuals form an important part of the public record and have real weight in rulemaking and future challenges to the rule. 

The current proposal is open for public comment until July 13. The rule is scheduled to take effect on October 1, 2026. Once the rule is implemented, it has the force of law. 

What Does This Mean for My Research? 

Several sections include proposed revisions that would have significant and foundational impacts on the conduct of research.  These include: 

  • §200.205 — Political review of discretionary grant awards 
    The proposed rule would require that federal awards “demonstrably advance the President’s policy priorities,” thereby placing political priorities above scientific merit review for the selection of grants to support research programs. 
  • §200.340 — Expanded grant termination authority 
    The proposed rule expands this authority to permit termination where work no longer advances “current program goals, agency priorities, or the national interest,” including through stop-work orders for up to 90 days. 
  • §200.305 — Drawdown payment justifications 
    The proposed rule would require recipients to submit a brief drawdown payment justification before each drawdown. 
  • §200.432 — Conference attendance requirements 
    The proposed rule would require prior authorization for conference attendance costs. 
  • §200.454 — Journal subscription costs 
    Journal subscriptions would no longer be allowed to be paid with grant funds. 
  • §200.461 — Publication and open-access costs 
    Publication fees would no longer be allowed to be paid with grant funds 
  • §200.220 — Prohibition on international scientific collaboration
    The proposal would prohibit the use of any federal funds for collaboration with “covered foreign countries” or entities affiliated with them, extending to travel, research activities, technical assistance, and allocable indirect costs. 

How Can I Take Action?

Step 1: Access the form — You can provide a comment by visiting the public docket on regulations.gov at www.regulations.gov/docket/OMB-2026-0034 and navigate to the comments section by clicking “open for comment” and then “comment.”  Or, you can navigate directly to the online comment form at: www.regulations.gov/commenton/OMB-2026-0034-0001 you may submit comments anonymously 

Step 2: Prepare your comments — Comments can be typed directly into the open text field on the website or submitted as an attachment.  Please note that responses typed directly into the comment box have a limit of 5000 characters.  

Step 3: Submit your comments — Below the comment box you can select how you will identify yourself, this is where you can indicate if you wish to submit anonymously. After checking the reCAPTCHA you can click on “submit comment” at the bottom. 

Tips for an effective comment 

1. Lead with who you are and why you're qualified. An effective comment begins with an introduction where you explain why you are interested in the regulation and highlight any experience with the subject of the rule that may distinguish your comment. We recommend conferring with your institutional government relations team for guidance on whether and how you should include your institutional affiliation and title. 

2. Be specific about which part of the rule you're addressing. Clearly identify the relevant part of the regulation you are commenting on. Reference the specific provision(s) that affect(s) your work and address it directly.

3. Bring evidence and explanations, not just opinion. Simply stating that you support or oppose a policy is not as persuasive as explaining how the policy would positively or negatively impact your research.

4. Tell the agency what it got wrong. Consider whether the proposed regulation is based on the best available scientific, technical, economic, and other information.

5. Describe unintended consequences. Even in the best of circumstances, agencies cannot predict every potential impact of a proposed regulation. Public comments can provide information that challenges assumptions. Think about how the rule would actually work in your lab, clinic, or field.

6. Make concrete recommendations e.g., withdrawal of the proposed change(s), don't just criticize.

7. Don't copy/paste someone else's comment. Multiple identical comments are not likely to be more persuasive than if the comment had been sent only once. Agencies are only supposed to address substantive, original comments.

8. Keep it readable, you do not have to be exhaustive or use technical jargon. A good comment need not be extremely technical to be effective. Some of the most effective comments are from individuals who describe the impacts of a proposal in terms of their own lived experience. Letting an agency know what may or may not work "on the ground" is often a very useful perspective to share.

9. Submit on time. Comments are due July 13 and there will not be an extension! 

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