Comment from Christina H

Thank you for this opportunity to comment and please see my attached letter. This comment is regarding proposed rulemaking to revise the Uniform Guidance for Federal Financial Assistance located in title 2 of the Code of Federal Regulations (2 CFR) Part 200, slated to take effect extremely soon on October 1, 2026, with a short 45-day comment period and, to date and unusually, with no published cost-benefit analysis by the Office of Management and Budget. The Federal Register states that the revision is intended to “improve government-wide policies and requirements related to the management of grants, cooperative agreements, and other forms of assistance” (Federal Register “Summary,” pg. 32199, found at https://www.govinfo.gov/content/pkg/FR-2026-05-29/pdf/2026-10817.pdf). The Office of Management and Budget (OMB) together with 41 federal agencies are proposing to rewrite the foundational rules that govern how nearly every federal grant dollar—including broadband, digital equity, research, and community development funds that are received by every entity that receives federal grants or has cooperative agreements (including states, local governments, Tribes, universities, nonprofits, hospitals, and for-profit organizations)—is awarded, conditioned, and potentially terminated. I work on community health and nutrition within the University of California. Some of my work is funded by the National Institutes of Health and by the National Institute of Diabetes and Digestive and Kidney Diseases. Proposals for such grant funding historically go through a rigorous process of review by experts that is designed to award federal funds to projects with scientific merit and exacting methods. Proposed revisions in Section 200 would by-pass independent expert review of Federal grants in favor of political oversight, allow grants to be terminated at any time, for any reason, and largely prevent the use of Federal funds for publishing, attending meetings, or collaborating internationally. This proposed rulemaking threatens to terminate predictable and evidence-based federal support for science, and it will have devastating repercussions for U.S. progress in science and health. I oppose the proposed revisions, and particularly oppose those detailed, by section, in my attached letter. Furthermore, I am writing to register my serious concern with the evidence cited in the rulemaking document. For example, the “Executive Summary” and “OMB Objectives” sections cite no peer-reviewed research. Rather they cite only Trump Administration Executive Orders and Fact Sheets, Heritage Foundation reports, op-eds from the Manhattan Institute and City Journal, and Senate Republican committee reports as justification. These are not official government findings nor are they peer-reviewed science. Rather they are advocacy and political documents, for the most part published by or during the current Administration. In other words, the arguments for the need for this rule-making are based on a particular viewpoint rather than on established facts. Finally, I am writing to voice my strenuous objection to the conversion from guidance to regulation in this rule-making (“Clarification of status of regulatory text. A second objective of this rulemaking is to clarify the status of the 2 CFR regulatory text as an OMB regulation”). This conversion violates the Administrative Procedure Act §553 notice-and-comment requirements (https://www.archives.gov/federal-register/laws/administrative-procedure/553.html ). As an academic researcher with a Ph.D. in public health and as a citizen of the United States of America I firmly believe that OMB should withdraw the Proposed Rule. Americans benefit from a federal funding system that is accountable, but also functional, predictable, and capable of delivering results. The Proposed Rule does not strike that balance. The proposed revisions to the rule dismantle decades of precedent and are not in the national interest. They will also harm my own research and scientific collaborations.