ASME Comments on OMB’s Proposed Revisions to the Guidance for Federal Financial Assistance

The American Society of Mechanical Engineers (ASME) respectfully submits these comments in response to the Office of Management and Budget’s (OMB) proposed revisions to the Guidance for Federal Financial Assistance (2 C.F.R. Part 200, Docket No. OMB-2026-0034). Founded in 1880, ASME is a not-for-profit professional organization that enables collaboration, knowledge sharing, and skill development across all engineering disciplines while promoting the vital role of the engineer in society. ASME serves more than 70,000 members in the United States and publishes peer-reviewed technical journals, convenes major engineering conferences, and administers internationally recognized codes and standards that underpin the safety of countless engineering systems utilized in everyday life by billions of people around the world each day.

ASME appreciates OMB’s goals of improving transparency, accountability, and efficiency in federal financial assistance programs, and we share the view that federal research investments must deliver clear public value. We also have concerns about several proposed provisions that, if finalized as written, would undermine the foundational mechanisms by which federally funded research is validated, disseminated, and evaluated by federal officials. This letter focuses in particular on three areas critical to the integrity and productivity of the U.S. engineering and science enterprise: (1) the peer review process for merit-based award decisions (§200.205); (2) restrictions on scientific publication costs (§200.461); and (3) limitations on conference, membership, and professional activity costs (§200.432; §200.454).

 

I. The Integrity of Peer Review Is Foundational to U.S. Research Competitiveness (§200.205)

A. Peer Review Ensures Technical Quality and Public Return on Investment

Expert peer review panels draw on the specialized knowledge of researchers who have dedicated careers of knowledge development in their fields. In engineering disciplines, this means evaluating whether a proposed approach to, for example, advanced materials processing, autonomous systems safety, or nuclear reactor design is technically sound, feasible within proposed budgets, and likely to produce replicable, useful results.

Federal science agencies such as the National Science Foundation (NSF), the Department of Energy (DOE), and the Department of Defense (DoD) have developed peer review systems over decades that are widely regarded as international models of merit-based funding. These systems have enabled the United States to lead the world in engineering innovation and have generated enormous returns—from GPS and the internet to modern cancer therapies—on the federal government’s investment in basic and applied research.

ASME recommends that OMB preserve expert peer review as the primary mechanism for meritbased award decisions, consistent with statutory program criteria established by Congress. Oversight roles for senior agency officials and oversight appointees should be focused on programlevel policy alignment, portfolio management, and fraud prevention—not case-by-case pre-issuance review of individual award recommendations. If OMB determines that enhanced oversight of individual awards is warranted in specific circumstances, the rule should establish clear, measurable criteria for triggering such review and should include procedural protections, including mandatory financial disclosures, to prevent conflicts of interest and ensure timely action.

 

B. The “Gold Standard Science” Standard Requires Clearer Definition

The proposed revisions to §200.205 also incorporate agency review requirements tied to the “Gold Standard Science” Executive Order without providing measurable definitions of what that standard requires in practice. For engineering research—which encompasses computational modeling, experimental validation, prototype development, and validation activities—the appropriate methodological standards vary considerably by discipline and application. ASME strongly recommends that OMB either provide clear, discipline-appropriate definitions of the “Gold Standard Science” criteria or limit the application of this standard to contexts where it can be consistently applied and evaluated.

 

II. Restrictions on Publication Costs Would Suppress the Dissemination of Federally Funded Research (§200.461)

The proposed revisions to §200.461 would restrict publication and printing costs allowable under federal awards. ASME is deeply concerned that these restrictions, as currently drafted, contravene federal statutes and directives requiring publication and impede the dissemination of research findings that federal investment has already paid to produce—undermining the return on the taxpayers’ investment and weakening the United States’ position as the world’s leading producer of engineering knowledge.

Publication costs support far more than manuscript formatting and dissemination. Publishers invest substantially in peer-review administration, plagiarism detection, data and image integrity checks, long-term preservation, cybersecurity, and increasingly sophisticated systems designed to detect AIgenerated content, fraudulent submissions, paper-mill activity, and other threats to the integrity of the scholarly record. As these threats grow in scale and sophistication, these quality-assurance functions have become an essential component of research dissemination. Limiting the allowability of publication-related costs could inadvertently weaken the safeguards that protect the credibility and reliability of federally funded research.

 

A. Publication Is the Mechanism by Which Research Delivers Value

Federal investment in research is not complete when an experiment concludes, or a prototype is built. The value of federally funded research is realized only when findings are validated through peer review, published in archival journals, and made accessible to the engineers, manufacturers, policymakers, and researchers who can apply them. Publication costs—including article processing charges, journal submission fees, and costs associated with open-access mandates—are not overhead; they are a necessary final step in the research process itself.

ASME publishes more than 30 peer-reviewed engineering journals covering topics from applied mechanics and heat transfer to manufacturing and energy systems. Publication costs are routinely included as allowable direct costs in grants. Restricting these costs on an agency-wide basis would create an immediate and practical barrier to publishing the results of taxpayer-funded research— contradicting the administration’s stated goal of ensuring that federal dollars serve the needs of the American public. Regardless of the funding model employed, journals depend on sustainable financial support to provide the independent quality assurance, editorial oversight, and scholarly communication infrastructure that underpin the research enterprise and inform decision-making across society.

 

B. Publication Restrictions Are Inconsistent with the Administration’s Public Access Policy

Restricting publication costs under §200.461 would directly conflict with the practical requirements of federal public access and open access policy mandates, placing awardees in an impossible position: required to publish openly, but unable to charge the costs of doing so to their federal awards. Restricting publication costs would also disproportionately burden early-career researchers and smaller institutions without alternative funding sources, and could accelerate the trend of highimpact engineering research migrating to journals and venues based in competitor nations.

U.S. dominance in peer-reviewed engineering and science publication is a strategic national asset. American researchers and institutions consistently lead global publication rankings in high-impact journals, and this leadership shapes international standards, attracts global talent, and establishes U.S. primacy in emerging technologies. ASME recommends that OMB retain publication and printing costs as generally allowable direct costs under federal awards, consistent with current practice. If OMB is concerned about excessive or duplicative publication expenditures, we recommend that OMB address those concerns through targeted guidance on cost reasonableness rather than broad regulation. In particular, OMB should explicitly confirm that article processing charges required for compliance with on-going revisions to federal open access mandates remain fully allowable.

Federal policies should empower researchers to pursue innovative, high-quality scientific inquiry and to disseminate their findings in ways that maximize their public impact. Federally funded researchers should be able to publish in the journals and platforms they determine are most appropriate, free from unnecessary administrative burdens, political influence, or requirements that undermine established intellectual property protections. This principle includes preserving their ability to choose publication venues, retain appropriate copyright interests, and determine the licensing arrangements that govern the use and dissemination of their work.

 

III. Conference and Professional Activity Restrictions Would Impair Research Dissemination and Workforce Development (§200.432; §200.454)

The proposed revisions to §200.432 and §200.454 would impose new prior approval requirements for conferences and limit allowable professional activity costs. ASME urges OMB to reconsider these provisions, which would significantly impair the ability of federally funded researchers to share their findings, engage with the broader technical community, and participate in the professional infrastructure that maintains U.S. engineering competitiveness. We recommend that OMB reject the proposed revisions to §200.432 and make conference attendance generally reimbursable where attendance is consistent with the goals of the overall project.

 

A. Engineering Conferences are Primary Venues for Research Dissemination and Validation

In the engineering disciplines, peer-reviewed conference proceedings are a principal channel through which research findings are first presented, critiqued, and validated by domain experts before formal journal publication. Many of these presentations are subsequently published as peerreviewed conference proceedings, creating a formal scholarly record that is distinct from, and often precedes, publication in journals. ASME’s annual technical conferences—including IMECE, the Turbo Expo, the Pressure Vessels and Piping Conference, and many others—serve as the primary forums where the results of federally funded engineering research are first presented to the global technical community. These conferences are not junkets or professional networking events; they are integral components of the research dissemination pipeline.

Conference participation is particularly critical for graduate students and early-career engineers whose professional development and career trajectories depend on presenting their federally funded research, receiving peer feedback, and establishing relationships with industry and academic mentors. Restricting conference costs would disproportionately affect this population, undermining federal investment in the next generation of the engineering workforce.

ASME recommends that OMB retain conference attendance as generally allowable under federal awards, subject to the existing cost reasonableness and necessity standards in §200.405 and §200.432. If OMB is concerned about specific categories of conference-related spending—such as extravagant venue costs or excessive entertainment—we recommend targeted guidance addressing those specific concerns rather than a blanket prior approval regime. OMB should also explicitly confirm that participation in technical conferences where federally funded research is presented is a standard and allowable component of federal research awards.

 

B. Prior Approval Requirements Would Create Unnecessary Administrative Burden

Imposing prior approval requirements for conference participation would add significant administrative burden to both awardees and federal agencies without commensurate benefit. Conference registrations, travel bookings, and presentation submissions typically occur on timelines that are incompatible with federal prior approval processes. Researchers who submit abstracts to ASME conferences often do so months before conference dates; requiring federal approval at each step would create logistical impossibilities and could force researchers to forfeit conference registrations and travel deposits when approvals are delayed.

Moreover, this approach to oversight is poorly targeted. The existing cost principles in §200.432 already require that conference costs be necessary and reasonable, directly related to the award, and approved in the award budget. These provisions are sufficient to prevent abuse. Prior approval requirements would impose blanket administrative overhead on most legitimate conference participation to address a marginal concern about outlier cases.

 

C. Restrictions on Public Communication of Research Findings

ASME is also concerned about proposed provisions in §200.450 that could restrict researchers’ ability to share scientific findings with the public and engage with policymakers and civil society groups. The distinction between dissemination of scientific results and impermissible lobbying must be clearly drawn in the regulatory text. Federally funded researchers have a legitimate and important role in informing public understanding of technical issues—from resilient infrastructure to cybersecurity risks to human safety. Overly broad restrictions on public communication would deprive policymakers and the public of expert technical input at precisely the moment when evidence-based engineering analysis is most needed.

 

IV. Additional Transformative Provisions 

 

A. Termination Authority (§200.340)

The proposed provision permitting termination of awards at any time based on program alignment with administration priorities introduces severe operational uncertainty for research institutions and the engineering projects they undertake on behalf of the federal government. Multi-year engineering research programs—particularly those involving capital equipment purchases, personnel commitments, and long-lead materials—cannot be wound down without incurring substantial costs and causing harm to the graduate students, postdoctoral researchers, and technicians whose livelihoods depend on award continuity. ASME recommends that any termination authority be exercised only with clear notice, reasonable wind-down periods, and compensation for allowable costs already incurred.

 

B. Foreign Collaboration Restrictions (§200.220)

ASME supports appropriate safeguards to protect sensitive research from foreign adversaries. However, broad restrictions on collaboration with covered foreign entities as currently proposed could impede legitimate scientific exchange that is essential to U.S. innovation leadership and could prevent U.S. researchers from participating in international standardization work that advances American technical leadership globally. ASME recommends a targeted, risk-based approach aligned with national security priorities established by the relevant statutory authorities, rather than broad categorical restrictions that could affect a wide range of legitimate technical collaboration.

 

V. Conclusion

ASME shares OMB’s commitment to ensuring that federal financial assistance programs are administered with integrity, accountability, and efficiency. Federal investment in science and engineering research is one of the highest-return uses of public funds, and the mechanisms that make those investments productive—peer review, publication, and professional exchange—must be preserved and strengthened.

The provisions addressed in these comments would impose significant administrative burdens, delay research dissemination, undermine the integrity of merit-based evaluation, and weaken the professional infrastructure on which U.S. engineering leadership depends. These costs would be borne not by bureaucracies, but by the researchers, graduate students, and institutions through which federal research investments are realized.

ASME urges OMB to revise the proposed rule to:

• Preserve expert peer review as the primary and determinative mechanism for merit-based award decisions;
• Retain publication costs, including article processing charges for open access compliance, as generally allowable direct costs under federal research awards;
• Maintain conference attendance as generally allowable costs, subject to existing reasonableness standards, without new prior approval requirements;
• Clarify that dissemination of scientific and technical findings remains permissible public communication, distinct from lobbying; and
• Provide clear, discipline-appropriate definitions and implementation guidance for any new research quality standards introduced in the regulation.

ASME stands ready to work with OMB, federal research agencies, and the broader scientific and engineering community to develop regulatory approaches that strengthen accountability and efficiency in federal financial assistance while preserving the research dissemination infrastructure that makes U.S. science and engineering the envy of the world. We welcome the opportunity to discuss these comments further.