Public Feedback Highlights Concerns with OMB Uniform Guidance Revisions

The White House Office of Management and Budget’s (OMB) proposed revisions to the Uniform Guidance (2 C.F.R. Part 200) have generated an unusually strong response from the research, higher education, nonprofit, and professional society communities. During the public comment period, a large number of organizations, institutions, associations, and individual stakeholders submitted comments expressing concerns about the proposed rule and its potential impact on federal research, innovation, education, and workforce development activities.  

The proposal would substantially revise the government-wide framework governing federal grants, cooperative agreements, and other forms of federal financial assistance. The rulemaking attracted criticism from a broad coalition of stakeholders, including universities, scientific and engineering organizations, nonprofit associations, and research advocacy groups, many of which urged OMB to reconsider or significantly revise portions of the proposal before issuing a final rule. 

Common concerns raised by commenters focused on provisions that would expand Executive Branch oversight of discretionary awards, impose new certification and compliance requirements, restrict certain international collaborations, and broaden agency authority to suspend or terminate federal awards. Many stakeholders also warned that changes affecting peer review, research dissemination, publication costs, conference participation, and scientific communications could increase administrative burdens and reduce the effectiveness of federal research investments. 

ASME participated in the rulemaking process by submitting formal comments to OMB on July 13. While supporting the goals of accountability, transparency, and responsible stewardship of taxpayer resources, ASME raised concerns that several provisions could undermine merit-based peer review, impede the dissemination of scientific and engineering research, and create significant new administrative burdens for award recipients. 

ASME Comment on Proposed Revisions to 2 C.F.R. Part 200 (Uniform Guidance) 

OMB is currently reviewing the public comments received and is expected to determine whether to issue a final rule, modify the proposal, or undertake further revisions. Given the broad role of the Uniform Guidance in federal research, education, manufacturing, workforce development, and technology programs, the outcome of this rulemaking could have significant implications for organizations across the U.S. engineering and scientific enterprise. 

ASME will continue to monitor developments and provide updates as the rulemaking process advances.