The Honorable Russell Vought
Director
Office of Management and Budget
Washington, DC 20503
Re: OMB-2026-0034, Office of Management and Budget Regulation for Federal Financial Assistance
Submitted via regulations.gov
Dear Director Vought:
The Ad Hoc Group for Medical Research, a coalition of nearly 600 organizations representing patients, scientists, health professionals, academic and research institutions, educators, and industry supporting funding for the National Institutes of Health (NIH), appreciates the opportunity to comment on the proposed revisions to the Uniform Guidance.
Medical research depends on a federal funding system that is rigorous, transparent, predictable, and stable. Scientific research frequently spans many years, relies on highly specialized personnel and infrastructure, and often requires sustained collaboration among institutions. We are therefore particularly concerned that several provisions of the proposed rule could unintentionally slow the timely issuance of federal awards, reduce the stability of awarded funding, and undermine the continuity that is essential for successful medical research. Although we recognize the Administration’s interest in strengthening stewardship and oversight of federal funds, we urge OMB to ensure that these objectives are achieved without disrupting the efficient operation of the nation’s medical research enterprise.
Proposed § 200.205 (Pre-Issuance Review). We are concerned that the addition of a new pre-issuance review by senior political appointees for all discretionary awards will substantially lengthen the time between scientific peer review and award issuance. The proposed rule provides that peer review recommendations would remain advisory and would be subject to an additional level of review before awards are finalized. Scientists already have experienced delays over the past two fiscal years due, at least in part, to the implementation of the new review processes which are being codified and expanded in this proposal.
Click here to view The Ad Hoc Group for Medical Research’s full Comments on OMB’s Proposed Uniform Guidance Revisions
