Academy Opposes OMB Proposed Rule: Regulation for Federal Assistance

In comments submitted today to the Office of Management and Budget (OMB), the Academy stated its opposition to the Notice of Proposed Rulemaking (NPRM), Regulation for Federal Financial Assistance, published May 29, 2026 (91 Fed. Reg. 32198).

The Academy's comments request that OMB withdraw the proposed rule to ensure that federal financial assistance continues to support rigorous, evidence-based nutrition and public health research that improves outcomes for all Americans. As drafted, the proposed rule would reduce the volume and reach of federally funded nutrition research, raise the cost and uncertainty of conducting that research, and weaken the scientific foundation the nation needs to reverse the chronic disease epidemic.

The Academy identified seven areas of concern within the proposed rule and shared their impact on basic and applied nutrition science. The Academy provided the following recommendations:

Merit Review and Award Selection (§ 200.205)

• OMB should revise § 200.205 to affirm that scientific peer review by independent content experts remains the primary basis for award determinations in research programs; and any additional review processes must be to evaluate the integrity of the finding, rather than supplant them.

Alignment with Administration Priorities (§ 200.202)

• Clarify that alignment requirements must remain consistent with congressional authorization and appropriations.
• Confirm that alignment requirements will not be applied retroactively to ongoing awards.

Expanded Termination Authority (§ 200.340)

• Limit discretionary termination authority to clearly defined circumstances;
• Require transition periods and safeguards for ongoing research, especially human-subject studies; and
• Provide clear standards and due process protections for recipients.

Elimination of Fixed-Amount Awards (§ 200.333)

• Retain fixed-amount awards for appropriate use cases, particularly pilot studies, demonstration projects, and community-based research.

Payment and Reporting Requirements (§ 200.305)

• Ensure that additional reporting requirements are proportionate and risk-based, and do not create unnecessary administrative burden for low-risk recipients.

Restrictions on Foreign Collaboration (§ 200.220)

• Provide clear definitions and exemptions to ensure that legitimate academic and public health collaborations are not unintentionally restricted.

Cost Allowability and Research Dissemination (Subpart E)

• Preserve the allowability of costs associated with scientific publication and dissemination, professional education and training, and community engagement; and
• Remove indirect cost rate level as a competitive factor in award selection.

Read the Academy's comments