Comment Deadline July 12
Early in this administration, DOGE bros & political appointees (e.g. Kennedy) canceled large numbers of federal research & service grants. The decisions were knee-jerk, ideological, and mostly unrelated to the purpose or quality of the work being funded.
Grants were often canceled because one of the DOGE bros or Kennedy thought a word in the scope of work was ‘woke’.
The lawsuits that followed overturned many of the DOGE/Kennedy sweeps. When judges overturned the cuts often did it because the federal agency (HHS) didn’t follow Office of Management and Budget (OMB) rules when they canceled the project.
Now the feds are changing the OMB rules so they can summarily cancel grants without judges overturning their decision.
How?
By rewriting the OMB federal rules that govern grants, cooperative agreements across the executive branch to make it so they can do basically whatever the political appointees want. OMB is calling it the “Uniform Grants Regulation.”
The new political criteria would (will) apply across the executive branch to dozens of agencies, including all the HHS agencies plus NIH, NSF, HUD, DOJ, FEMA, etc. OMB wants the final rule to take effect October 1, 2026.
Political Appointees Would Decide All
Under the already proposed rule, every discretionary grant would have to be approved by a political appointee before it could be awarded. The political appointee shall not defer to peer-review or expert recommendations.
The proposed rule instructs political appointees to make sure the grants advance the President’s policy priorities and that they can’t “promote anti-American values” (which is undefined).
The proposed rule even requires applicants to commit to what OMB calls the administration calls “Gold Standard Science”, which also doesn’t have an objective definition.
For decades, agencies like HHS and NIH have relied on independent experts to evaluate research proposals. They look at the question being asked, the quality of the methods, whether the work is likely to produce useful results, and whether the research team can do the job. Technical stuff.
All that would change once the OMB rules go into effect this fall.
Grants Could Be Cancelled Mid-Project for Political Reasons
The proposed rule also gives federal agencies broad new authority to end a discretionary award during the middle of a project. A grant could be ended if an agency decides that it no longer advances agency priorities or “the national interest.”
No finding of fraud, waste, abuse, or noncompliance would be needed, just a finding by the political appointee (e.g. Kennedy) that she or he thinks the research isn’t in the national interest.
There would be no due process and there wouldn’t need to be an administrative hearing or appeal process.
For example, a university could hire researchers and staff, enroll study participants, build a data system, and begin a multi-year project, only to have a political appointee determine the project isn’t in the national interest.
Same with just about any other cooperative agreement with a state and the pass-through money that goes to county health.
States & Counties Would Become Federal Compliance Officers
As if that’s not enough… the rule basically deputizes states and counties to also follow the federal OMB rules and even apply them to their subrecipients.
State governments get lots of money that they then pass through to county health departments, universities, hospitals, and nonprofit organizations.
Under the proposal, the state and pass-through entities would have to build the federal conditions into their own subgrants.
Why Your Comments Matter
AzPHA submitted comments on the proposed rule already but ADHS, county health departments, universities, hospitals, and others should file comments too. Nonprofits too. Your comments will be better than mine.
You can explain what grants you manage. Explain the people you serve. Explain what would happen if a project were cancelled halfway through.
Explain how political screening of research would affect your ability to recruit staff, plan programs, enroll participants, or partner with communities. Explain that the new rules give political appouintees like Kennedy to be arbitrary and capricious in their decision-making.
Reference the part of the proposed rule that concerns you. For example:
- Section 200.205: political review of discretionary awards and peer review.
- Section 200.206: expanded “risk” reviews, including organizational affiliations.
- Section 200.300: new federal conditions flowing down to subrecipients.
- Sections 200.340 through 200.343: termination, suspension, and limited due process.
- Section 200.450: restrictions on issue advocacy and public messaging.
Comments are due by July 13, 2026, through Regulations.gov under docket OMB-2026-0034. Here’s the Link to comment: OMB-2026-0034 Regulations.gov
View AzPHA Comments on OMB 2026 0034 Grant Award Rule (Regulation for Financial Assistance)
Suggestions for How to Comment on Federal Regulations
View the Proposed Rule: Federal Register: Regulation for Federal Financial Assistance
Your comments will become part of the public record. That’s important even if OMB ignores them. When this rule is challenged in court, your comments will matter.
Judges look at whether agencies considered real-world impacts, explained their choices, and acted reasonably under the law when they wrote the regulation.
