Comment Deadline July 12
This is a red alert for public health practice, health care, and academic research as the feds are proposing new regulations that allow (even instruct) federal agencies to use political criteria to award discretionary federal grants.
Early in this administration, DOGE bros & political appointees (e.g. Kennedy) canceled large numbers of federal research & service grants. The decisions were rushed, ideological, and mostly disconnected from the actual purpose or quality of the work being funded. Often grants were canceled because one of the DOGE bros thought a word in the grant scope was ‘woke’.
The lawsuits that followed overturned many of the DOGE/Kennedy sweeps. Judges mostly overturned those cuts when they believed the federal agency (HHS) didn’t follow rules that are in place at the Office of Management and Budget when they canceled the project.
Now the feds are changing the rules to hard wire that kind of arbitrary decision-making into the OMB rules.
The OMB is proposing a major rewrite of the federal rules that govern grants, cooperative agreements, and other federal financial aid. OMB is calling it the “Uniform Grants Regulation.”
The new political criteria would (will) apply government-wide across dozens of agencies, including HHS, NIH, NSF, HUD, DOJ, FEMA, etc. OMB wants the final rule to take effect October 1, 2026.
Political Appointees Will Decide All
Under the proposed rule, every discretionary grant would have to be approved by a political appointee before it could be awarded. It also says they shall not defer to peer-review recommendations.
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 chance when the OMB rules go into effect this fall. Under the OMB proposed rule political appointees are instructed 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.
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.
The cancelation won’t have 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. Also 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.
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 Submit Your Comment(s): 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, the written record will matter. Judges look at whether agencies considered real-world impacts, explained their choices, and acted reasonably under the law.
