Unless you are trying to enjoy a bit of your summer (in which case, why are you reading this?), you have probably read elsewhere about the Office of Management and Budget (OMB) proposed federal financial assistance regulation and how disastrous it is for math (and basically everything).¹

Given the extensive and excellent coverage listed in the Suggested Reading (footnote 1), why should you read what I have to say about this? Well... as an AAAS STP fellow in Congress, I helped draft this bill about grants and its committee report I helped organize this hearing about grants; all of that involved intensely studying and understanding the code of federal regulations pertaining to grants and previous attempts at doing the things OMB says it wants to do (and lots more). I became part of the unofficial "CBASS Appreciation Society" because Clint Bass at the Congressional Research Service has been covering this beat for a long time. After my year working for Senator Peters' HSGAC staff, I spent a year as an AAAS STP fellow in the grantmaking agency for math, NSF!

So, my one-pager about the 108 page proposal is at the end of this entry. There's much to lament, but the big changes will be to 2 CFR 200, outlined in Section VI.

But first: July 13, 2026 is the deadline to leave a comment on the regulations.gov docket. The most important thing is that your comment relates specifically to your mathematical story, and, with that context, why the new regulations are a TERRIBLE FUCKING IDEA.

General Template

Start with the sections you are responding to, included in brackets like [200.220]²

• A sentence in your own words about your general concerns.

• For each section, a sentence or paragraph explaining how it would affect your past successes had it been in place then.

• A sentence in your own words about your general concerns, again.

• Your name (and affiliation, if you choose to provide it)

What to expect next

The next email installment from me, sometime next week, will include what I would write about from the different perspectives (an R1 researcher; a grad student/postdoc; a SBIR/STTR grant recipient; etc).

Throughout the summer, I will write some explainers for the interested mathematical reader about agency rulemaking, the difference between guidance (what we have now) and a rule (what OMB proposes), the terrifying prospect of OMB/OIRA/any president having concentrated and extreme power over grants (imagine losing a collaborator overnight because Trump decided to call out their country in an executive order).³

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What's in the B[OMB]?

I. Executive Summary

OMB proposes revising 2 CFR to "improve transparency and oversight for taxpayer dollars", "clarify that OMB's policies are legally binding regulations rather than just guidance", and "reduce recipient burden".

MF's note: the only true part of that sentence is that OMB wants to make 2 CFR 200 legally binding to consolidate power in the executive branch.

It also aims to get rid of any whiff of "woke" policies, ending any DEI-related spending because of inconsistency with administration priorities.

MF's note: specifically administration priorities and not Congressional priorities. FYI, Broader Impacts in NSF grants are mandated by a law passed by Congress.

II. Background and Regulatory History

This section traces the evolution of Federal grant management from the first Circulars in 1958 to the establishment of the Uniform Guidance in 2013.

It explains that massive growth in Federal assistance now warrants a shift to ensure oversight keeps pace with spending.

MF's note: again, this is bullshit. There are plenty of GAO reports and Congressional hearing testimony about the oversight burdens that already exist, and adding more "oversight" is not a great idea. You can already check out what's being spent on what over at USASpending.gov.

III. Statutory Authority

OMB cites various authorities, including 31 U.S.C. 503 and the Transparency Act, which authorize the Deputy Director for Management to provide leadership on financial management and set government-wide requirements for grants and audits.

MF's note: ... you already know what I'm going to say. Editorial commentary from me ends here and the rest is a clean section-by-section.

IV. OMB Objectives for 2026 Proposed Revisions

• Objective 1: Transparency, Accountability, and Oversight: Proposed changes include eliminating fixed-amount awards, requiring merit-based selection, and increasing oversight of subrecipients to prevent fraud and wasteful spending

• Objective 2: Clarification of Regulatory Structure: OMB proposes renaming Part 200 the "Uniform Grants Regulation" (UGR) and removing language classifying it as "guidance" to emphasize its status as a binding regulation

• Objective 3: Reducing Recipient Burden: The rule seeks to streamline the application process by requiring all opportunities to be posted on Grants.gov and removing ideological mandates

V. Regulatory Impact Analysis (RIA)

The RIA evaluates the qualitative benefits and modest administrative costs associated with these reforms, such as the transition away from fixed-amount subawards and the implementation of new payment accountability measures

VI. Section-by-Section Discussion of Subtitle A Revisions

This is the most detailed part of the proposal, outlining specific changes to the Code of Federal Regulations.

• Part 1: Formally designates Subtitle A as "regulation" instead of guidance

• Parts 25 & 170: Updates requirements for the Unique Entity Identifier (UEI) and transitions all subaward reporting to SAM.gov

• Part 180 & 182: Clarifies that agencies must not deviate from government-wide debarment, suspension, and drug-free workplace requirements

• Part 200, Subpart A (Definitions): Removes definitions for "fixed amount awards" and "Protected PII" to align with broader policy shifts

• Part 200, Subpart B (General Provisions):

  • Conflicts of Interest (§ 200.112): Requires recipients to disclose if employees working on a proposal were employed by the awarding agency within the previous two years

  • Mandatory Disclosures (§200.113): Requires Inspectors General to transmit fraud disclosures to the U.S. Attorney’s Office within 10 days

• Part 200, Subpart C (Pre-Award Requirements):

  • Research and Development (§200.202): Establishes a "domestic-first" framework for R&D awards, limiting international elements to those in the national interest

  • Merit Review (§200.205): Mandates a pre-issuance review by senior appointees to ensure awards advance presidential priorities and do not fund discriminatory DEI initiatives

  • Prohibited Equipment (§200.216): Implements the American Security Drone Act of 2023, prohibiting the procurement of certain foreign-made unmanned aircraft systems

  • Disparate-Impact Liability (§200.218): Prohibits using Federal funds to support theories of "disparate-impact liability," which the rule argues encourages unlawful discrimination

  • Covered Foreign Collaborations (§200.220): Prohibits Federal funds for collaborations with covered foreign countries or entities (e.g., foreign adversaries)

• Part 200, Subpart D (Post-Award Requirements):

  • National Policy (§ 200.300): Explicitly prohibits funding for unlawful DEI practices, gender ideology, and sex-transition procedures for minors; protects faith-based organizations from discrimination

  • Internal Controls (§ 200.303): Requires all recipients to participate in E-Verify to confirm employee eligibility

  • Award Termination (§ 200.340): Expands Federal authority to terminate discretionary awards if they no longer align with "Federal agency priorities" or the "national interest"

• Part 200, Subpart E (Cost Principles): Unallowable Costs: Adds explicit prohibitions on costs for voter registration, issue advocacy, and elective abortions

VII. Discussion of Revisions to Subtitle B

This section covers conforming changes by specific agencies (e.g., HHS, DHS, EPA) to adopt OMB's new regulatory framework into their own agency-specific chapters

VIII–X. Severability, Indirect Costs, and Comments

The rule establishes that its provisions are severable (meaning they can be dealt with separately if one is unenforceable or deemed illegal)

• No updates to the indirect cost rate negotiation system are being proposed currently

• Finally, it requests public comments by July 13, 2026