A Choose Your Own Adventure (1)

Generative AI-Disclosure: Sooo... I accidentally wrote 25K words on this topic; I used an LLM to help prune it back to 15K words and make the formatting as easy as possible to navigate.

Contents ('cuz it got kinda long)

• Prologue
• How to Use the Guide(s)
• Bonus screed on 2 CFR 200
• Final Note (for today)
• Tomorrow: pick your player!
• After tomorrow: appendix on PUI stuff

PROLOGUE! (Part 1)

Put it in your calendar:

Public comments are due July 13, 2026. Comments should be submitted through regulations.gov on docket OMB-2026-0034. The docket instructions say to start each part of your comment with the relevant section number in brackets, such as [200.220], [200.340], or [200.333].

What to expect from the whole guide:

The proposed OMB grant regulation changes I wrote about last weekish affect the whole math community. The most useful public comments are specific, personal, and grounded in real consequences; so, I tried to walk a mile in the shoes of a bunch of different community members to see what surfaced to the top of the prioritized "yikes" list for each role.

The guide that will drop tomorrow ("PROFILES! (Part 2)") is designed to help readers find the voice that fits their experience and then write a comment that is not a form letter. My suggested guidance is to check out the profile that best matches you (and read more than one if you wear more than one hat, or if you want to, or whatever). Use your own examples to illustrate the harms the new rules (yes, they will be rules, not guidance!) will create.

You don't need to sound like a lawyer (unless you are a lawyer; in that case, go nuts). The goal is to help OMB understand how the proposed rule would affect real research, real students, real institutions, real communities, and real public benefits.

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RECAP: What is OMB proposing?

(again, but differently)

The Office of Management and Budget (OMB) has proposed a major rewrite of the federal rules governing grants and cooperative agreements. These rules live in 2 CFR Part 200, currently known as the Uniform Guidance (and where the changes that look like [200.???] will go). OMB proposes to rename it the Uniform Grants Regulation and to emphasize that it is legally binding regulation rather than guidance:

• [100.1] The proposal would make the framework more explicitly regulatory, reducing flexibility that agencies and recipients have used to administer awards in context-sensitive ways.

Research Freedom, Scholarly Inquiry, and Translation to Market

• [200.218] Restrictions on disparate-impact liability theories: federal funds could not be used to advance or support disparate-impact liability theories. This affects researchers (and beneficiaries of research) in areas such as algorithmic fairness, discrimination, civil-rights policy, and social inequality.
• [200.300(b)] Restrictions on DEI-related activities and ideological doctrines: the proposal would prohibit the use of federal funds for activities associated with certain DEI frameworks and related concepts. The language is broad enough to create uncertainty for research and educational activities involving inequality, discrimination, demographics, social mobility, public policy, or historical analysis.
• [200.332(i)] Reputational-damage restrictions on subrecipients: prime recipients would be responsible for ensuring that subrecipients do not engage in activities that could significantly damage the reputation of the federal government. This language will have a chilling effect on controversial, high-risk, or publicly critical research.

Integrity of Peer Review and Scientific Merit

• [200.205] Merit review and presidential priorities: Senior political appointees would review funding opportunities before they are issued to ensure they advance presidential priorities and avoid prohibited activities.
• [200.205(d)] Peer review as advisory rather than determinative: The proposal emphasizes that peer review serves an advisory role and does not bind agency decision-makers. Some researchers and scientific organizations worry this could weaken confidence in merit-based funding decisions and increase the influence of political considerations.

International Collaboration and Global Research Networks

• [200.202] Domestic-first research framework: Federal research and development awards would be framed around domestic benefits and national interest, limiting international elements unless they can be justified under that framework.
• [200.220] Covered foreign collaborations: Federal funds could not be used for collaborations with “covered foreign countries” or “covered foreign entities,” with covered countries or entities potentially identified through executive action.

Funding Stability and Award Continuity

• [200.340] Expanded award termination and stop-work authority: Federal agencies would have broader authority to terminate discretionary awards if they no longer align with agency priorities or the national interest. Agencies could also impose temporary stop-work orders, creating uncertainty for ongoing multi-year research projects, students, staff, and collaborators.

Recipient Burden and Administrative Capacity

• [100.1] Binding regulation rather than guidance: The proposal would make the framework more explicitly regulatory, reducing flexibility that agencies and recipients have used to administer awards in context-sensitive ways.
• [200.112] Expanded conflict-of-interest disclosures: Recipients would face additional requirements to identify and disclose potential conflicts of interest, including prior federal employment relationships involving personnel connected to a proposal. Institutions may need new tracking and reporting systems to comply.
• [200.202(g)] Basic, applied, and experimental classifications: The proposal would elevate research classification categories into binding regulatory context, potentially reducing flexibility in fields where projects move fluidly between theory, application, experimentation, and translation.
• [200.204(c)] Statements of Interest (SOIs): Agencies would be encouraged to use short Statements of Interest as an initial screening stage before full proposals are invited. While intended to reduce burden, institutions may disagree about whether this creates a useful simplification or an additional administrative hurdle.
• [200.303(f)] E-Verify: Recipients would be required to participate in E-Verify to confirm employee eligibility.
• [200.333] Fixed-amount subawards: The proposal would eliminate fixed-amount subawards, forcing more activities into actual-cost reimbursement models.

Equity of Access to Federal Research Funding

• [200.205(b)(3)] Preference for lower indirect-cost rates: Merit-review criteria could favor applicants with lower indirect-cost rates. Critics argue this may disadvantage smaller institutions, emerging research programs, and organizations that lack the scale to spread administrative and compliance costs across large research portfolios.

Financial Management, Cash Flow, and Research Operations

• [200.305(c)] Detailed payment justifications: Payment requests may require additional documentation demonstrating specific award-related activities before funds are released. Small businesses and institutions have expressed concern about the effect on cash flow, reimbursement timelines, and administrative workload.

Research Dissemination and Scholarly Communication

• [200.461 and related cost principles] Travel, publication, dissemination, and other research costs: Restrictions or uncertainty around allowable costs could turn ordinary research activities into unfunded mandates for researchers, departments, and institutions.

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How to use the upcoming "PROFILES! (Part 2)" of this guide

I tried to make this as easy as possible to engage with for you. In each section, I try to identify the regulatory sections most likely to matter to an individual in a particular role in the math community. Then I pose oodles of questions to help you generate your own examples. Finally, I wrote (very brief, neutral) sample language you can adapt.

Don't copy the sample language without personalizing it. OMB is more likely to learn from a short authentic comment than from a long generic one. A strong comment might be only three paragraphs:

1. "I am a faculty member / student / administrator / program director / community partner at [blank]."
2. "[200.???] This one very specific proposed change would affect my work in the following concrete way."
3. "For that reason, I urge OMB to revise or withdraw this provision."

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And, as promised, a bonus screed about grants stuff. (I do want to spell this out because I may be the only (math ∩ grants) wonk in your life!)

MOTHERFUNCTING LIES!

Or, "Reducing Recipient Burden"

(yes, those are scare quotes)

This is what I focused on in Congress as a fellow for part of my fellowship. I know the current administrative burdens pretty well, including the ways in which they prevent participation in the grants world. I feel very strongly about access to resources, and my comment (which I'm still editing down to a reasonable length!!!) will focus a lot on this part. (Yours doesn't have to, but prepare to get inspired by my eloquence on the topic...)

One of the stated goals of the proposed rule is reducing administrative burden on grant recipients. But it will increase administrative complexity, compliance costs, and reporting obligations while diverting time and resources away from research itself.

Everyone should be concerned here: academic researchers, students/trainees, research staff, grant admins, department chairs, university leaders, professional societies, SBIR/STTR recipients, community partners, research institutes, philanthropic funders, and federal agencies themselves. Your congressional representatives should be concerned because it definitely affects your congressional district! (Here's how it affects my congressional district! You can use the filters on USAspending.gov to change the congressional district to your district, your state, your county, whatever!)

Anyway: administrative burden is time! It's money! It's the difference between participating in federally funded research vs deciding that compliance costs are too high/risky!

[200.333] Elimination of fixed-amount subawards

The elimination of fixed-amount subawards is a contender for the most consequential administrative change. Fixed-amount subawards efficiently support well-defined activities such as small technical collaborations, workshop support, conference organization, summer programs, specialized consulting, limited-scope research activities, and community partnerships.

The proposed rule would force recipients to manage actual-cost reimbursement systems even for relatively small projects. That means more accounting, more documentation, more monitoring, more staff time, and more opportunities for delay.

Prompts to consider if you are inspired to write about this after my compelling spiel:

• Does your institution use fixed-amount subawards?
• What kinds of activities do those subawards support?
• How much additional accounting and reporting would actual-cost reimbursement require?
• Would faculty and staff spend more time documenting expenses?
• Would smaller institutions, small businesses, or community partners face disproportionate burdens?
• Would the compliance cost exceed the value of the activity?
• Would this make it harder to include small partners in collaborative research?

[200.303(f)] Mandatory E-Verify participation

The proposed E-Verify requirement imposes additional administrative obligations on institutions that routinely hire undergraduate researchers, graduate assistants, postdoctoral scholars, temporary research personnel, and grant-supported staff.

For a large institution, get ready to stand-up a substantial compliance apparatus. For a small college or nonprofit, it's a deal-breaker.

Prompts to consider:

• How many student employees, postdocs, temporary staff, and grant-funded personnel are hired annually?
• What additional training would staff require?
• Would implementation require new software, procedures, or personnel?
• How would onboarding timelines change?
• Would the burden fall on departments, HR offices, sponsored-research offices, or all three?
• How would smaller institutions absorb these additional responsibilities?

[200.202(g)] Research classification requirements

Mathematics and many other disciplines already distinguish among basic, applied, and experimental work when appropriate. My concern is seeing them elevated to binding regulatory categories.

Prompts:

• Does your work move between basic and applied research?
• Would formal regulatory classifications reduce flexibility?
• Could interdisciplinary work become harder to support?
• Would emerging technologies fit neatly into these categories?
• Would researchers be forced to predict in advance how exploratory work will evolve?
• Would classification become another compliance layer rather than a useful scientific description?

[100.1] From guidance to binding regulation

The proposed rule would transform many practices that have historically operated as guidance into binding regulatory requirements. While consistency can be valuable, increased rigidity reduces institutional flexibility, increases compliance costs, requires new oversight systems, creates additional reporting obligations, discourages innovative approaches, and eliminates subject-matter expert discretion and wisdom.

Prompts to consider:

• Are there areas where institutional judgement currently allows efficient administration?
• Would codifying these distinctions as binding regulations create new compliance obligations?
• Would institutions need new oversight mechanisms to ensure regulatory conformity?
• Would small institutions be able to absorb the burden?
• Would federal agencies lose flexibility to administer programs in ways appropriate to different fields?

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Final Publication Note

This guide (today's installment and tomorrow's and to-tomorrow's) is deliberately expansive! There are many legitimate ways to comment on the proposed rule. A good docket does not need thousands of identical comments; it needs many specific comments from people who understand different parts of the research ecosystem.