MOTHERFUNCTOR Guide for "Uniform Grants Regulation" Comment Writing (2/3)
As promised, today you will pick your player to write a comment. It's not perfect, it's not exhaustive, but I tried to give concrete starting points for many perspectives!
A Choose Your Own Adventure, or, PROFILES! (Part 2)
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.
Most of that ended up edited out (although the formatting was helpful), but some of the AI goofiness is probably still there. I eventually did have to clean my house, and the main ideas got through. Yay, mediocrity!
As promised, today you will pick your player. I got carried away, probably. What can I say? It was clean the house or "write my newsletter." Whomst among us hasn't been there?
Looking for a PUI Perspective?
See Part 3: Small Institutions, coming to your inbox Friday morning, which may be useful to:
- Liberal arts colleges
- Primarily undergraduate institutions (PUIs)
- Regional universities
- Minority-serving institutions
- Small nonprofits and community partners
- Institutions with limited sponsored-research infrastructure
- Graduate-school pathways and undergraduate research opportunities
Allons-y to the adventure!
Photo by Javier Martínez on Unsplash
Choose Your Character
| Character | Who This Is For | Key Issues |
|---|---|---|
| The Research Mentor | Faculty researchers, principal investigators, research-active scholars | Collaboration, conferences, dissemination, grant stability |
| The Future Scholar | Undergraduate researchers, graduate students, postdocs, trainees | Research opportunities, graduate-school pathways, career development |
| The Department Administrator | Department chairs, deans, program directors, academic administrators | Hiring, budgeting, compliance, student opportunities |
| The Research Infrastructure Builder | Research scientists, lab managers, technicians, coordinators, grant staff | Operational continuity, staffing, compliance burden |
| The International Collaborator | Researchers whose work depends on global partnerships | International collaboration, research networks, mobility |
| The Public Beneficiary | Community members, taxpayers, public-interest advocates | Public impact, outreach, long-term societal benefits |
| The University Leader | Presidents, provosts, vice presidents, senior administrators | Institutional risk, strategy, financial stewardship |
| The Teaching-Focused Faculty Member | Faculty whose primary mission is teaching and mentoring | Student opportunities, undergraduate research, graduate-school preparation |
| The Early-Career Researcher | Assistant professors, postdocs, newly independent scholars | Tenure timelines, research visibility, career development |
| The Grant Administrator | Sponsored-programs staff, compliance officers, grants managers | Recipient burden, implementation, compliance costs |
| The Industry & Community Partner | Nonprofits, school districts, museums, community organizations, local partners | Workforce development, public benefit, partnerships |
| The Innovation Entrepreneur (SBIR/STTR) | Startup founders, small-business owners, technology-transfer professionals, SBIR/STTR awardees | Commercialization, cash flow, innovation ecosystems |
| The Federal Program Officer | Current or former agency staff, review officers, program managers | Peer review, implementation realities, agency operations |
| The Small Scientific Society Leader | Societies supporting specific communities, journal editors, conference organizers | Conferences, peer review, scholarly communication, DEI |
| The Research Institute Leader | Institute directors | Workshops, visitors, scholarly communities |
| The Philanthropic Research Funder | Foundation leaders | Ecosystem stability, complementary funding, long-term investments |
| The Research Consortium Director | NSF centers, DOE centers, ARCs, AI institutes, quantum centers, multi-institution initiatives | Shared infrastructure, subawards, collaborative research |
The Research Mentor
Who this is for: Academic Researchers and PIs
What I thought of when I pretended to be you
Academic researchers mentor students, build collaborations, organize seminars, create research opportunities, maintain scholarly communities, and form a bridge between federal research investment and the next generation of scholars. Even a modest federal grant can support undergraduate research, conference travel, summer work, software, collaboration, or dissemination that would otherwise be impossible.
Primary sections to consider
- [200.220] Covered foreign collaborations
- [200.461] Travel, publication, dissemination, and related research costs
- [200.340] Expanded federal termination authority
- Optionally: [200.202] Domestic-first R&D framework, [200.205] senior political review of funding opportunities, [200.218] cutting all funding for disparate-impact liability theories.
[200.220] Covered foreign collaborations
Your concern: this proposal will disrupt international collaborations that are essential to mathematical and scientific research.
Prompts:
- What international collaborations have been central to your research?
- Did those collaborations grow out of conferences, workshops, graduate training, sabbaticals, online seminars, or long-term scholarly relationships?
- Would your work have been possible if collaborators could suddenly become off-limits because of executive action?
- Are there countries, institutes, datasets, field sites, archives, conferences, or scientific communities that are essential to your work?
- How would you plan a multi-year grant if a collaboration could become prohibited midway through the project?
- How would this affect graduate students, postdocs, or undergraduate researchers connected to those collaborations?
- What would happen to coauthored work, shared data, joint advising, or multi-institution workshops?
- Would this make U.S.-based researchers less attractive collaborators?
Possible language to adapt:
[200.220] My research depends on sustained international collaboration that I've built over years through shared expertise, trust, and specialized knowledge. A rule that allows covered countries or entities to be identified in ways that can change suddenly would make it much harder to plan responsible multi-year research projects.
[200.461] Travel, publication, and dissemination costs
Your concern: limits or uncertainty around funding for ordinary research dissemination creates unfunded mandates.
Prompts:
- How do conference travel, workshops, and research visits contribute to your work?
- How do students benefit when they present at conferences?
- Do you rely on grant funds for publication fees, open-access charges, page charges, software, data hosting, or dissemination?
- Would you still be expected to disseminate federally funded results if these costs were no longer reliably allowable?
- Who would pay instead: individual researchers, departments, colleges, students, or collaborators?
- Would restrictions fall especially hard on early-career researchers, researchers at smaller institutions, or researchers without discretionary funds?
- In mathematics, how often do collaborations begin through informal conversations at conferences or institutes?
Possible language to adapt:
[200.461] Presenting work, attending conferences, and publishing results are how federally funded discoveries become useful to the broader scientific community. In mathematics, conferences are often the incubator for new research partnerships and directions. If these costs become restricted or uncertain, the proposal will undermine research progress in mathematics.
[200.340] Expanded termination authority
Your concern: expanded termination authority would make long-term research planning riskier and will harm students and staff.
Prompts:
- How far in advance do you plan grant-supported research?
- How many people depend on your grants: students, postdocs, staff, collaborators, or community partners?
- Would you hire differently if an award could be terminated because priorities changed?
- Would you avoid ambitious or long-term projects?
- How would termination affect students whose degree progress depends on continuity?
- How would it affect staff whose jobs are grant-supported?
- Would this make researchers more cautious, less creative, or less willing to take intellectual risks?
- How would your institution absorb salary, equipment, or travel commitments already made?
Possible language to adapt:
[200.340] Federally funded research requires stability. Researchers make commitments to students, staff, collaborators, and institutions based on the expected duration of an award. If awards can be terminated because they no longer align with changing agency priorities or the national interest, then responsible long-term planning is impossible.
[200.202] Domestic-first R&D framework
Your concern: research excellence is not confined by national borders!
Prompts:
- Does your work require global mathematical communities, international conferences, shared datasets, or specialized expertise outside the United States?
- Would a "domestic-first" framework misrepresent how research actually advances?
- Could this reduce the quality, speed, or relevance of U.S. research?
- Would this discourage U.S. researchers from participating in international networks?
- Could students become less prepared for graduate study or careers in global research communities?
Possible language to adapt:
[200.202] A domestic-first research framework does not reflect the way modern scholarship works. The mathematical community is global, and U.S. researchers benefit when they collaborate with scholars and institutions wherever they are located.
[200.205] Senior appointee review and presidential priorities
Your concern: political review of funding opportunities weakens confidence in peer review and scientific independence.
Prompts:
- How would political review of funding opportunities affect peer review and scientific independence?
- Would researchers avoid topics perceived as politically vulnerable?
- How would this affect fields where broader impacts, education, equity, or public engagement are part of the work?
- Would it be harder to advise students about research directions?
- Would uncertainty discourage applications?
Possible language to adapt:
[200.205] The strength of federal research funding depends on confidence that proposals are evaluated through expert review and scholarly merit. Additional political review may discourage researchers from pursuing important work and will weaken confidence in the scientific merit of funded awards.
Closing prompt
Focus on the big picture. What research would be delayed? Which students would lose opportunities? Which collaborations would become impossible? What public benefit would be weakened?
Possible closing sentence:
For these reasons, I urge OMB not to adopt these proposed changes, especially sections [200.220], [200.340], and [200.461], without substantial revision.
The Future Scholar
Who this is for: Grad students, postdocs, undergraduate researchers, and trainees.
What I imagined when I pretended to be you
Federal funding pays for formative experiences for students and trainees: a summer research position, a conference trip, a graduate assistantship, a postdoctoral fellowship, a dissertation project, or access to a mentor. A funded opportunity can be the difference between entering a research career and being priced out of it.
Primary sections to consider
- [200.220] Covered foreign collaborations
- [200.461] Travel, publication, and dissemination costs
- [200.340] Expanded federal termination authority
- Optionally: [200.202] domestic-first framework and [200.205] political review of funding opportunities
[200.220] Covered foreign collaborations
Your concern: students and trainees learn through global research networks.
Prompts:
- Have you worked with an international collaborator?
- Have you attended a seminar, conference, summer school, or workshop involving international scholars?
- Did international collaboration expose you to methods, examples, datasets, or questions you would not have encountered otherwise?
- Would reduced international collaboration make your education narrower?
- Are your mentors, coauthors, committee members, or project partners connected to institutions outside the United States?
- Would uncertainty about covered countries make it harder for your advisor to include you in collaborative research?
- Did international collaboration influence your decision to pursue graduate study or a research career?
Possible language to adapt:
[200.220] International collaborations give trainees access to expertise, problems, and mentoring relationships that are critical for success. Restrictions that make those collaborations unstable will directly reduce training opportunities.
[200.461] Travel, publication, and dissemination costs
Your concern: conference travel and research dissemination are essential for students and early-career researchers.
Prompts:
- Have you presented a poster or talk at a conference?
- Did conference participation help you meet mentors, collaborators, graduate programs, employers, or peers?
- Would you have been able to attend without grant support?
- How would reduced travel funding affect students from less wealthy institutions or backgrounds?
- Have publication, open-access, or dissemination costs affected your ability to share work?
- Would these restrictions make research opportunities less equitable?
- Did a conference, workshop, or research visit help you imagine yourself as a future scholar?
Possible language to adapt:
[200.461] Conference travel and dissemination are part of research training. They are how students learn to explain their work, receive feedback, meet collaborators, and enter professional communities. If these costs become unavailable or uncertain, students will be the first to lose opportunities.
[200.340] Expanded termination authority
Your concern: grant instability can derail training, degree progress, and career plans.
Prompts:
- Is your stipend, summer salary, tuition, travel, or research work funded by a grant?
- How would sudden termination affect your ability to finish a thesis, dissertation, paper, or project?
- Would it change your decision to pursue research?
- Would it affect your financial stability?
- How would it affect students who relocate, choose advisors, or make multi-year plans based on funded projects?
- Would increased uncertainty make research careers seem less viable?
- Would fewer funded graduate positions make graduate school inaccessible to students who can't pay out of pocket?
Possible language to adapt:
[200.340] Students and trainees make major life decisions based on the expectation that funded research projects will continue long enough for us to complete meaningful work. Expanded termination authority would not only affect institutions; it would affect people in training whose education, income, and career development depend on stable research support.
[200.205] Merit review and presidential priorities
Your concern: students need to know that research careers are built on merit, not shifting politics.
Prompts:
- Would you worry that your field or project might become politically disfavored?
- Would this affect what students choose to study?
- Would it discourage work involving education, public engagement, equity, or community impact?
- Would reduced confidence in peer review make a research career feel less stable?
- Would uncertainty affect graduate-school applications or postdoctoral plans?
Possible language to adapt:
[200.205] Students and trainees need confidence that research funding decisions are based on expertise and merit. If funding opportunities become subject to shifting political review, students will question whether research careers are stable enough to pursue.
Closing prompt
What opportunity did research give you? What would you have lost under the proposed rule? What should future students still be able to experience?
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because students and trainees need stable, open, and well-supported research environments.
The Department Administrator
Who this is for: Department chairs at big universities; deans, directors, and administrators.
What I thought of when I pretended to be you
Department leaders and administrators feel the pain of regulatory changes creating new institutional burdens. They know which costs are absorbed by departments and which hardships fall on staff. They also see how federal grants support much more than individual investigators: students, seminars, equipment, staff, outreach, visitors, and curriculum.
Primary sections to consider
- [200.220] Covered foreign collaborations
- [200.340] Expanded termination authority
- [200.461] Travel, publication, and dissemination costs
- [200.303(f)] E-Verify
- [200.333] Fixed-amount subawards
- Optionally: [200.205] senior appointee review and [200.202] domestic-first R&D
[200.220] Covered foreign collaborations
Your concern: the proposal creates significant compliance burdens and planning instability.
Prompts:
- How many faculty, students, or staff in your unit collaborate internationally?
- Would your institution need to monitor changing lists of covered countries or entities?
- How would uncertainty affect memoranda of understanding, exchange programs, joint grants, visiting scholars, conferences, or research centers?
- Would administrators need to review collaborations more frequently?
- Would this delay proposals or make faculty less willing to pursue international work?
- How would small institutions with limited administrative staff handle these burdens?
Possible language to adapt:
[200.220] From an administrative perspective, the proposed restriction on covered foreign collaborations would create uncertainty and compliance burden across ordinary academic activities. Departments and institutions would need to monitor changing federal designations and assess their effect on existing projects, collaborations, personnel, and students.
[200.340] Expanded termination authority
Your concern: broader termination authority undermines hiring, budgeting, staffing, and program planning.
Prompts:
- How do departments plan around multi-year awards?
- Do grants support staff lines, graduate students, postdocs, lecturers, equipment, centers, or outreach programs?
- What happens if an award is terminated after commitments have been made?
- Would your institution become more cautious about hiring grant-supported employees?
- Would departments need to create contingency funds?
- Would this risk be harder for smaller or less wealthy institutions to absorb?
- How would instability affect student support or program continuity?
- Would this make it harder to offer research opportunities to undergraduates?
Possible language to adapt:
[200.340] Departments and institutions make commitments based on federal awards. We hire staff, support students, schedule programs, purchase equipment, and plan multi-year research activity. Expanded termination authority would transfer federal policy instability onto institutions, employees, and students.
[200.461] Travel, publication, and dissemination costs
Your concern: if ordinary research expenses are restricted, costs shift to departments and institutions.
Prompts:
- Does your department subsidize conference travel, publication fees, or research dissemination?
- Would you have the budget to replace grant support if these costs became unallowable or uncertain?
- Would early-career faculty, contingent faculty, students, or staff be most affected?
- Would this create inequities across departments or institutions?
- Would it reduce the visibility and impact of federally funded work?
- Would small departments have to choose between student support and faculty dissemination?
Possible language to adapt:
[200.461] If researchers remain expected to disseminate federally funded work but can't reliably charge reasonable dissemination costs to grants, the costs do not disappear. They create an unfunded mandate for departments, institutions, and individuals.
[200.303(f)] E-Verify and [200.333] fixed-amount subawards
Your concern: administrative burden accumulates at the department level.
Prompts:
- Would implementing or expanding E-Verify require new staff time, training, systems, or compliance review?
- How would this interact with existing hiring processes for students, temporary staff, or grant-funded personnel?
- Would it create delays for grant-funded positions?
- Would small departments or institutions face disproportionate burdens?
- Would eliminating fixed-amount subawards make workshops, consulting, or small collaborations more difficult?
- Who would handle the additional paperwork?
Possible language to adapt:
[200.303(f)] and [200.333] New recipient-wide administrative requirements require staff time, training, and compliance infrastructure. OMB should account for the real costs imposed on departments and institutions, especially those without large central research administration offices.
Closing prompt
End with institutional consequences: What would become more expensive? What would become riskier? Who would absorb the burden? Which students, staff, or faculty would be affected?
Possible closing sentence:
I urge OMB to withdraw or substantially revise these provisions because they would impose significant administrative burden and destabilize responsible institutional planning.
The Research Infrastructure Builder
Who this is for: Research scientists, lab managers, technicians, coordinators, and grant staff.
What I thought of when I pretended to be you
Research infrastructure builders keep projects working. They maintain instruments, data systems, budgets, labs, schedules, collaborations, and compliance workflows. Their expertise is invisible until it disappears! When awards become unstable or requirements become more complex, the burden lands on the staff who hold research programs together.
Primary sections to consider
- [200.340] Expanded federal termination authority
- [200.220] Covered foreign collaborations
- [200.461] Travel, training, publication, and dissemination costs
- Optionally: [200.303(f)] E-Verify and recipient burden provisions
[200.340] Expanded termination authority
Your concern: grant instability affects jobs, continuity, and the people who keep projects running.
Prompts:
- Is your job supported in whole or in part by grant funding?
- What long-term knowledge do you provide to research projects?
- What would happen if a grant ended unexpectedly?
- How would termination affect staff retention?
- Would people leave research support roles if funding became less stable?
- How much time and expertise would be lost if a project had to restart later?
- How would this affect students or faculty who depend on staff expertise?
Possible language to adapt:
[200.340] Research staff are essential to the continuity of federally funded work. We maintain systems, train students, manage data, coordinate logistics, and preserve institutional knowledge. If grants can be terminated more easily because priorities change, the loss is not just financial; projects lose people and expertise that can't be quickly replaced.
[200.220] Covered foreign collaborations
Your concern: international restrictions can disrupt operations, data, logistics, and project management.
Prompts:
- Does your project involve international data, samples, software, equipment, collaborators, or meetings?
- Would changing restrictions require new review procedures?
- Would you need to modify protocols, agreements, data workflows, or communication channels?
- How much staff time would be required to monitor compliance?
- Would uncertainty make project coordination more difficult?
- Would international students or visiting researchers be affected?
Possible language to adapt:
[200.220] International collaboration is not only a faculty concern. Research staff manage the practical infrastructure that makes collaboration possible. Sudden or uncertain restrictions would create operational disruptions, compliance burdens, and delays.
[200.461] Travel, training, publication, and dissemination costs
Your concern: professional development and dissemination keep research operations effective.
Prompts:
- Do you attend trainings, conferences, or technical workshops to maintain skills?
- Does your role require keeping up with standards, software, instrumentation, or compliance practices?
- Are staff involved in preparing publications, reports, datasets, or public-facing materials?
- Would restrictions on these costs reduce project quality?
- Would staff have fewer opportunities for advancement?
- Would staff expertise become harder to maintain?
Possible language to adapt:
[200.461] Travel, training, and dissemination are not luxuries. For research staff, they are how we maintain technical expertise, learn new tools, share best practices, and support high-quality research. Restricting these costs would weaken the infrastructure that grants depend on.
[200.303(f)] E-Verify and recipient burden
Your concern: new requirements create new work for the people already managing research operations.
Prompts:
- Would new verification requirements change hiring workflows?
- Would staff need to create or monitor new compliance processes?
- Would this create delays in hiring grant-funded personnel?
- Would additional reporting requirements reduce time available for project work?
- Would staff need training on new regulatory categories or subaward procedures?
Possible language to adapt:
New administrative requirements do not implement themselves. Each new requirement must be interpreted, communicated, monitored, documented, and enforced. Research staff are the people who make that happen, and the time required comes at the expense of research support.
Closing prompt
End with concrete operational consequences: What work would stop? What expertise would be lost? What delays would occur? Who would need to absorb extra compliance work?
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because stable research funding and reasonable administrative requirements are essential to the people who keep federally funded research functioning.
The International Collaborator
Who this is for: Researchers whose work depends on cross-border collaboration.
What I thought of when I pretended to be you
International collaborators can explain why research is not bounded neatly by national borders. In mathematics and science, collaborators have the right expertise, or maintain the right dataset, or developed the right method, or are part of a specialized community. Sometimes a research problem is unavoidably global. Collaborative relationships take years to build.
Primary sections to consider
- [200.220] Covered foreign collaborations
- [200.202] Domestic-first R&D framework
- [200.340] Expanded federal termination authority
- Optionally: [200.461] travel and dissemination costs
[200.220] Covered foreign collaborations
Your concern: collaboration is built on trust, expertise, and continuity. It can't be turned on and off.
Prompts:
- What international collaborations have shaped your research?
- How long did those collaborations take to build?
- What specialized expertise do collaborators contribute?
- Would the work be possible without them?
- Would uncertainty about covered countries or entities make collaborators less willing to work with U.S. researchers?
- Would projects be interrupted if a country or entity were designated after work began?
- Would students, trainees, or early-career researchers lose opportunities?
- Would this affect conferences, workshops, data sharing, joint advising, or coauthorship?
Possible language to adapt:
[200.220] International collaboration is normal and essential to modern research. Collaborations depend on trust, continuity, and shared expertise. A rule that makes collaborators suddenly ineligible because of changing federal designations will make it much harder to build and sustain serious scholarly partnerships.
[200.202] Domestic-first R&D framework
Your concern: research excellence is not confined by national borders.
Prompts:
- Does your field depend on global expertise?
- Are the best datasets, examples, field sites, archives, instruments, or mathematical communities international?
- Would a domestic-first framework reduce the quality of the research?
- Would it isolate U.S. researchers from important developments?
- Would it slow progress on problems that are global by nature?
- Would it make U.S. institutions less attractive collaborators?
Possible language to adapt:
[200.202] A domestic-first framework does not reflect how research actually advances. U.S. research benefits when scholars are able to collaborate with the best experts and communities in the world. Restricting international elements unless they satisfy a narrow national-interest test risks weakening the research the rule is supposed to protect.
[200.340] Expanded termination authority
Your concern: international projects often require long timelines and stable commitments.
Prompts:
- Does your collaboration involve multi-year planning?
- Would sudden termination damage relationships between institutions?
- Would it affect students or staff in more than one country?
- Would it make international partners reluctant to enter U.S.-funded collaborations?
- Could it strand data collection, field work, workshops, or publications?
- Would it undermine trust in U.S. commitments?
Possible language to adapt:
[200.340] International research projects require stable commitments. If a U.S. award can be terminated because priorities change, international partners may reasonably conclude that U.S.-funded collaborations are too risky to rely on.
[200.461] Travel and dissemination costs
Your concern: international collaboration requires travel and face-to-face exchange.
Prompts:
- Are conferences or research visits essential for maintaining collaboration?
- Would restrictions reduce the ability of collaborators to meet, present, or complete joint work?
- Would early-career researchers be disproportionately affected?
- Would this reduce U.S. participation in international research networks?
- Would virtual communication fully replace in-person workshops, field work, or research visits?
Possible language to adapt:
[200.461] International collaboration requires communication, trust, and sustained scholarly exchange. Travel and dissemination support can make those collaborations possible, especially for students and early-career researchers.
Closing prompt
End with what would be lost: a collaboration, a student opportunity, a research community, or a project that only works because of international expertise.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because they would weaken the international collaborations that make U.S. research stronger.
The Public Beneficiary
Who this is for: Community members and others who benefit from federally funded research.
What I thought of when I pretended to be you
Federal research funding affects people and communities through medical research, education, workforce development, environmental monitoring, technology, small business innovation, local jobs, public data, public tools, and partnerships among universities, schools, nonprofits, governments, and communities. You don't need technical expertise to explain why stable public-interest research matters!
Primary sections to consider
- [200.218] Prohibition of Disparate-Impact Liability Theories
- [200.300] "Unlawful DEI" and other provisions
- [200.340] Expanded federal termination authority
- [200.461] Travel, publication, and dissemination costs
- Optionally: [200.220] covered foreign collaborations and [200.202] domestic-first R&D framework
[200.218] Prohibition of Disparate-Impact Liability Theories
Your concern: discrimination based on disproportionate effects or disparities in outcomes between different groups is a real phenomenon.
Prompts:
- Do you belong to a group who faces unfair hurdles that others don't face?
- Have you experienced discrimination that led to poorer healthcare or other public services?
- Are there long-term problems in your community that would be best served by studying social structures and disparate impacts?
Possible language to adapt:
[200.218] Prohibiting research into injustice doesn't serve the public. Our society is stronger when we understand the differences that shape our experiences and work to fix broken systems.
[200.300(b)] "Unlawful DEI"
Your concern: eliminating programs that support mathematicians from underrepresented groups will reverse progress we've made on including the "missing millions" in STEM. Innovation requires the broadest possible pool of talent.
Prompts:
- Is there a person you know (including yourself!) who would make a great mathematician but chose to pursue something else because the field felt unwelcoming?
- Are there problems you face that would be best understood by someone that shares your experience, and would that perspective make scientific research more relevant to you?
Possible language to adapt:
[200.300(b)] We all benefit when more people are encouraged to pursue math and science. Different perspectives strengthen innovation and discover different strategies and even different problems. Supporting groups who face barriers to entering the math profession is a direct way to support U.S. innovation.
[200.340] Expanded termination authority
Your concern: communities need stable research, not projects that can disappear because priorities shift.
Prompts:
- Has federally funded research affected your health, school, workplace, community, or local economy?
- Has a university, lab, nonprofit, or research center partnered with your community?
- Would sudden loss of funding interrupt services, data collection, outreach, or education?
- Are there long-term problems in your community that require sustained research?
- Would instability make it harder to trust or participate in federally funded projects?
- Would local jobs, internships, or educational programs be affected?
Possible language to adapt:
[200.340] Communities benefit when federally funded research is stable enough to produce results, maintain partnerships, and follow through on commitments. Expanded termination authority may interrupt projects that communities rely on and make it harder for researchers to build trust with the public.
[200.461] Travel, publication, and dissemination costs
Your concern: research only helps the public when it can be shared, explained, and translated.
Prompts:
- Have you benefited from public reports, workshops, educational materials, community meetings, or research-based tools?
- Why is it important for researchers to share findings outside their own institution?
- Would restrictions on dissemination make research less useful to the public?
- Do conferences and professional meetings help spread ideas that later benefit communities?
- Would local partners lose access to training or outreach?
Possible language to adapt:
[200.461] The public benefits from research when findings are shared. Dissemination costs support communication, education, publication, and collaboration. Treating these costs as optional would make federally funded research less useful to the communities it is meant to serve.
[200.220] Covered foreign collaborations and [200.202] domestic-first framing
Your concern: some public problems require international knowledge and cooperation.
Prompts:
- Is the issue you care about global, such as disease, climate, technology, migration, food systems, or education?
- Would international collaboration help solve it faster or better?
- Would restricting collaboration reduce public benefit?
- Would domestic-first framing exclude expertise that could help your community?
- Would the public benefit if U.S. researchers were more isolated?
Possible language to adapt:
[200.220] Public problems don't necessarily stop at national borders. Research that benefits communities can depend on international knowledge, shared data, and collaboration. Restrictions that make collaboration unstable can slow work that matters to the public.
Closing prompt
End by saying what you want protected: stable research partnerships, public access to findings, student and workforce opportunities, health, education, environmental, or economic benefits.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because federally funded research serves the public best when it is stable, open, and able to reach the communities that need it.
The University Leader
Who this is for: Presidents, provosts, vice presidents, deans, and senior academic leaders responsible for institutional strategy, financial stability, and federal relationships.
What I thought of when I pretended to be you
University leaders balance educational missions, research priorities, financial stewardship, workforce development, compliance obligations, and long-term institutional planning. Federal grants support research, student opportunities, faculty recruitment and retention, research infrastructure, community partnerships, regional economic activity, and institutional reputation. Changes that increase uncertainty or administrative burden affect the entire institution.
Primary sections to consider
- **[200.300(b)] "Unlawful DEI"
- [200.340] Expanded termination authority
- [200.205] Presidential-priority review
- [200.220] Covered foreign collaborations
- [200.461] Travel, publication, and dissemination costs
- [200.333] Fixed-amount subawards
- Recipient burden
[200.300(b)] "Unlawful DEI"
Your concern: your mission involves supporting students from underrepresented groups, and your faculty excel at mentoring students.
Prompts:
- How do your facult support underrepresented groups in mathematics?
- Why does support for this kind of mentoring matter to your institution?
- What have exceptional students gone on to do?
Possible language to adapt:
[200.300(b)] The mission of our university is to support students in achieving their dreams, whatever they are. Federal funds help us encourage talented students to pursue STEM opportunities.
[200.340] Expanded termination authority
Your concern: institutional planning depends on predictable federal commitments.
Prompts:
- How many students, employees, and programs depend on federal awards?
- How would expanded termination authority affect budgeting and hiring?
- Would institutions need larger reserves to manage risk?
- Would this affect faculty recruitment and retention?
- Could long-term initiatives become harder to launch?
- Would governing boards become more risk-averse?
- Would institutions at different resource levels be affected differently?
Possible language to adapt:
[200.340] Universities make long-term commitments based on the expectation that federal awards will remain stable throughout their intended duration. Expanded termination authority shifts policy risk onto institutions, students, and employees.
[200.205] Presidential-priority review
Your concern: universities depend on confidence in federal funding programs.
Prompts:
- Would additional political review increase uncertainty?
- Could it affect institutional investments in emerging fields?
- Would it reduce confidence in peer review?
- Might researchers avoid important topics perceived as politically vulnerable?
- Would universities hesitate to create programs around federal priorities that could shift abruptly?
- Would this affect faculty recruitment or retention?
Possible language to adapt:
[200.205] Universities depend on transparent and predictable funding systems. Additional political review risks creating uncertainty that may discourage investment in promising areas of research and scholarship.
[200.220] Covered foreign collaborations
Your concern: international partnerships are core institutional assets.
Prompts:
- How many exchange programs, partnerships, and collaborations rely on international engagement?
- Would changing designations create compliance challenges?
- Could student and faculty opportunities be reduced?
- Would recruitment of international talent become more difficult?
- Would the institution need additional monitoring systems?
- Would international partners become less willing to collaborate?
Possible language to adapt:
[200.220] Universities build international partnerships over decades. Policies that create uncertainty around collaboration weaken research, education, student opportunity, and institutional relationships that can't be quickly rebuilt.
[200.461], [200.333], and recipient burden
Your concern: costs and burdens shift to institutions.
Prompts:
- Would dissemination or travel costs shift to institutional budgets?
- Could smaller institutions absorb these costs?
- Would dissemination become less equitable?
- How many collaborations rely on streamlined subaward mechanisms?
- Would eliminating fixed-amount subawards increase institutional costs?
- Would compliance burdens reduce funds available for students or academic programs?
Possible language to adapt:
[200.461] and [200.333] When federal rules restrict ordinary research costs or remove efficient administrative mechanisms, the costs do not disappear. They are shifted to institutions, departments, faculty, students, and partners. Institutions with fewer resources will feel these shifts most acutely.
Closing prompt
Focus on institutional stability, student opportunity, responsible stewardship, long-term planning, and the ability of institutions of different sizes to participate in federally funded research.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because institutions need stable awards, trusted peer review, and manageable administrative requirements in order to serve students, researchers, and the public effectively.
The Teaching-Focused Faculty Member
Who this is for: Faculty members whose primary responsibility is teaching, mentoring, advising, and creating opportunities for students.
What I thought of when I pretended to be you
Teaching-focused faculty are the primary point of contact between students and the research enterprise. Even when they aren't federally funded PIs, they create research opportunities, mentor students, advise career choices, supervise independent projects, and connect students with scholarly communities. Changes to federal grant regulations affect research activity and the educational opportunities that emerge from that activity.
Primary sections to consider
- **[200.300(b)] "Unlawful DEI"
- [200.340] Expanded termination authority
- [200.461] Travel, publication, and dissemination costs
- [200.220] Covered foreign collaborations
[200.218] Prohibition of Disparate-Impact Liability Theories
Your concern: discrimination based on disproportionate effects or disparities in outcomes between different groups is a real phenomenon. You or your colleagues study these phenomena and teach students about them to help them understand their worlds.
Prompts:
- Do you belong to a group who faces unfair hurdles that others don't face?
- Have you experienced discrimination that led to poorer healthcare or other public services?
- Are there long-term problems in your community that would be best served by studying social structures and disparate impacts?
Possible language to adapt:
[200.218] Prohibiting research into injustice doesn't serve the public. Our society is stronger when we understand the differences that shape our experiences and work to fix broken systems. It's important for students to encounter these research programs to understand the language and scholarly context.
[200.300(b)] "Unlawful DEI"
Your concern: eliminating programs that support mathematicians from underrepresented groups will reverse progress we've made on including the "missing millions" in STEM. Innovation requires the broadest possible pool of talent.
Prompts:
- Is there a person you know (including yourself!) who would make a great mathematician but chose to pursue something else because the field felt unwelcoming?
- Are there problems you face that would be best understood by someone that shares your experience, and would that perspective make scientific research more relevant to you?
Possible language to adapt:
[200.300(b)] We all benefit when more people are encouraged to pursue math and science. Different perspectives strengthen innovation and discover different strategies and even different problems. Supporting groups who face barriers to entering the math profession is a direct way to support U.S. innovation.
[200.340] Expanded termination authority
Your concern: students benefit from continuity.
Prompts:
- How many students participate in grant-supported activities?
- How would instability affect undergraduate research opportunities?
- Would students lose access to mentors, projects, or professional development?
- Would departments become more hesitant to create student opportunities?
- Would summer research programs become harder to plan?
- Would students applying to graduate school lose research experiences that strengthen their applications?
- At a teaching-focused institution, would losing a small grant have a larger educational effect than the dollar amount suggests?
Possible language to adapt:
[200.340] Students often experience the benefits of federally funded research through mentoring, independent projects, and research experiences. Increased uncertainty surrounding grant continuation may reduce the opportunities available to students and weaken the connection between teaching and scholarship.
[200.461] Travel, publication, and dissemination
Your concern: faculty bring new ideas back into the classroom.
Prompts:
- How do conferences improve teaching?
- How do professional meetings expose faculty to new methods and ideas?
- How do students benefit when faculty participate in scholarly communities?
- Have conference experiences led to new courses, projects, examples, or student opportunities?
- Would faculty at teaching-focused institutions have fewer discretionary resources to replace grant support?
- Would students lose opportunities to present their own work?
Possible language to adapt:
[200.461] Conferences and scholarly communication are important not only for research but also for teaching. Faculty regularly bring new ideas, examples, methods, and professional connections back to their students. Restrictions on dissemination and professional engagement would ultimately affect educational quality.
[200.220] Covered foreign collaborations
Your concern: international scholarship enriches education.
Prompts:
- How do students benefit from exposure to international research communities?
- Have international collaborations created opportunities for students?
- Would restrictions narrow students' academic experiences?
- Would students at smaller institutions lose access to broader networks?
- Would international speakers, conferences, or workshops be harder to involve in teaching?
- Would this affect students who hope to pursue graduate study?
Possible language to adapt:
[200.220] Students benefit when faculty participate in international scholarly communities. These connections expose students to diverse perspectives, research traditions, and opportunities that can't be replicated within a single institution.
Closing prompt
Focus on student opportunities, mentoring, career preparation, intellectual growth, and the connection between scholarly engagement and undergraduate education.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because students benefit most from educational environments that are connected to vibrant, stable, and collaborative research communities.
The Early-Career Researcher
Who this is for: Assistant professors, postdocs, newly independent investigators, and scholars building research programs.
What I thought of when I pretended to be you
Early-career researchers often have fewer resources and less institutional flexibility than established investigators. They are building research programs, establishing collaborations, mentoring students for the first time, and navigating promotion or tenure timelines. Policy uncertainty frequently affects them first and most severely.
Primary sections to consider
- [200.340] Expanded termination authority
- [200.205] Merit review and presidential priorities
- [200.461] Travel, publication, and dissemination costs
- [200.220] Covered foreign collaborations
[200.340] Expanded termination authority
Your concern: new research programs require stability.
Prompts:
- Are you currently building a research program, laboratory, or long-term scholarly agenda?
- Have you recently received your first external grant or are you actively seeking one?
- How far in advance do you plan research projects?
- How would uncertainty affect your willingness to hire students, postdocs, or research staff?
- Would you be less likely to pursue ambitious, long-term projects if awards could be terminated due to changing priorities?
- How would instability affect your progress toward promotion, tenure, or career advancement?
- Would you be more likely to pursue safe projects instead of innovative ones?
- How would funding uncertainty affect your ability to recruit collaborators?
- How does working at an institution with limited internal funding or limited sponsored-research support make stability especially important?
Possible language to adapt:
[200.340] Early-career researchers make long-term commitments based on the expectation that awarded funding will remain stable. Increased uncertainty surrounding award continuation disproportionately affects researchers who are still building laboratories, collaborations, and research programs.
[200.205] Merit review and presidential priorities
Your concern: early-career researchers rely on transparent and stable review processes.
Prompts:
- How important is confidence in peer review when deciding where to invest your research effort?
- Would additional political review create uncertainty about how proposals are evaluated?
- Would you hesitate to pursue certain topics because they might be perceived as politically disfavored?
- How important is it that funding decisions be viewed as fair and merit-based?
- Would uncertainty about agency priorities affect your willingness to submit proposals?
- Could reduced confidence in merit review discourage students or postdocs from pursuing research careers?
- Would junior scholars self-censor their research agendas?
Possible language to adapt:
[200.205] Early-career researchers often have limited opportunities to establish themselves professionally. Any reduction in confidence in the merit-review process may discourage innovative research and create uncertainty about how proposals will be evaluated.
[200.461] Travel and dissemination
Your concern: visibility is career development.
Prompts:
- How important have conferences been in building your professional network?
- Did you meet collaborators, mentors, or future employers through conferences?
- Have invited talks, conference presentations, or publications helped establish your professional reputation?
- How important is conference participation when seeking promotion, tenure, or future employment?
- Would reduced travel support affect your ability to become known in your field?
- How would restrictions on dissemination affect researchers at teaching-focused institutions with limited discretionary funds?
- Would early-career researchers be affected differently than senior scholars?
- Would reduced conference participation limit invitations, collaborations, or letters of support?
Possible language to adapt:
[200.461] Conference participation and dissemination are essential mechanisms through which early-career researchers build professional networks, establish collaborations, and gain visibility within their disciplines.
[200.220] Covered foreign collaborations
Your concern: collaborations often define careers.
Prompts:
- Are any of your collaborators based outside the United States?
- Did those collaborations begin during graduate school, postdoctoral training, conferences, or workshops?
- How important are international networks to your field?
- Would uncertainty regarding covered countries discourage future collaborations?
- How would changing restrictions affect long-term research planning?
- Would early-career researchers be less able to absorb disruptions than established investigators?
- How would these restrictions affect students and trainees working with you?
Possible language to adapt:
[200.220] Many early-career researchers build professional networks through international collaboration. Restrictions that create uncertainty around those relationships may limit opportunities for career development and scholarly growth.
Closing prompt
Focus on career development, mentoring students, building research programs, long-term planning, and the disproportionate effects of uncertainty on people without large reserves of funding, staff, or institutional flexibility.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because early-career researchers need stable, transparent, and merit-based systems in order to build the next generation of research programs.
The Grant Administrator
Who this is for: Sponsored-programs staff, compliance officers, grants managers, and research administrators.
What I thought of when I pretended to be you
Grant administrators are responsible for translating regulations into practice. They manage compliance, reporting, subawards, audits, training, and institutional risk. They are often the first people who can identify whether a proposed regulation will actually reduce burden or merely shift it to already stretched offices.
Primary sections to consider
- [200.220] Covered foreign collaborations
- [200.303(f)] E-Verify
- [200.333] Fixed-amount subawards
- [200.340] Expanded termination authority
[200.220] Covered foreign collaborations
Your concern: compliance is operational.
Prompts:
- How would your institution identify and monitor covered countries and covered entities?
- What new systems, policies, training programs, or review procedures would be required?
- How frequently would lists need to be updated and communicated?
- Would departments require additional support to remain compliant?
- How much staff time would implementation require?
- How would institutions manage collaborations that begin before a designation changes?
- Would compliance costs fall disproportionately on smaller institutions?
- Would faculty understand their obligations without substantial training?
Possible language to adapt:
[200.220] Institutions would need new systems to monitor changing covered-country and covered-entity designations, assess existing collaborations, and communicate compliance requirements to faculty and staff. These obligations represent significant administrative costs.
[200.303(f)] E-Verify
Your concern: new compliance obligations require infrastructure.
Prompts:
- 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?
- Would short-term student research positions become more difficult to administer?
Possible language to adapt:
[200.303(f)] New E-Verify requirements would require additional compliance infrastructure, training, oversight, and documentation. OMB should carefully consider whether these costs are justified by the anticipated benefits.
[200.333] Fixed-amount subawards
Your concern: this may be the largest administrative burden increase in the proposal.
Prompts:
- How frequently does your institution use fixed-amount subawards?
- What types of activities are supported through these mechanisms?
- How much additional accounting and documentation would actual-cost reimbursement require?
- Would faculty spend more time managing paperwork?
- Would smaller collaborations become harder to administer?
- Would the additional burden discourage participation by smaller institutions or community partners?
- How many additional staff hours might be required?
- Would actual-cost reimbursement be disproportionate for small, well-defined activities?
Possible language to adapt:
[200.333] Eliminating fixed-amount subawards would significantly increase administrative burden by requiring actual-cost reimbursement and expanded documentation even for limited-scope activities that currently can be administered efficiently.
[200.340] Expanded termination authority
Your concern: termination creates administrative work.
Prompts:
- What processes would be required to close out an award unexpectedly?
- How would institutions manage personnel whose salaries depend on terminated awards?
- What reporting obligations would arise?
- How would departments handle commitments already made to students, staff, or collaborators?
- Would institutions need new contingency planning procedures?
- How would this affect budgeting and financial forecasting?
- How much additional administrative effort would be required?
- Would agencies provide resources for these new closeout burdens?
Possible language to adapt:
[200.340] Expanded termination authority would create substantial administrative challenges associated with managing project closures, reallocating resources, supporting affected personnel, and ensuring compliance with federal requirements during award termination.
Closing prompt
Focus on administrative efficiency, compliance costs, implementation realities, institutional capacity, and the way new requirements affect faculty and students indirectly through staff workload.
Possible closing sentence:
I urge OMB to revise or withdraw provisions that increase administrative burden without clear research benefit, especially where the burden falls disproportionately on smaller institutions and lean sponsored-research offices.
The Industry & Community Partner
Who this is for: Businesses, nonprofits, school districts, museums, government agencies, and community organizations.
What I thought of when I pretended to be you
Federal research funding supports a wide ecosystem that extends beyond universities. Community and industry partners often host students and interns, participate in collaborative projects, help translate research into practice, build local workforce pipelines, and deliver public benefit. These partners can explain what happens when research instability reaches outside the campus.
Primary sections to consider
- [200.340] Expanded termination authority
- [200.461] Dissemination and outreach
- [200.220] Covered foreign collaborations
[200.340] Expanded termination authority
Your concern: partnerships depend on trust and continuity.
Prompts:
- Does your organization participate in federally funded projects?
- What would happen if those projects ended unexpectedly?
- Would future partnerships become harder to establish?
- Would community trust be damaged?
- Would workforce programs be disrupted?
- Would your organization hesitate to invest staff time in future projects?
- Would students, interns, patients, clients, or local residents be affected?
Possible language to adapt:
[200.340] Successful partnerships depend on stable commitments. Expanded termination authority may disrupt ongoing collaborations and make community organizations less willing to invest time and resources in future research partnerships.
[200.461] Dissemination and outreach
Your concern: research only matters if people can use it.
Prompts:
- Have you benefited from workshops, reports, training programs, or educational materials?
- Would reduced dissemination funding make research less useful?
- How important is communication between researchers and the public?
- Would outreach activities become harder to sustain?
- Would your organization lose access to training or technical assistance?
- Would research become more isolated from practice?
Possible language to adapt:
[200.461] Communities benefit from research when findings are communicated effectively. Dissemination costs support public engagement, training, outreach, and knowledge transfer that allow federally funded research to generate real-world impact.
[200.220] Covered foreign collaborations
Your concern: many public challenges are international.
Prompts:
- Does your organization rely on international expertise, standards, or data?
- Would collaboration restrictions affect innovation or problem solving?
- Could valuable partnerships disappear?
- Do global supply chains, global health, climate, migration, education, or technology standards affect your work?
- Would U.S.-based projects become less informed by global best practices?
Possible language to adapt:
[200.220] Many of the challenges faced by communities and industries are global in nature. Restrictions that create uncertainty around international collaboration may reduce access to expertise, data, and partnerships that help generate solutions.
Closing prompt
Focus on public benefit, economic development, workforce development, community trust, practical use of research, and long-term partnerships.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because strong research partnerships create lasting benefits for communities, industries, and the public.
The Innovation Entrepreneur (SBIR/STTR)
Who this is for: Small-business owners, startup founders, technology-transfer professionals, SBIR/STTR awardees, incubator leaders, and innovation ecosystem partners.
What I thought of when I pretended to be you
SBIR and STTR programs are designed to translate federally supported research into products, services, jobs, and economic growth. These programs depend on stable federal funding, predictable review processes, collaboration between universities and businesses, and the ability to disseminate and commercialize discoveries. Small firms do not have the administrative cushion of large institutions, so uncertainty and compliance burden can be decisive.
Primary sections to consider
- [200.340] Expanded termination authority
- [200.205] Presidential-priority review
- [200.220] Covered foreign collaborations
- [200.461] Travel, dissemination, and commercialization-related costs
- [200.333] Fixed-amount subawards, where relevant to partnerships
[200.340] Expanded termination authority
Your concern: startups and small businesses often make hiring and investment decisions based on expected grant support.
Prompts:
- Would investors view federally funded projects as riskier?
- Would your company hire fewer employees?
- Would uncertainty discourage commercialization?
- Could projects fail because funding becomes unreliable?
- Would milestones promised to partners, customers, or investors become harder to meet?
- Would uncertainty reduce the value of SBIR/STTR as a bridge between research and market?
Possible language to adapt:
[200.340] Small businesses use SBIR and STTR funding to bridge the gap between research and commercialization. Increased uncertainty around grant continuation makes it more difficult to hire employees, attract investment, and bring innovations to market.
[200.205] Presidential-priority review
Your concern: political review may increase uncertainty for innovative but unconventional projects.
Prompts:
- Would startups avoid pursuing certain technologies?
- Would changing political priorities make commercialization planning harder?
- Could investors become less willing to support grant-dependent innovation?
- Would novel or interdisciplinary technologies be harder to categorize and defend?
- Would small firms have less capacity to navigate uncertainty than large companies?
Possible language to adapt:
[200.205] Innovation depends on predictable and merit-based evaluation. Small businesses can't easily absorb uncertainty about whether promising technologies will remain aligned with shifting political priorities.
[200.220] Covered foreign collaborations
Your concern: innovation ecosystems are often international.
Prompts:
- Do you rely on international suppliers, collaborators, customers, or technical expertise?
- Could changing restrictions complicate product development?
- Would compliance costs burden small firms disproportionately?
- Would international standards, testing, or markets be affected?
- Would uncertainty slow technical development?
Possible language to adapt:
[200.220] Some small businesses operate in international innovation ecosystems involving suppliers, technical experts, standards bodies, customers, and research partners. Uncertainty around covered collaborations will create compliance burdens that small firms are poorly positioned to absorb.
[200.461] Dissemination and commercialization
Your concern: commercialization requires visibility, demonstration, and translation.
Prompts:
- How important are conferences, trade shows, demonstration events, and publications?
- Would restrictions slow technology transfer?
- Would they reduce the visibility of emerging companies?
- Would firms have fewer opportunities to find partners, customers, or investors?
- Would this slow the movement of federally funded discoveries into public use?
Possible language to adapt:
[200.461] Commercialization requires dissemination. Conferences, demonstrations, technical meetings, and publications help small firms find partners, customers, investors, and users. Restricting these activities would slow the movement of federally supported discoveries into the public sphere.
Closing prompt
End by describing what innovation produces: jobs, new technologies, economic development, public benefits, and commercialization of federally funded discoveries.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because successful innovation requires stable partnerships, predictable funding, and the ability to move discoveries from the laboratory into the public sphere.
The Federal Program Officer
Who this is for: Current and former program officers, grants officers, scientific review officers, agency staff, peer-review administrators, and research program managers.
What I thought of when I pretended to be you
Federal program officers occupy a unique position in the research ecosystem. They build and manage research portfolios, support peer review, maintain program continuity, monitor award performance, ensure accountability, connect agency priorities with scientific expertise, and facilitate productive relationships between agencies and award recipients. Because they work at the intersection of policy and implementation, they are well positioned to identify unintended consequences that may not be apparent from the text of a regulation alone.
Primary sections to consider
- [200.205] Merit review and presidential-priority review
- [200.340] Expanded termination authority
- [200.220] Covered foreign collaborations
- [100.1] Uniform Grants Regulation framework
- Recipient burden and agency burden
[200.205] Merit review and presidential-priority review
Your concern: trusted review processes are essential to agency credibility and program quality.
Prompts:
- How would additional political review affect agency operations?
- Would review timelines become longer or more uncertain?
- Would researchers become less willing to submit proposals?
- Would confidence in peer review be weakened?
- Could emerging or unconventional fields face greater barriers?
- Would program officers spend more time on clearance and less on scientific stewardship?
- Would reviewers be less willing to serve if they believed review outcomes could be overridden for political reasons?
Possible language to adapt:
[200.205] Program officers are already responsible for balancing scientific merit, agency priorities, and portfolio management. Additional review requirements should be evaluated carefully to determine whether they improve outcomes or merely increase administrative complexity.
[200.340] Expanded termination authority
Your concern: stable awards help agencies build successful portfolios.
Prompts:
- Would broader termination authority change how awards are managed?
- Would agencies become more risk-averse?
- Would investigators become less willing to pursue ambitious projects?
- How would termination affect agency credibility?
- Would long-term programs become harder to sustain?
- Would program officers have to manage more conflict, appeals, or closeout complexity?
- Would this make recruitment of reviewers and panelists harder?
Possible language to adapt:
[200.340] Successful research programs require stable expectations for both agencies and award recipients. Expanded authority to terminate awards based on changing priorities may create uncertainty that discourages long-term planning and weakens confidence in federal funding programs.
[200.340] Program officers frequently encourage investigators to pursue ambitious and innovative work. Greater uncertainty surrounding award continuation may unintentionally incentivize more conservative research portfolios.
[200.220] Covered foreign collaborations
Your concern: implementation complexity may be substantial.
Prompts:
- Would compliance requirements become difficult to administer?
- How would agencies monitor changing designations?
- Would uncertainty affect existing awards?
- Could collaborations be disrupted mid-project?
- Would program staff need to adjudicate complicated collaboration questions?
- Would agencies need new guidance, systems, or legal review processes?
Possible language to adapt:
[200.220] International collaboration is a normal feature of modern research. Program officers may face significant implementation challenges if covered-country or covered-entity designations change during the lifespan of active awards. OMB should carefully consider the operational consequences of such uncertainty.
[100.1] Uniform Grants Regulation framework and agency burden
Your concern: administrative requirements affect agencies as well as recipients.
Prompts:
- Would new requirements require additional agency staffing?
- Would review timelines become longer?
- Would agencies need new guidance and training?
- Would administrative costs increase without corresponding benefits?
- Would converting guidance into binding regulation reduce useful discretion?
- Would agency personnel have less flexibility to respond to disciplinary differences?
Possible language to adapt:
[100.1] Federal research programs vary substantially across agencies and disciplines. OMB should ensure that efforts to create consistency do not unintentionally eliminate the flexibility needed for effective program administration.
Although the proposal emphasizes reducing recipient burden, administrative requirements also create burden for federal agencies. New compliance obligations may require additional oversight, training, monitoring, and documentation while reducing the time available for program development and scientific stewardship.
Closing prompt
Federal program officers can speak uniquely to how policy decisions translate into implementation realities. Emphasize trusted peer review, stable awards, administrative flexibility, operational realities, and confidence in federal research programs.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because effective research administration depends on trusted peer review, stable award management, operational flexibility, and regulatory requirements that support rather than impede the federal research enterprise.
The Small Scientific Society Leader
Who this is for: Officers and board members of professional societies, conference organizers, journal editors, disciplinary coalitions, and leaders of scholarly communities and organizations.
What I thought of when I pretended to be you
Professional societies are part of the infrastructure of research. They organize conferences and workshops, publish journals, support mentoring and professional development, create research networks, connect students with the broader community, facilitate peer review, and disseminate research findings. In mathematics particularly, conferences, workshops, institutes, and professional meetings are often where collaborations begin and difficult problems are solved.
Primary sections to consider
- [200.300(b)] "Unlawful DEI"
- [200.461] Travel, conferences, publication, and dissemination
- [200.340] Award stability and termination
- [200.205] Merit review and presidential-priority review
- [200.220] Covered foreign collaborations
- Recipient burden and administrative complexity
Prohibition of Disparate-Impact Liability Theories
#### [200.218] Prohibited disparate-impact research
Your concern: your society is dedicated to these issues.
Prompts:
- How has federal funding supported members of your society?
- How has your society benefitted the profession and public by supporting this work?
Possible language to adapt:
[200.218] Prohibiting research into injustice doesn't serve the public. The success and impact of our society and its members illustrate the importance of this work.
[200.300(b)] "Unlawful DEI"
Your concern: eliminating programs that support mathematicians from underrepresented groups will reverse progress we've made on including the "missing millions" in STEM. Innovation requires the broadest possible pool of talent. Your society is dedicated to supporting a specific underrepresented group in mathematics.
Prompts:
- How have the contributions of your society members benefitted society thanks to their unique perspectives and understanding?
- Are there problems your members face that would be best understood by someone that shares your experience, and would that perspective make scientific research more relevant to them?
Possible language to adapt:
[200.300(b)] We all benefit when more people are encouraged to pursue math and science. Different perspectives strengthen innovation and discover different strategies and even different problems. Supporting groups who face barriers to entering the math profession is a direct way to support U.S. innovation.
[200.461] The nature of mathematical collaboration
Your concern: mathematical research depends heavily on communication and collaboration.
Prompts:
- How do conferences contribute to discovery?
- How do workshops and research institutes create collaborations?
- How important are meetings for students and early-career researchers?
- What role do publications play in advancing the discipline?
- How many collaborations begin at society-sponsored meetings?
- Would restrictions on travel or dissemination disproportionately affect fields where conversation is the main research infrastructure?
Possible language to adapt:
[200.461] Mathematical research depends on sustained intellectual exchange. Conferences, workshops, seminars, and publications are not ancillary activities; they are essential components of the research process itself.
[200.461] Professional societies provide much of the infrastructure through which research communities communicate and collaborate. Policies that restrict support for conferences, meetings, and dissemination would weaken the mechanisms through which federally funded research generates impact.
[200.340] Award stability and termination
Your concern: research communities require stability to organize conferences, maintain scholarly programs, support students, and plan collaborative activities.
Prompts:
- How far in advance are conferences and programs planned?
- Would instability affect commitments to venues, speakers, and participants?
- How might uncertainty affect mentoring and professional-development programs?
- Would students lose opportunities?
- Would societies hesitate to co-sponsor activities with federal awardees?
- Would community-wide programs become harder to sustain?
Possible language to adapt:
[200.340] Scholarly communities rely on stable funding environments. Expanded authority to terminate awards based on shifting priorities creates uncertainty that can ripple through conferences, collaborative programs, mentoring initiatives, and other community-wide activities that require long-term planning.
[200.205] Merit review
Your concern: the federal research enterprise depends on expert peer review.
Prompts:
- Why is expert peer review essential?
- How does trust in peer review affect the discipline?
- Could political review discourage participation in federal programs?
- Would confidence in funding decisions be weakened?
- Would reviewers be less willing to serve?
- Would early-career researchers become more cautious in their research agendas?
Possible language to adapt:
[200.205] The strength of the federal research enterprise rests on rigorous peer review by experts capable of evaluating scholarly merit, feasibility, and potential impact. Additional political review risks undermining confidence in a process that has long been regarded as one of the strengths of the American research system.
[200.220] Covered foreign collaborations
Your concern: mathematics is an international discipline.
Prompts:
- How international is your membership?
- How many collaborations begin at society-sponsored meetings?
- Would uncertainty weaken research networks?
- Could international participation decline?
- Would students and early-career researchers lose access to global communities?
- Would society programs need new compliance review?
Possible language to adapt:
[200.220] Mathematical research is inherently international. Professional societies play an important role in connecting researchers across institutions and national borders. Restrictions that create uncertainty around international collaboration risk weakening research networks that have taken years or decades to build.
Recipient burden and administrative complexity
Your concern: societies often operate as lean nonprofit research infrastructure.
Prompts:
- Would additional compliance obligations affect conferences or publications?
- Would smaller societies be able to absorb the burden?
- Would societies need new review procedures for participants, speakers, or partners?
- Would administrative complexity reduce time available for mentoring, programming, and dissemination?
- Would society-sponsored workshops become harder to support?
Possible language to adapt:
Professional societies provide essential research infrastructure, often with limited administrative capacity. New compliance obligations should be evaluated not only for their legal purpose but also for their effect on conferences, publications, mentoring programs, and scholarly communication.
Closing prompt
Professional societies are uniquely positioned to explain why conferences matter, why peer review matters, why funding stability matters, why excessive administrative burden is counterproductive, and why international collaboration strengthens research.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because a healthy research ecosystem depends on robust scholarly communication, stable funding, expert peer review, international collaboration, and administrative requirements that support rather than impede research.
The Research Institute Leader
Who this is for: Directors, deputy directors, program officers, scientific organizers, and leaders of research institutes and organizations.
What I thought of when I pretended to be you
Research institutes are built around exactly the activities most affected by this proposal: conferences, workshops, visiting researchers, international collaboration, research dissemination, and long-term scholarly communities. For many institutes, bringing people together is not merely support for research. It is the research process.
Primary sections to consider
- [200.461] Travel, conferences, publication, and dissemination
- [200.220] Covered foreign collaborations
- [200.340] Expanded termination authority
- [200.333] Fixed-amount subawards, where relevant
- Recipient burden and administrative complexity
[200.461] Conferences and research communication
Your concern: research institutes exist to facilitate intellectual exchange.
Prompts:
- How do workshops generate new collaborations?
- How do conferences contribute to discovery?
- How important are visiting researchers to the institute's mission?
- How do students and early-career researchers benefit from participation?
- Would limits on travel or dissemination alter the core function of the institute?
- Would programs become less accessible to participants without institutional resources?
Possible language to adapt:
[200.461] Conferences, workshops, and visiting researcher programs are not peripheral activities. They are central mechanisms through which new collaborations form, ideas are tested, and research communities advance knowledge. Restrictions that make these activities more difficult to support would directly weaken the research ecosystem.
[200.220] Covered foreign collaborations
Your concern: research institutes routinely host international participants.
Prompts:
- What proportion of participants come from outside the United States?
- Would uncertainty about covered countries affect planning?
- Would it discourage participation?
- Could existing programs be disrupted?
- Would organizers need to screen participants differently?
- Would international scholars be less willing to commit to programs?
Possible language to adapt:
[200.220] Research institutes play an important role in connecting scholars across institutions and national boundaries. Uncertainty regarding covered countries or entities will significantly disrupt long-term planning and reduce opportunities for international collaboration.
[200.340] Award stability
Your concern: institutes frequently plan programs years in advance.
Prompts:
- How far ahead are workshops scheduled?
- What commitments are made to speakers and participants?
- How would instability affect long-term programming?
- Would cancellation harm early-career researchers who planned around participation?
- Would it undermine confidence among participants, funders, and partner institutions?
Possible language to adapt:
[200.340] Institutes often commit to multi-year programming that depends on stable funding expectations. Increased uncertainty regarding award continuation would make long-term planning substantially more difficult.
Recipient burden and administrative complexity
Your concern: research institutes often operate with lean staffing structures while supporting large scholarly communities.
Prompts:
- Would additional compliance obligations require new staff?
- Would workshops require additional review procedures?
- Would participation become more administratively difficult?
- Would resources be diverted from programming to compliance?
- Would smaller institutes be able to absorb new requirements?
- Would fixed-amount subaward changes affect workshop or program partnerships?
Possible language to adapt:
Administrative requirements that appear modest on paper can significantly affect research institutes whose primary mission is creating opportunities for collaboration, discovery, and scholarly exchange. OMB should consider how new requirements would affect institutes with lean staffing and national or international program responsibilities.
Closing prompt
Focus on scholarly community building, conference infrastructure, international collaboration, long-term planning, student and early-career researcher opportunities, and the administrative realities of running an institute.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because research institutes need stable funding, international participation, and manageable administrative requirements in order to support the collaborative infrastructure of discovery.
The Philanthropic Research Funder
Who this is for: Foundation presidents, program officers, board members, and leaders of organizations.
What I thought of when I pretended to be you
Private philanthropy is an essential complement to federal research funding. Foundations often support emerging fields, seed high-risk ideas, build research communities, sustain long-term initiatives, and fill gaps in the funding ecosystem. Because philanthropic funders often work alongside federal agencies, they have a unique perspective on how policy changes affect the broader research enterprise.
Primary sections to consider
- [200.340] Expanded termination authority
- [200.205] Merit review and presidential-priority review
- [200.220] Covered foreign collaborations
- [200.461] Dissemination and scholarly communication
[200.340] Award stability
Your concern: philanthropic funding frequently supplements or complements federal awards.
Prompts:
- Would increased instability require foundations to fill funding gaps?
- Would long-term initiatives become harder to sustain?
- Would uncertainty reduce the effectiveness of philanthropic investments?
- Would co-funded programs become riskier?
- Would foundations shift away from partnerships with federal awardees?
- Would promising early-stage fields lose continuity?
Possible language to adapt:
[200.340] Federal funding is most effective when it provides a stable platform upon which philanthropic organizations can build. Increased uncertainty regarding award continuation may reduce the effectiveness of both public and private investments in research.
[200.205] Merit review
Your concern: strong research ecosystems depend on trusted evaluation processes.
Prompts:
- Why is expert review important?
- How does uncertainty affect long-term investment decisions?
- Would confidence in the research enterprise be weakened?
- Would foundations have to compensate for gaps created by shifting federal priorities?
- Would politically sensitive but scientifically important fields become harder to support?
Possible language to adapt:
[200.205] Both public and private research funders depend upon confidence in expert evaluation and scholarly merit. Preserving trust in merit review is essential to maintaining a healthy and innovative research ecosystem.
[200.220] International collaboration
Your concern: many foundations intentionally support international research networks.
Prompts:
- Would restrictions reduce the impact of philanthropic investments?
- Would global research communities become more fragmented?
- Could important collaborations disappear?
- Would U.S.-based researchers become less connected to foundation-supported international networks?
- Would foundations need to redesign programs around compliance uncertainty?
Possible language to adapt:
[200.220] Many scientific advances emerge through international networks of researchers. Policies that create uncertainty around collaboration may reduce the impact of investments intended to strengthen global scientific communities.
[200.461] Dissemination and scholarly communication
Your concern: philanthropic impact often depends on community building and communication.
Prompts:
- Do foundation programs support conferences, networks, publications, or institutes?
- Would federal restrictions weaken complementary philanthropic programs?
- Would dissemination costs shift to philanthropy?
- Would foundations be asked to fund activities federal grants no longer support?
- Would public-private funding become less efficient?
Possible language to adapt:
[200.461] Philanthropic research funding often complements federal investments by supporting networks, meetings, dissemination, and community building. Restrictions on ordinary dissemination costs may shift additional burdens to private funders and reduce the combined effectiveness of public and private research investments.
Closing prompt
Focus on complementarity between public and private funding, long-term investments, research ecosystem health, scientific innovation, and the danger of shifting federal instability onto philanthropy.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because federal funding should provide a stable platform that philanthropic investments can complement, not an unstable system that private funders must continually patch.
The Research Consortium Director
Who this is for: Directors of multi-institution research centers, ARCs, AI institutes, quantum centers, NSF centers, DOE centers, engineering research centers, and other collaborative initiatives spanning multiple organizations.
What I thought of when I pretended to be you
Research consortia exist to solve problems that no single institution can solve alone. They often coordinate multiple universities, industry partners, government agencies, community organizations, international collaborators, shared infrastructure, and workforce development programs. As a result, administrative complexity and uncertainty can affect these organizations especially strongly.
Primary sections to consider
- [200.220] Covered foreign collaborations
- [200.340] Expanded termination authority
- [200.333] Fixed-amount subawards
- Recipient burden and administrative complexity
[200.220] Covered foreign collaborations
Your concern: large collaborative projects often involve many partners.
Prompts:
- How many institutions participate?
- Would changing restrictions require restructuring collaborations?
- Could active projects be disrupted?
- Would compliance obligations multiply across partners?
- Would the lead institution need to monitor every collaborator differently?
- Would uncertainty discourage smaller or international partners from participating?
Possible language to adapt:
[200.220] Multi-institution collaborations require substantial planning, coordination, and trust. Uncertainty regarding covered-country or covered-entity designations may create significant implementation challenges for large collaborative initiatives.
[200.340] Award stability
Your concern: consortia frequently support shared infrastructure, workforce development, and multi-year strategic goals.
Prompts:
- How many organizations depend on a single award?
- What would happen if funding ended unexpectedly?
- How would workforce development programs be affected?
- Would shared infrastructure be stranded?
- Would partner commitments become liabilities?
- Would center staff, students, postdocs, or industry partners be affected?
Possible language to adapt:
[200.340] Large collaborative initiatives often support multiple institutions, shared infrastructure, workforce development programs, and long-term strategic objectives. Funding instability can have consequences far beyond a single organization.
[200.333] Fixed-amount subawards
Your concern: research consortia frequently manage large numbers of subawards.
Prompts:
- How many subawards flow through the center?
- How much additional accounting would be required?
- Would smaller partners become harder to support?
- Would administrative costs increase significantly?
- Would actual-cost reimbursement create delays?
- Would partners with limited administrative capacity withdraw?
Possible language to adapt:
[200.333] Eliminating fixed-amount subawards would substantially increase administrative burden for collaborative centers and research consortia. Activities that can currently be managed efficiently may require significantly greater accounting, monitoring, and documentation.
Recipient burden
Your concern: administrative costs compound across large collaborations.
Prompts:
- How many institutions would be affected by a new compliance requirement?
- Would smaller partners struggle to participate?
- How much staff time would be required across the consortium?
- Could administrative complexity discourage collaboration?
- Would the lead institution have to absorb more risk?
- Would burden fall unevenly across partners?
Possible language to adapt:
Requirements that appear modest for a single institution may become substantial when multiplied across many partners. OMB should carefully consider the cumulative burden imposed on collaborative research enterprises.
Closing prompt
Focus on multi-institution collaboration, shared infrastructure, workforce development, administrative complexity, long-term scientific goals, and how burdens multiply across partners.
Possible closing sentence:
I urge OMB to revise or withdraw these provisions because large-scale collaborative research depends on stable funding, manageable administrative requirements, and the flexibility necessary to coordinate complex partnerships across institutions and sectors.
A Simple Comment Template
Use this if you want a short structure for your own comment.
I am writing as a role at institution/organization/community. My work involves brief description.
[Relevant section number] This proposed change would affect students/research/staff/collaborators/community/industry because specific example.
In my experience, tell a concrete story: a student who presented at a conference, a collaboration that took years to build, a subaward that made a workshop possible, a grant-funded staff member who keeps a project running, a public partner who depends on research findings.
The likely consequence is lost opportunity, increased cost, delayed research, reduced participation, administrative burden, weakened collaboration, fewer funded graduate pathways.
For these reasons, I urge OMB to withdraw/revise/clarify this provision.
MF's reminders to you, dear reader-writer, are:
- Be specific; write from your experience.
- Use section numbers in brackets before your comments.
- Explain who is harmed and how; do not rely only on abstract objections!
- A short comment with a real example is better than a long comment that could have been written by a bot!
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