Comment on Proposed Rule for Federal Financial Assistance

This proposed rule is a 100+ page proposed regulation that does several things simultaneously, and the DEI rollback is one of many disturbing aspects. The public comment page is here, scroll down for a template you can modify and copy/paste as desired. 

Summary
This regulation essentially rewrites the government-wide framework for managing federal financial assistance including grants, cooperative agreements, and related forms of federal funding.

What it does structurally
The rule consolidates power for grantmaking under OMB instead of the federal agencies related to the grant function.

Since 2013, the OMB rules governing federal grants (called "Uniform Guidance") were exactly that — guidance. Agencies had flexibility in how they implemented them. This rule converts guidance into binding OMB regulation. That means OMB, a White House office controlled by the president, now has direct regulatory authority over every federal grant across every agency. Future amendments to grant rules would go through OMB alone, not through individual agencies. One office, controlled by political appointees, governing all federal financial assistance.

The most dangerous provision is the "pre-issuance review" — every discretionary grant must now be reviewed by senior political appointees before it can be awarded. Peer review by scientific experts becomes purely "advisory." A political appointee can overrule the scientists and deny funding for any reason that doesn't align with "the President's policy priorities."

That means research on climate change, environmental health, public health disparities, gun violence, reproductive health — anything that contradicts the administration's political agenda — can be defunded not through Congress but through a political appointee's veto at the grant review stage. The research never happens. The data never gets collected. The knowledge never exists.

The DEI and gender ideology provisions:
The rule explicitly prohibits federal funds from being used for anything the administration defines as DEI activities, "gender ideology," or what it calls "child sex mutilation",  their term for gender-affirming care for minors. 

Gender-affirming healthcare is funded through multiple federal channels — NIH research grants studying gender dysphoria treatment, Medicaid covering transition-related care, HRSA community health centers providing services. This rule gives the administration a mechanism to defund all of it simultaneously across every agency without needing to pass a law or win a court case. Just deny the grants at the pre-issuance review stage.

For trans people who depend on federally funded healthcare for hormones, mental health services, and medical care, this could mean clinics lose funding and close. Providers stop offering services. Research into best practices stops. The infrastructure of care disappears not through a ban but through the quieter mechanism of defunding.

The rule also prohibits grants to organizations that promote "gender ideology", a term deliberately left vague enough to encompass virtually any organization that acknowledges trans people exist. Homeless shelters that house trans people according to their gender identity. Domestic violence organizations that serve trans women. Mental health providers who offer gender-affirming therapy. All of these receive federal grants. All of them could lose funding.

The broader issue:
The rule also allows agencies to terminate existing grants mid-stream if funding "no longer aligns with program goals, agency priorities, or the national interest." That language is broad enough to cancel virtually any grant for any political reason. Combined with the pre-issuance political review, it creates a system where new grants require political approval and existing grants can be terminated at political will.

Active grants — research in progress, clinical trials, public health programs — can be killed without cause. The scientists running them have already spent years and millions on the work. It all stops because a political appointee decides it doesn't serve the president's priorities.

Notably this proposed rule also prohibits grants supporting disparate impact theory, voter registration campaigns, and issue advocacy.

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Comment Template

Below is a template you can modify and copy/paste sections you want to highlight in your comment. (Link to public comment page is here)

While the stated objectives of transparency, accountability, and oversight are laudable, the proposed rule as written would achieve the opposite — concentrating grant-making authority in political appointees, undermining scientific independence, threatening the lives of vulnerable populations, and fundamentally altering the relationship between federal agencies and the communities they serve.

[§ 200.205] Pre-Issuance Review 
This provision reduces expert peer review to a purely advisory role, requiring political appointee approval for all discretionary grants. For decades, peer review has ensured funding is awarded on scientific merit, not political alignment. A system requiring political approval before funding is awarded will produce only politically acceptable knowledge.

Climate science, public health research, epidemiology, environmental monitoring, and social science research all depend on the ability to follow evidence wherever it leads. A system that requires political approval before funding is awarded is a system that will produce only politically acceptable knowledge. This is not transparency. It is censorship at the point of origin, ensuring that inconvenient data is never collected in the first place.

I urge OMB to withdraw this provision and preserve the independence of merit-based peer review as the primary mechanism for grant award decisions.

[§ 200.300]  DEI, Gender Identity and Disparate Impact Prohibitions
Prohibiting funds related to "gender ideology" — a term left deliberately broad — threatens to defund healthcare infrastructure that transgender Americans depend on for basic medical care, mental health services, and suicide prevention. LGBTQ+ youth who lack access to affirming care are at significantly elevated risk of suicide. Defunding these services will cost lives.

Prohibiting research based on disparate impact theory would end the study of health disparities and environmental justice. These are empirically validated methodologies, not ideological frameworks. Banning them does not eliminate disparities. It eliminates our ability to understand and address them. 

I urge OMB to remove these prohibitions in their entirety.

[§ 200.340-344] Expanded Termination Authority
Expanded Termination Authority Allowing termination when an award "no longer aligns with the national interest" — a term undefined and subject to political interpretation — is functionally unlimited. Since January 2025, the administration has terminated thousands of grants and faced legal challenges. This provision appears designed to provide post-hoc legal authority for actions courts have questioned.

I urge OMB to maintain existing termination procedures that require documented cause, adequate notice, and meaningful opportunity for appeal.

[§ 200.206] Risk-Based Applicant Review and FEMA Implications
Embedding immigration enforcement into the grant framework raises life-and-death concerns. A flood does not check immigration papers. A wildfire does not ask for documentation. A hurricane does not distinguish between citizens and non-citizens. Relief organizations should not be forced to either. Research confirms that immigration enforcement produces declines in communities' willingness to seek emergency services.

I urge OMB to explicitly exempt emergency management, disaster relief, and public health emergency programs from immigration enforcement provisions in the proposed rule.

[2 CFR Subtitle A] Conversion from Guidance to Binding Regulation 
Converting the Uniform Guidance into a binding OMB regulation centralizes authority in a single White House office, removing individual agencies' ability to tailor requirements to their programs. This unprecedented consolidation of executive power over federal spending cannot account for the diverse needs of scientific research, public health, education, and environmental protection.

I urge OMB to maintain the existing framework in which agencies retain flexibility to implement guidance in ways appropriate to their specific programs, rather than centralizing regulatory authority in a single office.

[§ 200.450] Prohibition on Voter Registration and Issue Advocacy  
Voter Registration Prohibition Voter registration is a nonpartisan civic activity protected by the National Voter Registration Act. Prohibiting federally funded organizations from conducting voter registration suppresses civic participation among low-income, minority, and underserved communities.

I urge OMB to distinguish between partisan activity and nonpartisan voter registration.

Conclusion:
This proposed rule not an incremental adjustment. It is a structural transformation of federal grant-making into a tool of political control. I urge OMB to withdraw it in its entirety.

Respectfully submitted,

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Additional summaries of the proposed regulations that go into greater depth and breadth:

• OMB Proposes Major Overhaul of Federal Grant Rules: What Grant Recipients Need to Know (JD Supra, 6/5/26)
  
• OMB Unveils Proposed Rule to Restructure Federal Financial Assistance Oversight (JD Supra, 6/2/26)
• Breakdown of OMB Proposed Rule: Regulation for Federal Financial Assistance (American Astronomical Society, 6/4/26)
• Office of Management and Budget Government-Wide
  Regulations for Federal Financial Assistance (American Council on Education, 6/2/26)
• OMB Proposed Uniform Grants Regulation (AMPO, 6/2/26)