Dear Colleagues,
The Office of Management and Budget (OMB) recently published a proposed rule, Regulation for Federal Financial Assistance, that would fundamentally alter the way federal grants are awarded, administered, and overseen across federal agencies. If implemented as proposed, the rule would represent one of the most significant shifts in federal research administration in decades, with substantial implications for how investigators and institutions apply for, manage, and sustain federally funded research projects.
The university is working in close coordination with our peers and our national higher education partners, including the Association of American Universities (AAU), the Association of American Medical Colleges (AAMC), the Council on Governmental Relations (COGR), and the American Council on Education (ACE), among others. We are deeply engaged in assessing the potential impacts on our research community and preparing a coordinated institutional response. In addition, individual comments from the academic research community can be especially valuable when they include concrete examples of how the proposed changes would affect ongoing or planned research activities. We have provided information below as a resource for GW community members who wish to submit comments on their own behalf.
Highlights of the Proposed Changes
Based on an initial analysis conducted by AAU, COGR, and the Association of Public and Land-Grant Universities (APLU), the proposed rule includes more than 300 revisions, with some notable changes:
- Minimizing Peer Review in Federal Funding Decisions – Under the proposed rule, peer review of submitted proposals would become advisory, and agencies would be directed to consider subjective factors such as institutional direct cost rates, perceived "questionable practices,” and alignment with administration priorities, among others. All discretionary grants would require pre‑issuance review by senior political appointees.
- Expanded Authority to Suspend or Terminate Awards – Agencies would be able to terminate grants “for convenience” if an award is deemed inconsistent with evolving agency priorities or the national interest. The proposal also removes the ability to appeal such terminations.
- Restrictions on Allowable Costs – The proposal would significantly narrow the types of costs that can be charged to federal awards, including: publication costs and many open‑access fees; subscriptions to academic and professional journals; conference participation unless expressly approved; and memberships in professional organizations unless required for the award.
- New Restrictions on International Collaboration – The proposal requires federal agencies to apply a “domestic‑first framework, under which international elements may be included only if the Federal agency determines that such elements are justified, consistent with program objectives, and in the national interest of the United States.”
- Elimination of Most Fixed‑Amount Awards and Subawards – The proposal would largely eliminate fixed‑amount mechanisms unless specifically authorized by statute, increasing administrative burden and reducing flexibility in managing subawards.
Opportunity to Submit Individual Comments
The proposed rule is open for public comment until 11:59 PM EDT on July 13, 2026. The notice states that the final regulation will be effective October 1, 2026.
- If you wish to submit a comment on your own behalf, you may do so through the Regulations.gov website. Investigators may wish to comment on potential impacts on their research programs; effects on collaboration, publication, or data management practices; administrative or financial burdens introduced by the proposal; or implications for student training, workforce development, or long‑term research planning.
- The summary of key issues authored by AAU, COGR and APLU provides additional context on the proposed rule.
- Regulations.gov has published guidance on submitting effective public comments.
Faculty who wish to pursue additional avenues of engagement are encouraged to consult with the Office of Government and Community Relations team by emailing ogcr
gwu [dot] edu (ogcr[at]gwu[dot]edu).
We recognize that many members of our research community may feel concerned or uncertain about the potential implications of this proposal. Please know that GW is fully engaged in this process and is working closely with peer institutions and national organizations to ensure that our research community’s voice is represented.
Thank you for your continued commitment to advancing research and scholarship at GW.
Sincerely,
Renee McPhatter
Associate Vice President for Government and Community Relations
Robert H. Miller
Interim Vice President for Research
Vivian Gill Distinguished Research Professor and Professor of Anatomy and Cell Biology