Dear Colleagues,
We want to provide an update on GW’s institutional response to the Office of Management and Budget's (OMB) proposed rule on federal grantmaking. We also want to thank everyone who participated in the town hall on the topic and the many individuals who have shared thoughtful feedback and questions by email.
If enacted as it is currently written, several provisions of the rule could affect the conduct and administration of federally sponsored research, including research collaborations, award management, and the dissemination of research results.
Given the potential significance of these proposed changes, your input has shaped the university’s engagement with peers and higher education organizations. Your feedback also informed GW’s institutional comment, which makes the following recommendations by section:
- 200.205 (Federal Agency Review of the Merit of Proposals): Preserve peer review as the primary basis for research funding decisions and provide clear limits on non-scientific review of awards.
- 200.218 (Disparate-Impact Liability): Protect the use of established, evidence-based research methodologies, including disparate-impact analysis, in federally funded research.
- 200.220 (Covered Foreign Collaborations): Ensure that restrictions on foreign collaborations are narrowly tailored and do not impede beneficial international research partnerships.
- 200.305 (Federal Payment): Avoid new payment justification requirements that would impose significant administrative burden without corresponding oversight benefits.
- 200.333 (Fixed Amount Subawards): Retain flexibility for fixed amount subawards that support efficient research administration and broad participation in federally funded projects.
- 200.340–200.343 (Termination and Suspension): Establish clear standards, due process protections, and closeout safeguards for award terminations and suspensions.
- 200.432 and 200.461 (Conferences; Publication and Printing Costs): Maintain support for research dissemination by preserving the allowability of publication, conference, and open-access costs.
Researchers, staff, collaborators, and community partners who wish to participate in the rulemaking process may submit comments describing how the proposed changes could affect their work and communities. If you wish to submit a comment on your own behalf:
- Regulations.gov will accept comments on the proposed rule through 11:59 p.m. EDT on Monday, July 13.
- Review GW’s institutional comment and consider describing how the proposed rule may affect your research, collaborations, students, or other federally supported activities.
- Comments may be submitted anonymously.
- Consider sharing your comment with your federal elected officials, who will continue to play an important role in shaping federal research policy and oversight.
As a reminder, additional context and resources have been posted on the Federal Research Updates webpage.
Thank you again for your engagement and continued commitment to research excellence. Your participation has strengthened our efforts to advocate on behalf of GW researchers and the broader federally funded research enterprise.
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