OMB’s proposed rewrite of 2 CFR Part 200, the Uniform Guidance governing all federal grant management, hit the Federal Register on May 29. I read the rule text this week. It’s what the August 2025 executive order on grant oversight tried to accomplish by fiat, now wrapped in formal rulemaking to survive the courts.
The biggest structural shift: any federal agency may cancel any grant at any time by asserting it’s no longer in the “national interest.” Awards would carry standard language at issuance confirming recipients accept this condition. The existing 2 CFR Part 200 termination rules require documented notice and basis. This proposal removes that floor entirely.
Peer review survives, technically. The document states “peer review remains advisory and does not replace agency discretion,” phrasing NIH and NSF have always carried as a legal carve-out. Under the proposed rules, officials exercising that discretion won’t be expert program officers. They’ll be political appointees explicitly directed not to “routinely defer” to reviewer scores, with scientific merit subordinate to work being “aligned with administration policies and priorities.”
The rule bans funding for theories of disparate-impact liability, DEI activity, and “gender ideology” (defined as any attempt to deny the sex binary). Chinese researcher collaborations face potential outright prohibition. Publication costs and conference travel become “unallowable” without advance agency approval, case by case.
The formal rulemaking route is the tell. The administration lost a string of grant-cancellation court cases in 2025 precisely because agencies terminated awards without following any procedure. Publishing in the Federal Register builds the administrative record those courts said was missing. That’s the mechanism: a litigation shield embedded in the rulemaking structure.
Public comment on Docket OMB-2026-0034 is open. Worth reviewing against your upcoming grant submissions.
Rebecca Lauren