OMB Proposed Rule on Federal Financial Assistance (2 CFR)

An Update for the Membership of the College

Docket OMB-2026-0034  |  91 FR 32198  |  Published May 29, 2026  |  Comments due July 13, 2026

Background / Rule Information

On May 29, 2026, the Office of Management and Budget (OMB) published a proposed rule rewriting the Uniform Guidance at 2 CFR, to be rebranded the Uniform Grants Regulation (91 FR 32198, Docket OMB-2026-0034). The rule is government-wide. More than forty agencies, including the Department of Health and Human Services and therefore the National Institutes of Health, along with the National Science Foundation, would conform their implementing regulations. The proposal also reclassifies the 2 CFR text as a binding OMB regulation with independent regulatory effect, replacing the prior model in which agencies adopted OMB guidance with some flexibility.

OMB states three objectives: improving transparency, accountability, and oversight; clarifying the regulatory status of the text; and reducing recipient burden. The rule is issued pursuant to Executive Order 14332. Comments are due July 13, 2026, and OMB proposes a final rule effective October 1, 2026, in time for FY27 awards.

The proposed changes reach the research the College’s members conduct in several ways. Most consequentially, a pre-issuance review provision tied to Executive Order 14332 would change how award decisions are made. Other provisions address research examining sex, gender, and race, the continuity of awards already made, international collaboration, and the cost rules that govern meeting attendance, dues, and publication fees. The sections most relevant to the membership include 200.205, 200.300, 200.218, 200.340, 200.220, and the cost principles at 200.432, 200.454, and 200.461.

Implications for the Science and Work of ACNP Members

Merit Review and the Role of Peer Review

• A new pre-issuance review at 200.205, is the change with the greatest consequence for the field.
• Senior agency officials would give final approval to every discretionary research award, based on alignment with Federal policy priorities.
• Scientific peer review would become advisory only and would no longer decide what gets funded.

Research on Sex, Gender, And Race

• Section 200.300 would bar grants from funding diversity, equity, and inclusion policies, gender ideology, or the gender transition of a person under nineteen.
• Section 200.218 would direct agencies to stop using disparate-impact liability in award decisions.

Funding Continuity and Mid-study Risk

• Revised 200.340 would allow an award to be terminated if it no longer fits agency priorities or the national interest at the time.
• Stop-work and temporary suspension clauses would become mandatory in all awards.
• Section 200.342 would let agencies skip administrative hearings for these discretionary terminations

International Collaboration

• New 200.220 would bar Federal funds from supporting collaboration with covered foreign countries or entities.
• Cross-national consortia in psychiatric genetics, neuroimaging, and epidemiology could be affected.

Research Workforce and Laboratory Operations

• Section 200.303(f) would require all recipients and subrecipients to use E-Verify for staff and contractors working on an award.
• Section 200.112 would require disclosing whether personnel were agency employees in the prior two years.

The Annual Meeting, the Journals, and Dues

• Cost principles at 200.432, 200.454, and 200.461 govern whether members can charge meeting attendance, dues, and publication fees to an award.
• New 200.219 would bar recipients from discriminating by viewpoint or content when providing event services.

Indirect costs

• OMB did not change the negotiated indirect cost rate system at 200.414; the earlier attempt to impose a uniform fifteen percent rate was enjoined.
• The preamble asks commenters not to address indirect rate negotiation in this docket.
• Section 200.205 would, all else equal, favor institutions with lower indirect cost rates.
• A new cost principle at 200.477 would make elective abortion costs unallowable, which is peripheral to most ACNP science.

Position of ACNP

The public is entitled to confidence that Federal research dollars are spent with rigor, transparency, and accountability, and the College’s members hold that expectation as fully as any taxpayer. Accountability and scientific merit are not opposing aims. The College’s concern is whether the mechanism this rule establishes would strengthen the evidence base or weaken it.

As drafted, the rule would have senior political appointees give final approval to every federal research award for alignment with presidential priorities, while reducing scientific peer review to an advisory role that no longer determines what is funded. This is a monumental change, and its consequences are likely to compromise the preeminent position of the United States in scientific discovery and its application. The College is also attentive to the proposal’s treatment of research examining sex, gender, and race, which in this field are scientific variables rather than ideological categories, and to the process itself: a 412-page rule that would restructure Federal research administration is open for public comment for only forty-five days is an unusually brief window for a change of this scope.

The goals the administration states can be advanced through means that strengthen expert review rather than displacing it, including publicly stated funding criteria, rigorous conflict-of-interest and integrity standards within peer review, expanded post-award transparency, and regular reporting to Congress. The College would welcome the opportunity to contribute to measures of this kind. Our engagement is scientific rather than partisan, grounded in the methods and evidence of federally funded research.

What ACNP Will Do

ACNP will submit formal comments before the July 13, 2026 deadline. The College intends to:

• Address the displacement of merit-based peer review and the proposal’s treatment of research examining sex and race, drawing on the membership’s expertise in the methods and evidence of federally funded research.
• Offer constructive alternatives that advance accountability while strengthening expert review, such as publicly stated funding criteria, rigorous conflict-of-interest and integrity standards within peer review, expanded post-award transparency, and regular reporting to Congress.
• Verify the relevant regulatory text against the primary Federal Register version before relying on any description in the filing, since several characterizations now circulating derive from secondary analyses.
• Coordinate with sister scientific societies where appropriate, so that the College’s contribution complements rather than duplicates theirs.
• Share the comments it plans to submit with the membership and monitor the rulemaking and its timeline through the close of the comment period and toward the proposed October 1, 2026 effective date.

What ACNP Encourages Its Members to Do

• Review the proposed rule and submit individual comments before the deadline. The membership’s expertise in the methods, the evidence, and the real-world stakes of federally funded research is precisely what this comment process needs.
• Draw on your own scientific experience of how rigorous, merit-based peer review advances the diagnosis, treatment, and prevention of disorders of the brain and behavior.
• Describe the specific potential adverse impacts of the proposed change on your own research, in concrete terms, since a described real-world effect is more persuasive than a general objection.
• File at gov under Docket OMB-2026-0034, prefacing each comment with the relevant section number in brackets (for example, [200.205]). Comments are due July 13, 2026.

How to Submit a Comment to the Federal Register

Comments on the proposed rule are filed electronically through the federal eRulemaking portal at regulations.gov. The comment period closes on July 13, 2026 at 11:59 p.m. Eastern Time. The steps below describe the process:

Filing your comment

• Go to gov and search for the docket number OMB-2026-0034, or navigate directly to the comment page at regulations.gov/commenton/OMB-2026-0034-0001.
• On the docket page, select the “Comment” button. The proposed rule and its full regulatory text are available on the same page for reference.
• Enter your comment in the text box, which accommodates up to 5,000 characters. For a longer or formatted submission, upload it as an attachment (PDF preferred) and use the text box to summarize.
• Providing an email address is optional. An email allows the portal to send a confirmation receipt and to notify you when the agency responds in the final rule.
• Submit before the deadline. Allow time for the portal, since volume tends to increase in the final days of a comment period.

Writing an effective comment

• Preface each comment with the relevant section number in brackets, for example [200.205], so it is routed to the correct provision.
• Write in your own words. Identical or copied comments carry less weight in the record than distinct, substantive ones.
• Anchor the comment to scientific merit and to the specific consequences for research, for example how merit-based peer review advances the diagnosis, treatment, and prevention of disorders of the brain and behavior, and how the proposed change would affect that work.
• Be concrete. A described, real-world effect on a study, a research program, or a line of inquiry is more persuasive than a general objection.

Before you submit

• Comments are part of the public record. Your comment, along with any name or organization you provide, is posted publicly on regulations.gov and is searchable.
• Do not include personal information you do not wish to make public, such as a home address or telephone number. Anyone may comment; there is no citizenship requirement.
• Institutional comments submitted by a professional society, university, or organization, and signed on behalf of its members, carry additional weight in the record. Members affiliated with an institution may wish to coordinate with their grants office before filing in an institutional capacity.

Commenting anonymously

A comment may be submitted anonymously. Because everything submitted is posted to the public record without change, and agencies do not verify identity, anonymity depends on what the commenter chooses to leave out rather than on a setting the portal enforces.

• In the commenter-type field, choose the anonymous or individual option, and leave the name, organization, and address fields blank, since these are optional.
• Omit an email address for full anonymity. An email is not displayed publicly, but leaving it out is the cleanest path.
• Keep identifying details out of the comment text and any attachment, including your name, institution, job title, city, and indirect identifiers such as a specific grant number or named laboratory.
• Clear hidden file metadata before attaching a document, since a Word or PDF file often stores the author’s name automatically. Pasting the text directly into the comment box avoids this.
• Save the comment tracking number the portal provides, which is the only record of an anonymous submission.