The Center for Open Science (COS) has submitted a public comment opposing several proposed revisions detailed in the White House Office of Management and Budget’s (OMB) proposed Regulation for Federal Financial Assistance (2 CFR 200). Earlier this month, we joined over 300 organizations requesting an extension to the comment period, citing the scope, complexity, and impact of the proposed rule, which affects the approximately $1.1 trillion worth of federal investments through grants and cooperative agreements. The request for extension has yet to be granted, with the comment period closing on July 13, 2026.
Here, we’re sharing why we weighed in, what concerns we raised throughout our comment, and how you can add your own voice. Our full submission includes a detailed, provision-by-provision analysis with supporting citations. You can read it here.
Codifying “Gold Standard Science”
Last year, we issued a statement after the White House released its executive order on Restoring Gold Standard Science (GSS) on May 23, 2025. While the executive order referenced several open science practices COS has long championed — reproducibility, transparency, and unbiased peer review among them — it also empowered senior political officials to adjudicate what meets the "gold standard" and what does not. As an organization committed to increasing the openness, integrity, and trustworthiness of research, COS was concerned that this framework citing principles of scientific rigor could instead become a mechanism for political influence over which science is funded and trusted.
The proposed OMB rule takes this concern a step further, codifying concerning elements of the Executive Orders on Improving Oversight of Federal Grantmaking and Restoring Gold Standard Science. Several provisions embed political oversight and approval directly into the grantmaking process, sidelining the experts best positioned to judge scientific merit and restricting the free flow of scientific information.
What the Proposed Rule Does
The proposed rule revises the government-wide regulation that sets the terms for federal awards, spanning scientific research and development, public health, education, and social services. Given COS’s mission and areas of policy expertise, we kept our comments limited to provisions impacting the openness, integrity, and trustworthiness of the nearly $200 billion in federal grantmaking that supports research and development.
Our Concerns
We organized our comments around two broad themes, with a closing observation drawn from OMB’s own regulatory impact analysis.
The rule compromises the independence and integrity of federally funded research. Several provisions would insert senior political officials into funding decisions across the grant lifecycle — shaping which opportunities exist, how applications are evaluated, and whether awards continue. One provision (§200.205) would require political pre-issuance review of awards and direct appointees not to defer to expert peer review. Another (§200.340) would allow active grants to be terminated if they no longer fit "agency priorities or the national interest as they exist at the time of the termination," with limited recourse. Together, these changes subordinate independent expert evaluation to shifting political priorities. Notably, this undermines the Gold Standard Science tenet of “unbiased peer review,” empowering political appointees to override expert review that has been a hallmark of the U.S. merit review process.
The rule limits funded researchers’ ability to freely and independently communicate their work. Other provisions would restrict participation in conferences (§200.432), communication with the public and policymakers (§200.450), and the publication costs that make findings openly available (§200.461). These activities are central to how the public realizes the benefit of its investment and to how researchers collaborate and build on prior work. Restricting them narrows the channels through which federally funded work reaches the people it is meant to serve.
The rule undermines OMB’s own stated goal of reducing administrative burden. In its own Regulatory Impact Analysis, OMB concedes it “was unable to quantify the expected costs of the rule” and anticipates “minimal to modest to substantial short-term costs for recipients.” OMB also appears to underestimate these costs. Its analysis treats the pre-issuance review, for example, as having “no perceived impacts,” despite its requirement that senior appointees substantively review every discretionary award rather than deferring to the judgment of expert review panels. These are not costless — nor is it cost-saving to introduce greater political control over research.
Why This Matters
Federal research funding has produced exceptional returns precisely because decisions about what to fund have rested on merit and independent expert judgment, rather than political alignment. The process can always work better, and COS has long advocated for reforms to do so. But subjecting scientific judgment to shifting political priorities is not the answer; rather, it undermines the stability that rigorous, multi-year research investments depend on. The consequences are already visible: in 2025, an estimated 1 in 30 active NIH-funded clinical trials lost funding, affecting more than 74,000 enrolled participants, as part of terminations totaling roughly $1.8 billion — the kind of disruption §200.340 would make routine.
Add Your Voice
Public comments are open through July 13, 2026. Strong comments are grounded in first-hand experience: what a provision would mean for your work, your institution, or the communities you serve. You can submit a comment at regulations.gov under Docket OMB-2026-0034. You do not need to write a comment as detailed as ours. A clear, specific account of how the rule would affect your work is valuable on its own.
COS remains committed to building and sustaining the infrastructure, policies, and partnerships that help science deliver on society's greatest challenges.