UC3 Comments on OMB’s Proposed Changes to Federal Grant Rules

UC3 has submitted comments regarding the Office of Management and Budget’s proposed rewrite of 2 CFR Part 200. This is the Uniform Guidance that governs federal grants and cooperative agreements. The proposed rule is the largest revision to these rules since the Uniform Guidance was established in 2013, and it has spurred widespread concern from research institutions, universities, and scientific and medical societies. More than 50,000 public comments have already been submitted as of posting this. The scope of the proposed revisions to these rules is extremely broad, and several of its provisions have direct consequences for the research infrastructure that UC3 builds.

Much of our work focuses on helping researchers and organizations meet the requirements that federal agencies have set for openly sharing research. The proposed rule would work against these same expectations. Just a few of the many issues: 

• The rule would also significantly restrict international collaboration, which would have serious consequences for the research data management tools and systems that U.S. research depends on
• Publication and open access costs would become unallowable
• Conference attendance would require agency approval written into the terms of an award at the beginning
• Federal granting agencies would have the ability to terminate active awards when priority shifts, which undermines the multi-year commitments that our projects depend on

Our letter addresses these provisions from our perspective as an infrastructure provider serving not only UC campuses but the international research community. The OMB proposal includes many more changes than we could address. We concentrated on the areas that we know the best.

Comments on the proposed rule are open through July 13th. We encourage you to weigh in if you haven’t!