Comment period ends July 13 at 11:59 p.m. ET

Yes, NAVBO is currently crafting an organizational comment which will be submitted to the public register. We encourage all members to submit a comment.

Read the letter from NAVBO's past, present, and future presidents here.

Yes! To submit anonymously, go to the comment page and select "anonymous" when responding. Be careful to not reveal any personal details if you submit anonymously.

This has been a valid concern within the scientific world and unfortunately we do not have a good answer. Public comments are part of the public record, so if you are concerned about current or future funding, you may submit an anonymous comment instead.

This OMB rule will affect many aspects of the scientific grant-making landscape, and may affect collaborations with others and institutional guidelines. If you have active collaborations that involve federal funding (NIH, CDC, DOD, NSF, etc.), we would still encourage you to submit a comment on how this would affect you.

The form does not ask submitters to identify citizenship status. If the proposed rule would affect you, we still encourage you to submit a comment.

The implementation of OMB rules is a multi-step process and the submission of comments is an important part of it. Agencies are required to address and consider all comments and public comments become part of the administrative record. Even if OMB does not change a single sentence after the deadline, comments may lead OMB to further explain the reasoning behind the provisions, clarify ambiguities, and may be used as part of litigation in the future.

While templates may be a great starting point, we do not recommend using a template for your public comment submission to OMB. Comments from a template may all be lumped together as a single submission during the review process. Using your own words helps ensure the comment contributes to distinct information to the administrative record.

Yes, all comments submitted through regulations.gov will be part of the public record.

Yes, with some considerations. Instead of repeating the same points in each comment, focus on a distinct issue within the provisions.

Yes! You can view posted comments here: https://www.regulations.gov/document/OMB-2026-0034-0001/comment

There may be multiple sections within the proposed rule that you may want to refer to in your comment. It is helpful to point to specific provisions when writing your comment as well, so feel free to use the section numbers below to help craft your comments. Please note, you can refer to any specific sections that will affect you in your comment(s), but it is not necessary to refer to all.

Relevant sections of the proposal:

• §200.205 — Political appointee review of grants

• §200.340 — Grant termination

• §200.432 — Conference attendance pre-approval

• §200.454 — Journal subscriptions (would be unallowable)

• §200.461 — Publication costs (would be unallowable)

• §200.300 — DEI and gender ideology prohibitions

• §200.218 — Disparate-impact research banned

• §200.220 — Foreign collaboration prohibition

• §200.202 — Programs must align with administration priorities

• §200.204 — Grant competitions can be exempted from public notice

If you are concerned regarding submitting a public comment, contact an immigration expert. As a reminder, comments may also be submitted anonymously (anonymous comments will also be part of the public record).

Resources: https://immpolicytracking.org/policies/omb-issues-proposed-rule-updating-requirements-for-federal-financial-assistance/#/tab-policy-overview