Dear Colleagues,
The Office of Management and Budget has proposed a major revision to Uniform Guidance (2 CFR Part 200), the federal regulation that specifies how sponsored research is funded, administered, and audited. The proposed rule would codify changes made to the federal grant decision making process including issues of federal control, award selection, international collaborations, indirect costs, and termination authority. Lehigh is preparing to submit an institutional comment, as well as contribute to responses by organizations we belong to such as COGR (Council on Governmental Relations).
In addition to these efforts, professional organizations and societies are encouraging their individual members to comment in their own voices. Individual comments from active researchers carry credibility: you can speak directly to how these rules will affect your lab, your students, and your science. You do not need permission from, nor should you coordinate with us. Just speak from your own experience.
Some of the proposed changes are outlined briefly below. More information is emerging from various organizations, and we recommend that you check COGR’s dedicated website for more information as it appears.
If you do submit a comment, please include a line making it clear that you are speaking for yourself, not the university. For example:
"I am a professor of [field] at Lehigh University; I submit these comments in my individual capacity based on my expertise and experience, and they do not represent the position of the University."
The comment period deadline is July 13, 2026, although COGR has already requested an extension. Submission instructions are here.
If you have any questions, or wish to discuss this situation, please feel free to contact us.
Best wishes,
Cynthia Kane, Associate Vice Provost, Research and Sponsored Programs
Dominic Packer, Senior Advisor to the Vice Provost for Research
Nathan Urban, Provost
Some of the Proposed Changes
Political-appointee review before awards are issued. The proposal would have a senior agency official sign off on awards, weighing alignment with agency priorities and national interest. Scientific peer review would be treated as advisory. If you serve as a reviewer or applicant, you may have a perspective on the role of expert peer review in funding decisions.
Broader authority to terminate awards. Agencies would be able to end awards that they deem no longer align with federal priorities. If you have planned multi-year projects, supported personnel on grant funding, or built research around continuity, you might speak to what mid-stream termination would mean in practice.
Conference and publication cost rules. The proposal tightens pre-approval and allowability for conference and publication expenses. If this affects how you disseminate your work, it can help to note concrete examples — e.g., a conference, a publication, the added steps or delay. Conferences are also where many new collaborations begin and ideas are strengthened, so limits here may affect the quality and impact of the work that follows.