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University of California System Comments on Proposed Rule, Regulation for Federal Financial Assistance, 91 Fed. Reg. 32198, published May 29, 2026 (Docket ID No. OMB-2026-0034)
Abstract
This comment letter responds to the Office of Management and Budget (OMB)'s proposed revisions to the Regulation for Federal Financial Assistance (Uniform Guidance). The University of California (UC) urges OMB to withdraw the proposed rule, arguing that it would weaken merit-based research funding, restrict international scientific collaboration, limit dissemination of federally funded research, expand agency authority to suspend or terminate awards, and significantly increase administrative and compliance burdens. If OMB proceeds, UC recommends substantial revisions to preserve peer review, support research collaboration and public access, maintain allowable research costs, protect award stability, and ensure a prospective, well-planned implementation process.