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.
This comment letter responds to the Office of Management and Budget (OMB)'s Proposed Rule to revise sections of 2 CFR, Subtitle A, Chapters I and II (the Uniform Guidance). UC expresses support for OMB’s burden-reducing changes but said the rule still leaves uncertainty and unrecovered costs around indirect-cost rates, agency IDC limits, outdated caps, DS-2 reporting, COI scope, and subaward rules. UC recommends clearer language, stronger enforcement of negotiated IDC rates, eliminating or updating outdated requirements, clarifying procurement COI, and preserving administrative flexibility.
This comment letter responds to OMB's request for comments on OMB's Proposed Rule on Guidance for Grants and Agreements issued on February 9, 2023. UC supports OMB’s implementation of Build America, Buy America requirements but said the proposed guidance lacks clarity on when BABA applies to federal awards that are not primarily infrastructure projects. UC recommends adding language specifying that BABA applies only to infrastructure-project spending under covered awards, not to non-infrastructure spending, to reduce compliance costs, avoid conflicting “Buy America” rules, and prevent project delays.
This comment letter responds to the Office of Management and Budget (OMB)'s request for information on proposed revisions to 2 CFR, Subtitle A, Chapters I and II (Uniform Guidance). UC endorses COGR’s comments and recommends that OMB reduce administrative burden under 2 CFR by eliminating the DS-2 requirement, raising the subaward MTDC cap from $25,000 to $75,000 with regular reevaluation, and reconsidering the 26% cap on administrative F&A costs. UC also asks OMB to clarify that negotiated indirect cost rates must be accepted unless limited by statute or regulation, specify that § 200.112 concerns procurement-related conflicts rather than research COI, and rewrite subrecipient indirect-cost-rate rules in plain English so pass-through entities and subrecipients have clear, workable options.
This comment letter requests that OMB extend the comment period for the proposed revisions to 2 CFR, Subtitle A, Chapters I and II (Uniform Guidance) by 60 days. OMB's proposed revisions to the Uniform Guidance was published in the Federal Register on February 9, 2023 and only provided a 30-day comment period.
This comment letter requests that OMB extend the comment period for the proposed revisions to the Guidance for Grants and Agreements by 60 days. OMB's Proposed Rule on Guidance for Grants and Agreements was published in the Federal Register on February 9, 2023 and only provided a 30-day comment period.
