The following comments were submitted by Richard Besser, MD, Robert Wood Johnson Foundation (RWJF) President and CEO, in response to the Office of Management and Budget's (OMB) proposed revisions to the Uniform Guidance governing federal financial assistance (the proposed rule), published in the Federal Register on May 29, 2026.[1]
RWJF is a leading national philanthropy dedicated to taking bold leaps to transform health in our lifetime. Through funding, convening, advocacy, and evidence-building, we work alongside communities, practitioners, researchers, nonprofit organizations, and public institutions to get to health equity faster and pave the way together to a future where health is no longer a privilege, but a right. Our comments are grounded in the perspectives and expertise of our grantees, who include nonprofit organizations, researchers, and educational institutions that are committed to promoting health, wellbeing, and scientific innovation.
RWJF strongly opposes OMB’s proposed regulation to alter “Uniform Guidance.” As written, the proposed rule would fundamentally alter how federal grants are awarded, administered, and terminated across the federal government. The proposed rule would introduce new ideological requirements into federal grantmaking; elevate political review over expert judgment; expand the government's authority to terminate grants for political, viewpoint, and ideological reasons after they have been awarded; and discourage science-based research and programs designed to understand and address the factors that shape health outcomes in America.
Although presented as an effort to improve accountability and oversight, the proposed rule would instead make federally funded health research, public health programs, and community services less effective, less predictable, and less responsive to the needs of the American people. RWJF’s concerns center on three overarching points:
- Further limiting efforts to foster equal opportunities for health will exacerbate disparities and hinder innovation that benefits everyone. The proposal would prohibit or chill a wide range of diversity, equity, and inclusion (DEI) activities; hinder work to understand and remedy policies with disparate impacts; and constrain efforts to address structural drivers of poor health, particularly affecting communities of color, immigrants, LGBTQ+ people, individuals with disabilities, people with limited incomes, and other historically marginalized groups. The past 17 months demonstrate that the federal government has exploited broad and intentionally vague bans on “unlawful DEI” and related concepts to target lawful evidence-based programs, research, and services, and to deter future work that is essential to closing health gaps.
- Allowing political and ideological preferences to dominate health research and public health funding decisions will undermine merit-based review and weaken the science that keeps people healthy. The proposal would require senior political appointees to pre-review funding opportunities and final grant awards, treat peer review as advisory, and prioritize alignment with the President’s policy preferences and an undefined “Federal interest” over scientific rigor and public health needs. It would also impose new restrictions on what scientists can study and how they disseminate results, limiting support for certain topics, constraining publication and conference costs, and requiring additional approvals to share evidence, all of which would slow discovery, reduce transparency, and delay translation of research into better health outcomes.[2]
- Expanding discretionary authority to suspend or terminate grants for viewpoint disagreement creates profound instability for federal grant recipients and the communities they serve. Under the proposal, agencies would gain broad new authority to terminate awards midstream whenever they decide an award no longer advances agency or presidential priorities, even when grantees have complied with all grant conditions. This instability would be particularly damaging for nonprofit organizations, state and local governments, universities, health systems, and community-based partners that rely on multi-year grants to sustain essential services, maintain clinical trials and longitudinal studies, and support the next generation of scientists and public health professionals.[3]
Federal grantmaking best serves the American people when it protects scientific integrity, rewards merit, supports inclusive and equitable participation, and provides stable, predictable support for evidence-based programs and research. The proposed rule moves federal investments in the opposite direction, making the grant system more political, less transparent, and less responsive to the health needs of communities.
RWJF respectfully urges OMB to withdraw the proposed rule in its entirety. In its place, OMB should work with agencies, Congress, grantees, and communities to strengthen the oversight mechanisms that preserve independent scientific and programmatic review; ensure that grants remain nonpartisan; and protect the ability of agencies and partners to advance health equity so that everyone has a fair and just opportunity to be as healthy as possible.
I. Overview of the Proposed Rule
OMB has proposed a comprehensive revision of 2 C.F.R. Part 200, the government-wide framework known as the “Uniform Guidance.”[4] The Uniform Guidance establishes the administrative requirements, cost principles, and audit standards that govern all federal grants and financial assistance awarded each year by federal agencies to states, local governments, universities, hospitals, nonprofit organizations, and other recipients.[5]
The proposed rule would replace the current Uniform Guidance with a new Uniform Grants Regulation (UGR) and make significant changes across multiple parts of Title 2 of the Code of Federal Regulations. While OMB describes the proposal as an effort to improve transparency, accountability, and oversight, the proposed rule would fundamentally change how discretionary grants are awarded, administered, and terminated. Most notably, it would expand agency discretion throughout the grant lifecycle, elevate the role of senior political appointees in funding decisions, and incorporate Administration policy priorities directly into award selection, risk assessment, compliance oversight, and termination determinations.[6] The proposal would also codify numerous harmful policy directives previously implemented through executive orders and agency guidance, while imposing new compliance, reporting, and cost allowability requirements on funding recipients.[7] This includes effectively codifying Executive Order 14332, “Improving Oversight of Federal Grantmaking;” Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy;” and Executive Order 14303, “Restoring Gold Standard Science,” giving this guidance the power of enforceable regulations.[8] [9] [10] More broadly, the proposed rule reflects a shift away from a grants framework primarily grounded in scientific merit and programmatic expertise toward one that instead prioritizes alignment with administrative priorities.[11] [12]
These changes have significant implications for the health of the people living in the United States. The vast majority of health research, public health infrastructure, workforce development, disease prevention initiatives, and community-based programs that improve health outcomes nationwide are supported by federal grants.[13] [14] [15] [16] In addition, federal grants support housing, education, and economic development programs that profoundly shape people’s opportunities for health. Many of these activities rely on stable, multi-year funding. By increasing uncertainty regarding award decisions and unpredictability regarding funding continuity, expanding the grounds for grant suspension or termination, and creating new compliance obligations tied to evolving policy priorities, the proposed rule could undermine the stability and predictability that health organizations need to plan, implement, and sustain critical public health and research activities.
II. The Proposed Rule Would Politicize Scientific Decisionmaking and Undermine Evidence-Based Governance
Health research and public health programs funded by the federal government work best when decisions are grounded in scientific merit, public health need, and community benefit, not partisan preferences. Peer review and expert programmatic review help ensure that federal funds support rigorous, high-value science grounded in the best available science. While the nonpartisan expert review process that normally guides competitive grant selection may be best known in the context of “peer” scientific review, competitive grantmaking is used to award roughly $200 billion of federal funding each year across government.
The proposed rule would upend this approach by requiring political appointees to pre-review funding opportunities and individual awards, and by treating scientific and peer review as advisory rather than determinative. In practice, this would shift final decisionmaking power away from independent experts and toward senior political officials, who would be directed to prioritize alignment with “Federal agency priorities,” “the President’s policy priorities,” and an expansive notion of “Federal interest” rather than scientific merit.[17] RWJF is deeply concerned that these changes would reduce the role of merit and evidence in federal funding decisions and make it harder for agencies to support research and programs that respond to community needs, especially when those needs do not align neatly with the administration’s political agenda.
Subordinating peer review to political judgment would weaken a core safeguard that helps ensure federal investments support high-quality, ethical, and impactful science. Peer review is not perfect, but it provides a structured, transparent process in which experts assess methods, significance, and feasibility; identify weaknesses; and help agencies select the strongest proposals from a field of qualified applicants.[18] When political appointees can override these assessments based on ideological considerations, including concepts such as “gender ideology” that are defined in executive orders rather than statutes, or vague notions of alignment, agencies risk funding projects that are less rigorous, less relevant to population health, or more driven by short-term political goals than by long-term public benefit.[19]
The proposed rule also introduces new constraints on what scientists can study and how they can communicate their findings. Provisions that restrict or disfavor research on topics deemed politically controversial, such as health equity, climate-related health risks, the health of immigrants, or the needs of LGBTQ+ people, would narrow the scope of inquiry and discourage work on urgent public health challenges.[20] Additional limits on using grant funds for publication costs, open access fees, and conference participation would make it harder to disseminate findings, to translate new knowledge into practice, and to engage in the scientific exchange that drives improvement and innovation. Recent reporting on a federally funded COVID-19 vaccine study that was blocked from publication underscores how political interference can delay dissemination of findings even when the underlying science is complete.
These changes would not only reduce the quality and impact of federally funded science; they would also make the research ecosystem less stable and less attractive for current and future scientists. Graduate students, postdoctoral scholars, early-career investigators, and community-based researchers often depend on multi-year federal funding to build careers and contribute to the evidence base. A recent 20-year study of two National Institutes of Health diversity-focused training programs found that participation doubled the odds that an undergraduate student would go on to earn a PhD, demonstrating that targeted investments can meaningfully expand and diversify the scientific workforce.[21] Yet despite this documented success, federal funding for both initiatives was terminated, illustrating how political decisions can dismantle evidence‑based programs that are working as intended. A system in which grants can be blocked, reshaped, or terminated for political reasons, rather than based on performance or compliance, will discourage talented people from entering or remaining in research, particularly those from underrepresented backgrounds who already face additional barriers.[22] That concern is especially acute for a research workforce already shaped by longstanding barriers to entry and advancement. RWJF has repeatedly emphasized that broad participation strengthens scientific capacity and improves the quality and relevance of federally supported research.
Politicizing grant decisions, constraining peer review, and destabilizing funding will slow scientific progress and weaken the nation’s ability to protect health. The Foundation is concerned that fewer independent, high-quality studies will be conducted on issues such as chronic disease prevention, maternal and child health, mental health, environmental exposures, and emergency preparedness. Additionally, restrictions on publication and conferences could delay the translation of evidence into practice, limiting the ability of clinicians, public health agencies, and communities to benefit from new findings. Together, these changes would erode the infrastructure of “gold standard” science that the public relies on for safe, effective, and equitable health interventions.
The U.S. scientific enterprise has long been a core public asset, built through sustained federal investment and independent expert review to advance health, discovery, and innovation. The National Academies, established in 1863, helped create an early model for expert scientific advice to government,[23] and World War II and the postwar years transformed that model into a durable federal research compact that fueled the modern biomedical enterprise.[24] That system has improved health, extended life, strengthened the economy, and powered major technological advances across the country. The proposed rule would further erode the foundation of the nation’s health ecosystem, compounding damage already inflicted through executive orders, presidential guidance, and other actions taken by this administration that have weakened scientific independence and public health capacity. Further weakening of that foundation now would risk slowing innovation at the very moment when other countries are investing aggressively to gain ground in science and technology.[25]
RWJF believes that federal funding and policy should strengthen, not weaken, the foundations of evidence-based governance. Protecting independent peer review, supporting transparent dissemination of findings, and providing stable support for a diverse research workforce are essential to safeguarding the health of current and future generations. The proposed rule would move the system in the opposite direction, making it more political, less predictable, and less capable of producing the discoveries, workforce, and public trust needed to improve health over time.
III. The Proposed Rule Would Weaken Efforts to Create Equal Opportunities for Health for Everyone in the Nation
Health Equity is Essential to Effective Public Health
Health equity means ensuring that everyone has a fair and just opportunity to be as healthy as possible.[26] That requires making visible and understanding differences in health by race, income, sex, geography, and other characteristics, along with addressing underlying drivers of health differences, including discrimination, access to quality schools and jobs, and fair and responsive representation at all levels of government.
Health equity is a form of DEI, which encompasses strategies to nurture the talent inherent in every community and group of people, to create equal opportunities to thrive, and to ensure people from every walk of life feel seen, heard, and valued. Robust research and practice demonstrate that well-designed health equity efforts can not only close health gaps but also improve health outcomes for all populations.[27] It is not a zero-sum exercise where some lose and some gain. For example, doula access programs designed to address disparities in maternal mortality have led to reductions in C-section rates for pregnant patients of all races.[28]
Accordingly, health equity is fundamental to effective public health practice.[29] Health outcomes are shaped not only by clinical care but also by social, economic, environmental, and structural factors.[30] [31] [32] Federal health programs rely on the ability to measure and respond to differences in outcomes across populations in order to allocate resources effectively, design targeted interventions, correct flaws in systems, and evaluate program performance.
Agencies, researchers, and community organizations rely on population-level data to identify disparities across areas such as chronic disease, maternal and infant health, infectious disease, behavioral health, and access to preventive services.[33] These analyses are essential to directing federal investments to populations with the greatest need, tailoring interventions to local conditions, and evaluating program effectiveness.[34] Public health priorities, including disease surveillance, reducing maternal mortality, increasing vaccination uptake, addressing opioid-related harms, and expanding access to primary care, depend on understanding how and why outcomes differ across populations. Limiting these analytical and programmatic functions would weaken the evidence base for effective intervention design, reduce the ability of programs to respond to documented disparities, and ultimately diminish the effectiveness of federal health programs in improving outcomes and closing persistent gaps in care.
Restrictions on DEI Activities Could Harm Program Effectiveness
The proposed rule’s restrictions on “illegal DEI”-related activities raise significant concerns for federally funded health programs, especially because such intentionally vague definitions have facilitated the targeting of lawful and essential health equity efforts.[35] Recent federal actions have already reduced support for disparities-related research by cutting or terminating NIH grants, including grants at the National Institute on Minority Health and Health Disparities, affecting clinical trials and research focused on American Indian, Alaska Native, Asian, Black, Hispanic, and Native Hawaiian and Pacific Islander populations, as well as HIV research and prevention work.[36] At the same time, race-neutral policies that ignore the role of racism can perpetuate inequities in health policy and care delivery by discouraging the use of racism-conscious approaches that depend on community engagement, policy evaluation, and attention to how neutral policies produce unequal outcomes. [37]
Many established public health practices are designed to ensure that programs are accessible, responsive, and effective for diverse populations, including culturally and linguistically appropriate services, targeted outreach, workforce training on cultural competency, and community engagement strategies.[38] These approaches are grounded in decades of public health research and implementation science demonstrating their effectiveness. Moreover, health equity strategies help to create interventions that improve systems, services, and supports for all people.
These approaches are operational tools, not ideological initiatives. Framing them otherwise reflects a misunderstanding of their scientific and programmatic basis. Vaccination campaigns, clinical trials, cancer screening programs, maternal and child health initiatives, and chronic disease prevention efforts frequently depend on tailored outreach to improve participation among populations with historically lower access to care. Similarly, efforts to diversify the physician workforce have the added benefit of increasing the number of physicians practicing primary care and serving in underserved communities.[39]
To the extent these activities are restricted or discouraged, even indirectly, the effectiveness of federally funded programs may be reduced.[40] Experience shows that ambiguity regarding permissible activities will also lead recipients to narrow or eliminate otherwise allowable practices to mitigate compliance risk. This can result in reduced outreach, diminished use of demographic and outcome data, and less effective engagement with underserved populations.[41] The cumulative effect may be weaker program participation, reduced trust between communities and health systems, and diminished effectiveness of federal investments intended to improve population health.
Impacts on Affected Populations
The proposed rule would have sweeping effects on populations served by federally funded health and social service programs, not merely on research, state, or university grantees. By prohibiting activities that “promote, encourage, subsidize, or facilitate” so-called “gender ideology” and by creating uncertainty about whether recipients may consider race, national origin, sex, disability, or other characteristics in program design and service delivery, the proposed rule would chill core functions across community health centers, Title X family planning providers, Ryan White HIV/AIDS programs, homelessness services, navigator programs, Medicaid-related outreach initiatives, women’s health grants, and disability-focused services.[42] These programs routinely depend on targeted outreach, demographic data collection, language access, and culturally responsive care to identify need, direct resources, and administer services effectively.
The practical effect of these restrictions would extend across nearly all affected populations. Recipients may reasonably respond by limiting or eliminating activities that could be characterized as DEI-related under the proposed rule, including data collection on disparities, provider training, community health worker programs, language access services, and targeted outreach.[43] That chilling effect would reduce the ability of federally funded programs to reach populations with the greatest barriers to care and would undermine implementation of services that are expressly intended to address documented inequities.
The proposed rule’s restrictions would be especially harmful where federally funded programs are designed to respond to well-documented disparities. For LGBTQ+ individuals, federal funding has supported efforts to identify disparities, collect sexual orientation and gender identity data, train providers, and deliver nondiscriminatory care for communities that experience higher rates of mental health conditions, substance use disorders, HIV, sexually transmitted infections, and barriers to access care.[44] [45] [46] [47] Those activities could be discouraged or curtailed if recipients fear that data collection, outreach, or training will be viewed as facilitating prohibited “gender ideology” activities under the proposed rule.[48] The result would be reduced outreach, less accurate data, and weaker access to culturally competent services, all of which would undermine federally funded efforts to address persistent disparities.
Immigrant communities would face similar harms. Many federal programs use language access services, culturally and linguistically appropriate materials, and community-based outreach to ensure that vaccination campaigns, emergency alerts, chronic disease management, and preventive services reach all households, including mixed-status families.[49] If grantees believe that these activities could be scrutinized under the rule’s provisions limiting DEI-related work or considering national origin and related characteristics, they may scale back or eliminate them to avoid compliance risk.[50] That would reduce participation in public health and treatment programs and weaken trust in public institutions, especially where services depend on community navigators or bilingual staff. This ultimately jeopardizes population health and wellbeing for all communities.
The proposed rule could also disproportionately affect women, including women’s health research which has long seen underinvestment; maternal mortality and morbidity prevention efforts at a time when pregnant and postpartum women in the U.S. are dying at exponentially higher rates than in other wealthy nations; and sexual and reproductive health programs which are essential to women’s wellness across the life course.[51] [52] [53] Collectively, the proposed changes could deepen the inequities women already experience, disrupt essential research, and hinder evidence-based interventions critical to improving women’s health from adolescence to menopause.
People with disabilities would likewise be affected. Programs funded through the Administration for Community Living, Protection and Advocacy systems, independent living centers, and related grant streams often exist to reduce barriers to access, support community integration, and provide tailored assistance to people with different functional needs.[54] If the proposed rule is read to discourage attention to disability-related disparities or accommodations, recipients may hesitate to maintain targeted services, expert support, or outreach to people with disabilities. That would make it harder for programs to fulfill their statutory purposes and would be especially concerning where grant-funded services are intended to promote independence and access to care.
Limits on Disparate Impact and Root Cause Inquiry Could Undermine Effective Public Health
The proposed rule would add a new provision, titled “Prohibition of Using Federal Awards To Promote or Support Theories of Disparate-Impact Liability,” which would bar the use of federal financial assistance to promote or support theories that impose disparate-impact liability based on federally protected characteristics such as race, sex, or age.[55] The provision would direct agencies and pass-through entities, to the maximum extent permitted by law, not to administer awards in a manner that promotes or supports disparate-impact theories, including through terms, conditions, or guidance, and would direct recipients and subrecipients not to use federal award funds for that purpose unless expressly required by law. It would also allow internal statistical or demographic analysis for internal use, so long as that activity is not funded by the federal award and is not used in connection with award activities.
Read alongside the proposed unlawful-DEI provisions, § 200.218 would create substantial uncertainty for public health work that depends on examining how facially neutral policies operate in practice.[56] That uncertainty could chill research, program evaluation, data collection, and policy analysis examining racial, ethnic, sex-based, disability-based, or other disparities, even where the work is necessary to identify root causes and design effective interventions. Recipients of federal financial assistance may reasonably conclude that efforts to analyze differential outcomes, disaggregate data, or test structural remedies carry regulatory risk if those activities are perceived as advancing disparate-impact theories.
That is especially problematic because much of public health depends on identifying how neutral policies produce unequal outcomes.[57] Work on housing, transportation, criminal legal systems, environmental exposure, and healthcare access has long shown that disparate outcomes often reveal structural barriers that can be addressed through policy change, implementation reform, or enforcement.[58] This type of analysis does not rest on proving discriminatory intent; it examines how rules and practices operate in the real world and identifies opportunities to redesign systems so they work better for everyone.
Accordingly, disparate impact analyses and enforcement have helped to secure language access services in hospitals, resulting in more equitable care, fewer medical errors, and lower costs; to limit the placement of factories that spew pollution in low-income communities and communities of color; and to mitigate the harms of artificial intelligence use in healthcare, where discriminatory intent is nearly impossible to establish whereas discriminatory impacts are common.[59]
The proposed rule would also exacerbate existing deficiencies in socio-demographic data and data disaggregation. Many federal, state, and local datasets already contain missing or inconsistent race, ethnicity, language, disability, and sexual orientation and gender identity (SOGI) information, which limits the ability to measure disparities and target resources.[60] [61] If recipients fear that collecting, disaggregating, or analyzing these data could be viewed as supporting disparate-impact theories, they may reduce or abandon these activities, widening information gaps and weakening the ability of agencies to evaluate whether federal investments are improving health outcomes.
Lessons From the Past 17 Months
Recent experience demonstrates that changes to federal grantmaking are not implemented in a narrow or isolated manner. Instead, when new layers of political review, administrative controls, or funding conditions are introduced, they tend to produce system-wide effects that reshape how grants are designed, awarded, and administered across agencies.[62]
In the past 17 months, federal grantmaking has become increasingly subject to political and administrative interference at nearly every stage of the lifecycle.[63] New review layers embedded in core grant infrastructure, including systems used to post funding opportunities and process payments, have contributed to delays in the release of Notices of Funding Opportunities (NOFOs), slower award decisions, and interruptions in routine disbursements.[64] [65] [66] [67] In several cases, additional review requirements applied outside of established agency processes have limited or delayed the availability of appropriated funds.[68] [69] [70]
At the same time, agencies have reportedly modified grant criteria, added new terms and conditions, and revised or removed funding opportunities in ways that reflect shifting policy priorities rather than programmatic continuity.[71] [72] [73] These actions have included narrowing eligibility for certain types of research and programmatic work, introducing new compliance conditions, and revisiting or terminating previously awarded grants.[74] [75] [76]
Across the system, these developments have increased uncertainty for grantees and introduced additional administrative burden into routine grant operations.[77] The cumulative effect has been slower fund disbursement, greater variability in award timelines, and increased risk of disruption to ongoing projects, including in areas where funding has already been appropriated by Congress.[78]
Long-Term Health Consequences
When funding uncertainty leads to reduced program scope or delayed implementation, the consequences extend beyond administrative compliance and directly affect public health outcomes.[79] Disruptions in prevention and treatment programs can lead to delayed diagnosis, reduced service uptake, and interruptions in continuity of care, particularly for populations that rely heavily on federally funded services.[80] Reductions in data collection and research capacity limit the ability to identify emerging health trends and evaluate intervention effectiveness.[81]
Over time, these effects contribute to widening disparities in health outcomes and reduce the effectiveness of federal investments intended to improve population health.[82] They may also increase overall healthcare costs by shifting care from preventive and community-based settings to more acute and emergency care settings, where treatment is more expensive, and outcomes are often worse.
IV. The Proposed Rule Would Create Instability for Federal Grant Recipients and the Communities They Serve
Federal grants and cooperative agreements are the backbone of many health, social service, education, and research systems, especially in communities with limited local resources. Nonprofit organizations, public health agencies, hospitals, universities, and state and local governments rely on predictable, multi-year awards to hire staff, sustain services, build partnerships, and plan for long-term impact. When grant conditions are stable and decisions are made on the basis of merit and compliance, recipients can focus on improving outcomes and meeting community needs; when awards become subject to abrupt political reversal, recipients must divert scarce capacity to crisis management, contingency planning, and risk mitigation.
The proposed rule would substantially increase instability across the federal grants landscape by allowing agencies to suspend or terminate awards whenever they conclude that a grant no longer advances agency or presidential priorities, even where the recipient is otherwise meeting performance, fiscal, and compliance requirements.[83] By expanding termination authority and tying it to fluid and largely subjective notions of “alignment,” the proposed rule would make every stage of the grant lifecycle more uncertain—from application and award to implementation and closeout. This would be particularly damaging for multi-year initiatives, such as clinical trials, longitudinal studies, workforce training pipelines, and community-based public health programs, which depend on continuity to deliver impact.[84] [85]
For many grantees, federal funding is not easily replaced. When an award is terminated midstream—or when renewal and continuation are perceived as politically contingent rather than performance-based—organizations may face existential financial risk. They may be forced to lay off staff, end critical programs abruptly, cancel community commitments, or walk away from infrastructure built with prior federal investments. In the research context, terminating grants midstream can render years of work and data collection nearly useless, leaving unanswered questions and undermining trust among research participants and community partners.[86] It can also mean loss of access to investigational treatments for clinical trial participants. The collateral damage is borne not only by institutions, but by patients, families, and communities who lose access to services and opportunities.
The proposed rule would also make planning and budgeting more difficult for state and local governments, tribal nations, and safety-net providers that braid and blend multiple federal funding streams. If agencies gain broad discretion to withdraw grants for ideological reasons unrelated to performance or compliance, these entities will face new fiscal and operational uncertainty on top of existing budget pressures. This uncertainty will be felt most acutely in communities where federal grants constitute a large share of the public health and social service infrastructure. In such places, instability in federal awards can translate directly into closed clinics, reduced outreach, shorter program hours, and lost capacity to respond to emergencies.[87]
Existing Oversight Mechanisms Already Protect Against Fraud, Waste, and Abuse
Existing oversight tools already allow agencies to address genuine problems such as noncompliance, misuse of funds, or failure to meet performance goals. Financial audits, programmatic reviews, site visits, corrective action plans, and enforcement mechanisms provide targeted ways to protect taxpayers and ensure accountability.[88] [89] Creating a broad new power to terminate grants based on shifting political priorities does not strengthen oversight; it simply introduces risk and volatility for compliant organizations and the communities that depend on them. Rather than layering on politicized termination authority, federal policy should focus on strengthening transparent, fair, and consistent enforcement of the robust mechanisms that already exist.
RWJF supports strong accountability measures for federal financial assistance. Taxpayer dollars should be spent responsibly, transparently, and in accordance with applicable laws and regulations, and recipients should face meaningful consequences when they misuse funds or fail to meet their obligations. But the proposed rule appears to assume that significantly greater political oversight is needed to ensure accountability and prevent fraud, waste, and abuse. RWJF is concerned that this increased instability will chill participation in federal programs, particularly among community-based organizations, smaller nonprofits, rural providers, and institutions led by or serving historically marginalized communities.
The nation benefits when federal grantmaking is both accountable and predictable. Existing audit, monitoring, and enforcement systems can and should be improved where they fall short, but the answer is not to supplant them with a system that privileges political oversight over professional, legal, and scientific standards. The proposed rule risks weakening that balance by layering new political controls on top of already robust safeguards. This could weaken the reach and effectiveness of federal programs and undermine efforts to improve health and opportunity across the country.
V. Conclusion
The proposed revisions to the Uniform Guidance would have far-reaching consequences for health research, public health programs, healthcare delivery, nonprofit organizations, and communities across the country. Although framed as administrative reforms to improve transparency and accountability, the changes would fundamentally alter how federal grants are awarded, managed, and sustained, and would do so in ways that increase political influence while heightening instability for recipients and the communities they serve. OMB has not provided a sufficient evidence-based justification for these sweeping changes or addressed the documented risks to program effectiveness, scientific integrity, and public health outcomes.
As described in these comments, the proposed rule would make it more difficult to understand and address barriers to health, undermine evidence-based decisionmaking, increase political control over scientific and programmatic judgments, create new vulnerabilities for grantees, and weaken the partnerships that enable federal programs to improve lives. It would narrow the space for health equity and DEI work that helps systems perform better for everyone, subordinate peer review and expert assessment to political review, and expand the use of termination authority in ways that threaten long-term research, workforce development, and community-based initiatives.
The nation’s health challenges require more evidence, more innovation, and stronger collaboration, not greater uncertainty and politicization in the grants system. Federal financial assistance is most effective when decisions are guided by expertise, accountability, transparency, and community need, supported by clear legal standards and robust oversight. OMB’s proposed rule moves federal grantmaking away from these principles and would ultimately diminish the effectiveness and credibility of programs intended to serve the American people.
For these reasons stated above, RWJF strongly opposes the proposed rule and urges OMB to withdraw the proposal in its entirety. At a minimum, OMB should extend the public comment period and undertake a more comprehensive and inclusive stakeholder engagement process, with agencies, recipients, communities, and experts, before proceeding with changes of this magnitude.
We have included numerous citations to supporting research, including direct links to research. We direct OMB to each of the materials we have cited and made available through active links, and we request that the full text of each of the studies and articles cited, along with the full text of our comment, be considered part of the formal administrative record for purposes of the Administrative Procedure Act. If OMB is not planning to consider these materials part of the record as we have requested here, we ask that you notify us and provide an opportunity to submit copies of the studies and articles into the record.
[1] Regulation for Federal Financial Assistance, 91 Fed. Reg. 32,198 (proposed May 29, 2026) (to be codified at 2 C.F.R. pts. 1, 25, 170, 175, 176, 180, 182, 183, 200, and scattered pts. 300–6600).
[2] 91 Fed. Reg. at 32247.
[3] 91 Fed. Reg. at 32250.
[4] Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. pt. 200 (2026), https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200.
[5] Tyler Sear, What is 2 CFR Part 200 Uniform Guidance?, Smart Grant Solutions (Jun. 17, 2026), https://www.smartgrantsolutions.com/2-cfr-part-200/.
[6] 91 Fed. Reg. at 32250.
[7] 91 Fed. Reg. at 32248.
[8] Exec. Order No.14332, 90 Fed. Reg. 38929 (Aug. 7, 2025).
[9] Exec. Order No. 14281, 90 Fed. Reg. 17537 (Apr. 23, 2025).
[10] Exec. Order. No. 14303, 90 Fed. Reg. 22601 (May 23, 2025).
[11] Loren Dejone Schulman & Kate Kohn, This Proposed Rule Could Change American Science Forever. We Read It So You Don’t Have To, FAS (Jun. 4, 2026), https://fas.org/publication/this-proposed-rule-could-change-american-science-forever/.
[12] Erica Kimmerling & Amanda Vernon, New Draft Rule Threatens To Undermine Existing Merit-Based Government Investment in Science By Creating A More Opaque, Politicized, and Inefficient Funding Process, ASTC (Jun. 9, 2026), https://www.astc.org/policy/omb-rule-threatens-merit-based-funding/.
[13] U.S. Department of Health and Human Services (HHS), Grants.gov (Last visited Jun. 25, 2026), https://www.grants.gov/learn-grants/grant-making-agencies/u-s-department-of-health-and-human-services-hhs.
[14] HRSA, Apply for a Health Workforce Grant, HRSA Health Workforce (Jun. 16, 2026), https://bhw.hrsa.gov/funding/apply-health-workforce-grant.
[15] Josh Michaud et al., CDC’s Funding for State and Local Public Health: How Much and Where Does It Go?, KFF (Apr. 7, 2025), https://www.kff.org/other-health/cdcs-funding-for-state-and-local-public-health-how-much-and-where-does-it-go/.
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About the Robert Wood Johnson Foundation
RWJF is a leading national philanthropy dedicated to taking bold leaps to transform health in our lifetime. Through funding, convening, advocacy, and evidence-building, we work side-by-side with communities, practitioners, and institutions to get to health equity faster and pave the way together to a future where health is no longer a privilege, but a right.
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