July 9, 2026
The Honorable Russell Vought
Director
Office of Management and Budget
725 17th St, NW
Washington, DC 20503
Re: OMB-2026-0034, Proposed Revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Dear Director Vought:
The Society of Hospital Medicine (SHM) thanks you for the opportunity to comment on the Office of Management and Budget’s (OMB) Notice of Proposed Rulemaking (NPRM) concerning the Uniform Guidance governing federal grants. The proposed revisions to 2 CFR Part 200 published in the Federal Register on May 29, 2026, “Regulation for Federal Financial Assistance.” The revisions under consideration will reach every corner of medicine: from the foundational research behind new treatments, to the programs that train our nation’s physicians, to the public health and health services research that improves the quality and affordability of care.
Hospital medicine researchers have made tremendous contributions to science, both in bench research as well as translational research that directly reaches patients. Federally funded hospitalist research has included work on many topics, including; delirium prevention and management, substance abuse treatment, cellular aging and longevity, hospital at home outcomes, diagnostic error prevention through teamwork, effective prevention of pulmonary embolism in hospitalized patients, to name only a few. Hospitalist researchers across the United States have been awarded millions of dollars in National Institutes of Health (NIH) grants, including from National Heart Lung and Blood Institute (NHLBI), National Institutes on Aging (NIA), and Agency for Healthcare Research and Quality (AHRQ). Centers for Disease Control and Prevention (CDC) and Department of Veterans Affairs (VA) have
also provided funding for hospitalist researchers to study topics such as infection prevention and control, hand hygiene, and central line infection safety and appropriateness.
Up and coming areas of hospital-based research include topics from improving emergency department (ED) boarding of admitted patients to genetic testing pathways for hospitalized patients, which would lend themselves to future federal grant applications. These types of research projects often take multiple years from planning and applying for grants, to receiving and conducting the work supported by the grant, to completing the research, publishing the findings, and translating the findings into clinical care at the bedside. Americans have long benefited from the medical research conducted by physician scientists, including hospitalists, to enhance patient care and safety while creating technological advancements to continue improving hospital care into the future.
We recognize and appreciate that the stated goals of this rulemaking include improved transparency, accountability, and stewardship of federal funds. These goals are widely shared across the medical research community. However, we respectfully but firmly oppose several of the proposed provisions. As drafted, they would do serious and lasting damage to the federal research enterprise that they intend to strengthen. We urge OMB to substantially revise or withdraw the provisions discussed below.
[200.205] The proposed rule would undermine, rather than protect, the objectivity of federally funded research.
The proposed revisions to §200.205 direct senior agency appointees to review proposals to ensure that discretionary awards “advance the President’s policy priorities,” while characterizing merit-based peer review as merely advisory. Peer review by independent subject-matter experts is the mechanism that has historically separated objectively meritorious science from politically convenient science. If funding decisions can be, or even appear to be, overridden based on alignment with the policy preferences of whichever administration is in office, the operative criterion for federal research support shifts from “is this the best science?” to “is this the science a given administration wants to hear?” That is not a marginal change; it strikes at the foundation of what makes publicly funded research objective in the first place. We respectfully urge OMB to retain the binding role of independent merit review in funding decisions and to remove language that subordinates expert review to political-alignment criteria.
[200.205] The displacement of merit review will degrade the overall quality of the research portfolio.
Quality control in science depends on rigorous, independent evaluation of methodology, feasibility, and significance — precisely what peer review panels are constituted to provide. Reducing peer review to an advisory formality, while elevating undefined standards without operational criteria, removes the primary safeguard against funding being directed toward weak, poorly designed, or non-reproducible studies. Over time, a portfolio selected partly on political alignment rather than scientific merit will simply produce weaker science: studies with smaller effect sizes accepted on faith, important confounders left unexamined, and rigorous but unfashionable proposals getting overlooked. We encourage OMB to preserve and strengthen, rather than dilute, the role of independent expert review as the primary determinant of award decisions.
[200.205; 200.300, 200.340] Entire areas of important research risk going unstudied, leaving critical public health questions unanswered.
When funding eligibility and award continuation depend on alignment with shifting policy priorities, investigators have a strong incentive to avoid proposing and reviewers and program officers have an incentive to avoid funding research on topics that are scientifically important but politically sensitive in any given moment. Combined with the broadened agency discretion to terminate awards under §200.340, this creates a chilling effect that would extend well beyond any single administration’s stated priorities. The result is not just that controversial questions get answered differently; it is that they may not get answered at all, potentially leaving enormous gaps in our understanding of disease states, treatment options, and population health questions. These gaps may then take a generation to fill once identified. We urge OMB to ensure that no provision of the final rule, directly or through the risk of a chilling effect, narrows the scope of scientific inquiry.
There are numerous diseases and conditions that impact populations differently. These include but are not limited to genetic-linked diseases, like Sickle Cell Disease and certain cancers, to conditions that have a disproportionate impact on a specific geographic or demographic population. It is imperative to fund research to study these conditions and explore treatments within impacted populations. We are deeply concerned these proposed revisions will set back advances in our understanding of a wide variety of diseases and treatments that will ultimately leave Americans sicker.
[200.340] The instability created by expanded termination authority will drive researchers out of the field or out of the country.
Biomedical and public health research requires long time horizons: clinical trials run for years, longitudinal cohorts for decades, and training a single independent investigator takes a decade or more of sustained support. Expanding agency discretion to terminate awards for reasons unrelated to performance or misbehavior introduces a level of instability that early-career researchers in particular cannot absorb. Faced with the prospect that a multi-year award could be terminated mid-stream for reasons disconnected from the scientific merit of their work, talented investigators — especially those early in their careers, and those with international mobility — will reasonably choose other career paths or relocate to research systems in other countries that can provide greater stability. Other nations are already actively recruiting U.S.-trained research scientists; this rule, as proposed, would accelerate that outflow. We urge OMB to narrow §200.340 so that termination for convenience is reserved for genuinely exceptional circumstances and is not available as a routine tool for redirecting the Federal research portfolio.
[200.205] The appearance of politicized funding decisions will erode public trust in science, possibly past the point of recovery.
Public trust in science rests substantially on the belief that scientific conclusions are arrived at through transparent, merit-based processes free from political considerations. If the public comes to believe — accurately or not — that federally funded research results are pre-shaped by which conclusions are politically acceptable, every subsequent finding from federally funded science becomes suspect. This would hold true regardless of political party or the actual rigor of scientific studies. This is an asymmetric risk: trust that took decades to build through consistent, transparent peer review can be lost very quickly, and once lost, it does not return simply because the underlying rule is later amended. We urge OMB to weigh this risk heavily, as it affects not just the research enterprise itself but the public’s willingness to accept and act on important findings related to health, safety, and medicine.
[§ 200.432] Requiring advance agency approval for conference attendance costs at the time of award is disconnected from the reality of research timelines and would limit the uptake of the very findings the award was intended to produce.
SHM appreciates the intent of this provision, which is to ensure that federal funds are used only for reasonable, necessary, and award-related conference costs. However, grant applications are often submitted years before investigators know what they will find, when results will be ready to share, or which professional meetings will provide the most appropriate audience for dissemination. Conferences are a primary channel for sharing federally funded findings with clinicians, researchers, policymakers, and other stakeholders – restricting this channel will serve to restrict dissemination and uptake of findings.
The burden would fall hardest on trainees, early-career investigators, and recipients at less-resourced institutions, who are least likely to have support for registration, travel, and presentation costs. Applicants should be permitted to budget conference attendance as a general category of anticipated award-related costs, with a certification that funds will be used only for reasonable, allocable, and directly related expenses, such as registration, travel, lodging, and presentation costs. Those costs would remain subject to ordinary agency review, documentation requirements, and audit standards. This approach would maintain accountability and preserve the dissemination activities necessary for federally supported work to serve its public benefit.
The cumulative harm from these provisions taken together would be irreparable.
Each of the provisions discussed above compounds the others. A research workforce that has dispersed to other countries or other careers cannot be reassembled on short notice. Long-term studies that are terminated mid-course cannot simply be restarted — the cohorts, the longitudinal data, and often the scientific opportunity itself are permanently lost. Public trust, once damaged, is exceptionally slow to rebuild. And research questions that go unasked during a period of chilled inquiry represent knowledge gaps that may never be filled, because the conditions that made the question answerable (available cohorts, funding windows, technological context) may not recur. For these reasons, the Society of Hospital Medicine does not believe the risk of harm from the provisions described above can be adequately remedied through future rulemaking, however well-intentioned.
Conclusion
The Society of Hospital Medicine shares OMB’s stated interest in transparency, accountability, and the responsible stewardship of federal research dollars, and welcomes engagement on alternative approaches that advance those goals without compromising the independence of merit review — for example, publicly stated funding criteria, strengthened conflict-of-interest standards within peer review, expanded post-award transparency reporting, and regular reporting to Congress on award outcomes. As such, we respectfully urge OMB to substantially revise the provisions identified above before issuing a final rule, and to consider withdrawing them from the current rulemaking pending further consultation with the scientific community.
Thank you for your consideration of these comments. If you have any questions or require further information, please contact Josh Boswell at jboswell@hospitalmedicine.org.
Sincerely,
Efrén C. Manjarrez, MD, SFHM
President
Society of Hospital Medicine