The University of California recently submitted comments in response to the United States Office of Management and Budget (OMB) proposal to revise several parts of the Regulation for Federal Financial Assistance located in title 2 of the Code of Federal Regulations (CFR). This section of regulations affects how federal research grants are awarded and administered. As stated in the letter:

If finalized as drafted, the Proposed Rule would have consequences well beyond UC. It would make the federal assistance environment less predictable and less stable, particularly for multi-year research efforts that depend on continuity. That uncertainty would not be borne only by institutions; it would affect patients awaiting clinical advances, communities relying on applied research, students and trainees building careers, and federal agencies carrying out long-term missions. It would also undermine the nation’s global competitiveness by sidelining the best available science, constraining innovation, and limiting the ability to deliver timely results.

UC’s position is clear: OMB should withdraw the Proposed Rule. The proposed revisions are sweeping in scope and would fundamentally reshape the administration of federal financial assistance. Given their significance, stakeholders have not been afforded a sufficient opportunity to provide meaningful input. If OMB wishes to pursue revisions to the Uniform Guidance, it should withdraw this proposal and issue a new one following a more robust stakeholder engagement process and a meaningful opportunity for public comment.

In the absence of complete withdrawal, the letter focused on several key sections in which UC urged substantial revision. The topics impacted by these sections include:

  • Merit review and award selection,
  • Research security and foreign collaborations,
  • Allowable costs,
  • Publication and open access, 
  • Termination and suspension of awards, and
  • Increased administrative and compliance burdens for federal agencies and funding recipients by imposing new documentation, review, oversight, procurement, subrecipient monitoring, financial management, and closeout requirements,

Additional comments were submitted from specific locations and entities around the UC system, including the following letters addressing issues impacting scholarly communication:

Other letters of interest from the scholarly communication community include:

The proposed regulation received nearly 500,000 comments in total according to Regulations.gov as of July 15, some of which can be found on the Regulations.gov site alongside the proposed rule.

Share
 

Tags: ,