The U.S. Office of Management and Budget Targets the Research and Technology Enterprise

On May 29, 2026, the Office of Management and Budget (OMB) published a proposed rule that would substantially rewrite 2 CFR Part 200—the “Uniform Guidance” governing nearly every U.S. federal grant, cooperative agreement, and pass-through award. The 400-plus-page proposal would apply government-wide, affecting universities, research institutions, nonprofits, scientific and professional societies, and individual award recipients.

The Oceanography Society (TOS) is an international organization, however, these proposed changes could have a detrimental effect on international partnerships and collaborations among TOS members. TOS is working with dozens of scientific societies on a coordinated response to this potential change; however, comments from individuals will form a critical and powerful contribution to the public record. OMB is required to respond to all significant individual public comments before finalizing a proposed rule.

Public comments are due July 13, 2026. The proposed ruling changes have a proposed effective date of October 1, 2026 (start of FY 2027). Over 14,500 comments have been received so far, but every additional comment builds a stronger case.

Example provisions that will impact The Oceanography Society and our members

Political appointees control all competed awards (grants, etc.) [§200.205(b)]
Senior political appointees—not career scientists—would review discretionary grants before award decisions are made. Final decisions to fund can be based on ideologies or current Administration priorities. Peer review recommendations may be ignored.

Active awards can be terminated at any time and for any reason [§ 200.340]
Agencies would be permitted to immediately terminate awards that no longer align with agency or Administration priorities or shifting national interests, with no transition period for in-flight multi-year awards.

DEI, gender research, and related topics are banned as award conditions [§ 200.300(b)]
New prohibitions on using federal awards to support diversity, equity, and inclusion programs, along with other policy and ideology-based conditions.

Broad prohibition on international scientific collaboration [§ 200.220]
Federal funds would not support a bilateral or multilateral collaboration with a “covered” foreign country or entity.

Publication and journal costs [§ 200.461]
Publication and most journal subscription costs would be unallowable unless required by statute and/or approved in advance by the agency.

“Domestic-first” framework for research awards [§ 200.202(e)]
Except for certain limited circumstances, research and development awards generally would be limited to U.S. entities and partners.

Applicants can be denied based on organizational affiliations [§ 200.206]
Reviewers could weigh an applicant’s activities outside their research, including advocacy and organizational affiliations.

Conference attendance and costs, professional memberships, and communications [§ 200.432], [§ 200.454], and [§ 200.450]
Conference attendance, associated costs, and individual professional society membership require agency approval on an individual conference and membership and conference, and severe restrictions will be placed on public communication and engagement as well as issue advocacy (e.g., climate science, public health research, and equity research listed as “divisive ideologies”).

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