On May 29, 2026, the White House Office of Management and Budget published a proposed rewrite of the Uniform Guidance, the government-wide framework in 2 CFR Part 200 governing grants, cooperative agreements and other forms of federal financial assistance. Among its most consequential provisions is a requirement that agencies designate senior appointees to conduct a pre-issuance review of all discretionary awards.
The proposal says those reviewers must consider applicable law, agency priorities and the national interest. Where applicable, discretionary awards must demonstrably advance the president’s policy priorities, while scientific peer-review recommendations would remain advisory rather than binding on the senior officials making the final decision.
By the time the comment period closed on July 13, the docket had received 496,769 submissions, according to STAT’s reporting on the public-comment record.
What the Uniform Guidance actually is
The Uniform Guidance sits at 2 CFR Part 200. It provides government-wide rules covering how federal financial-assistance awards are made and administered, including cost principles, audit requirements, award conditions and termination procedures.
For research universities, it reaches grants and cooperative agreements from agencies including NASA, NIH, NSF and the Department of Energy. It does not, however, turn every federal research expenditure into a grant: federal procurement contracts operate under a different legal framework.
That distinction matters for lunar science, where university research awards can sit alongside commercial procurement contracts, mission hardware agreements and other funding mechanisms.
The proposal that alarmed the National Academies
The presidents of the National Academy of Sciences, National Academy of Engineering and National Academy of Medicine each submitted comments objecting to the proposal and later issued a joint public statement.
Their concern centered on independent scientific review. They argued that requiring political appointees to review research-grant proposals could weaken a system in which scientific merit has traditionally played a central role in deciding which projects receive support.
The proposed text is explicit about the shift. Agencies could continue using peer review, but those recommendations would have to remain advisory. Senior appointees or their designees would be required to exercise independent judgment rather than routinely defer to reviewers’ recommendations.
That does not abolish peer review. It changes where final authority sits.
Why the peer-review provision matters
Federal science agencies use different review structures, but outside specialists commonly assess technical merit before agency officials make funding decisions within statutory, budgetary and programmatic constraints.
Under the proposed §200.205, agencies would still run merit-review processes for discretionary awards. The difference is that the mandatory pre-issuance review would sit inside that process and could itself form the basis for deciding not to select an applicant.
The same section says discretionary awards must, where applicable, demonstrably advance presidential policy priorities. It also tells senior reviewers not to treat other recommendations as effectively binding.
For researchers, the practical question is therefore not whether scientific review disappears, but how much weight it retains when it conflicts with the judgment of the senior official conducting final review.
The termination-at-discretion provision
The proposal also expands and clarifies agency authority to terminate an award when, to the extent permitted by law, the agency determines that termination is in its interest.
The text specifically says that can include situations in which an award no longer advances program goals, federal agency priorities or the national interest as those priorities exist at the time of termination.
For a multi-year research project, that possibility matters because personnel, equipment purchases and experimental schedules may be planned years ahead. A change in administration or agency priorities could therefore affect an award after work has already begun, subject to the final rule and applicable statutes.
That creates a different planning environment from one in which investigators expect an award to continue unless performance, compliance or funding problems intervene.
What happens to publication and conferences
The proposed rule would also change which research-related costs can be charged to federal awards. Publication costs, including page charges, article processing charges and open-access fees, would generally become unallowable.
There are exceptions. Publication costs specifically required by federal statute, or approved in advance by an agency on a case-by-case basis, could still be permitted. The proposal does not create a general requirement for the government to approve the content of a paper before publication; the provision governs whether federal award money may pay the publication cost.
Subscriptions to business, professional, academic and technical periodicals would be unallowable. Professional or technical membership costs could remain allowable when necessary to fulfill award requirements, but they would require prior written agency approval.
Conference attendance would likewise be chargeable only when participation is expressly approved by the agency and included in the award’s terms and conditions.
The international collaboration clause
Another provision would prohibit recipients and subrecipients from using federal funds for bilateral or multilateral collaborations with defined covered foreign countries or covered foreign entities, unless an exception applies.
The proposal defines covered countries through existing statutes, executive orders and other federal law, including designations involving foreign adversaries, countries of particular concern and certain national-security restrictions. Its explanatory discussion specifically cites existing restrictions on NASA and bilateral work with China under the Wolf Amendment.
An exception could be authorized where federal law expressly permits it, or where the agency head or a designee determines that the activity poses no national-security risk and is in the United States’ national interest.
Separately, the proposed research-and-development provisions call for a domestic-first framework when agencies evaluate international elements. They also tell agencies to consider whether overseas participation supplies expertise, facilities, data, populations or other resources that are not reasonably available domestically.
The broader rulemaking pattern
The grant proposal is moving alongside other federal rulemakings affecting universities. Inside Higher Ed reported in September on proposed accreditation changes that would alter requirements for federally recognized accreditors and, through them, the colleges they oversee.
Treasury and the IRS have also proposed new rules governing racial nondiscrimination at tax-exempt private schools. The Treasury-IRS proposal would revise the standards under which private schools qualify for federal tax exemption and would apply across educational, admissions, scholarship, athletic and other policies.
These are separate rulemakings with different statutes, agencies and procedures. Their overlap is institutional: federal grants, accreditation and tax status can each affect how universities finance and organize their work.
What nearly 500,000 comments mean
The 496,769 submissions made the Uniform Guidance docket unusually visible. A University of North Carolina analysis conducted with STAT classified the comments that were publicly available for analysis and reported overwhelming opposition among that subset.
But a federal comment period is not a referendum. Agencies are required to consider significant substantive comments and explain important choices when issuing a final rule; the raw number of comments does not compel OMB to adopt or reject a provision.
The comment record does, however, give OMB a large body of objections, supporting arguments and proposed alternatives that it must work through as the rule advances.
What is at stake for lunar science specifically
Parts of lunar science rely directly on federal grants and cooperative agreements to universities and research institutions, so changes to 2 CFR Part 200 can affect those awards.
But one important Moon program sits outside that grant framework. NASA’s Commercial Lunar Payload Services initiative buys lunar delivery services through indefinite-delivery, indefinite-quantity contracts and task orders with commercial providers. Those procurement contracts are not themselves Uniform Guidance grants.
The distinction does not make the proposed rule irrelevant to lunar exploration. University investigators developing instruments, analyzing samples or conducting planetary-science research may still depend on grants and cooperative agreements governed by Part 200, even when the spacecraft or delivery service involved is purchased through a separate contract.
For those research awards, appointee review, termination authority, publication-cost restrictions and international-collaboration rules could all affect how projects are selected, budgeted and carried through to completion if the proposal is finalized substantially as written.
What comes next
The rule remains a proposal. OMB and the participating agencies must review the public record before issuing any final version, and provisions can be changed, dropped or retained during that process.
Any eventual final rule would also operate within statutes passed by Congress and would remain subject to administrative-law review in court. Whether particular provisions survive legal challenge would depend on the final text, the statutory authority involved and the administrative record supporting the agencies’ choices.
Congress retains its own role through appropriations, authorizing statutes and oversight of the agencies that fund scientific research.
For now, existing grantmaking continues while the proposal remains unresolved. Researchers submit applications, panels review them and agencies administer awards under the rules currently in force.
The May 29 proposed rule occupies 108 Federal Register pages. The paperwork is dense, but the questions inside it reach much further: who makes the final call on federal research money, how secure an award remains after it begins, and which costs and collaborations the government will agree to support.
