Editor’s note: Today’s post is by Darla Henderson, member of the SSP Advocacy Task Force, and CEO and Executive Director of the Federation of American Societies for Experimental Biology.

Much has been written in a brief time on the Office of Management and Budget proposed rule 2CFR Part 200 (May 29, 2026). The 2CFR Part 200, commonly called the “Uniform Guidance,” addresses how organizations receiving federal financial grants and support may use those funds. Much more will be written in the next months.

The proposed OMB rule is a 412-page-long significant rewrite of the guidance governing all federal grants and cooperative agreements, and proposed changes would apply to Fiscal Year 2027, starting October 1, 2026. These are not minor changes — the proposed rule entirely reworks the concept of federal grants. Changes span 456 sections of the regulations, with 52 new subsections and 375 reworded sections. The rule would impact the entirety of government grant-making across the United States.

Equally as important, the rule would make 2CFR Part 200 a binding regulation instead of guidance. In and of itself, that singular provision, changing this document from guidance to a binding regulation, is transformative, and would impact the risk assessment organizations make in determining whether to apply for grants. Notably, smaller organizations without significant infrastructure, endowments, or reserves would be disenfranchised from participating in funding opportunities.

The Transformative Impact on Scholarly Societies

On a long plane ride to Las Vegas, where I was attending a member society annual conference, I started to read the OMB proposed rule and naturally focused on the impact on my community: scholarly societies. The proposed rule has a considerable number of components that would negatively impact scholarly societies.

There are many points of view I considered as I read and debated the OMB proposed change. More to come in another post about the potential impact on researchers, grant recipient organizations, science, taxpayers, the US, and the world; the tl;dr summary is stakeholders would each experience negative outcomes. This short piece starts to consider the impact on scholarly societies — not because they are the only stakeholder — but because they are, by definition, by governance, and by operations, representative of the values and practices communities determine are important to advancing a discipline. Societies were conceived and founded by disciplinary communities, individuals who came together and aligned on how to best advance the discipline. Today, when done well, they are led by community-centered governance working in a productive partnership with operational staff; in the case of my organization, scientists from the biological and biomedical community. The academic value of this partnership is tremendous and yet not well-quantified. We can, and should, better define the value-add, starting with these two broad brushstrokes that demonstrate the clear economic value of scholarly societies.

Scholarly societies serve as a vital connective tissue within the American economy. Societies provide the infrastructure through which the value of federally invested research funds is realized: dissemination, validation, and accumulation of new findings. Societies operate journals that publish research findings funded by the federal government. Societies convene meetings where new findings are discussed, vetted, and ideas exchanged. Societies educate, maintain, and support the peer review networks that assess merit. Societies provide career development and educational offerings that create a workforce serving the nation.

Denying grantees access to publication fees, conference attendance, professional memberships, international collaborations, providing grant termination for convenience, and eliminating merit-based review as the underpinning of the system — this is not cost-cutting — it would be a transformative structural defunding of scholarly societies and thus the ecosystem and US economy. That is what the proposed rule would do. Let’s briefly look at this through two lenses — the direct economic impact from scholarly societies, and the downstream impacts.

• Lens 1: The direct economic impact resulting from associations. The American Society of Association Executives (ASAE) commissioned a 2024 study of 20,000 associations that demonstrated trade and professional associations generate $116B in revenue, and nonprofit organizations as a whole are responsible for >5.6% of the US GDP. More than 272K association-led events serve 52M participants annually, providing taxes that fuel local and state economies. Scholarly societies are a vital subset of that data — an estimated 20% of the total association universe.
• Lens 2: Downstream US biotech, pharma, defense, and tech companies rely on the value delivered by and through scholarly societies. For example, basic and applied scientific research, funded by the federal government, with structural supports from scholarly societies, fills the pipelines for private sector innovation 10-15 years downstream – the loss of this pipeline would be enormous. Operationally, scholarly societies perform specific technical functions that no government agency replicates. Eliminating their funding would create a gap — not only for the communities served by societies — but also for the economy and the ecosystem.

The OMB proposed rule would not only be operationally damaging for scholarly societies but would represent both a loss of competitiveness for America and a policy failure. The gap that the OMB proposed rule would create by structurally defunding societies also undermines the administration’s own goal of producing high-quality, trustworthy science.

The Gold Standard Science Executive Order calls for science that is reproducible, transparent, collaborative, interdisciplinary, subject to unbiased peer review, and without conflicts of interest. The proposed OMB rule would contradict every single one of those tenets, counter to the administration’s own executive order, by replacing unbiased review with political appointees, banning international collaborations (a cornerstone of how science is done, how science advances), and limiting funding to administrative priorities, changeable at any moment.

The Transformative Scale of Impact Extends Beyond Publishing, Beyond Scholarly Societies

As I thought more about the proposed rule and the potential impact, I remembered the true purpose of 2CFR 200, and the scale hit hard. 2CFR 200 has broad applicability to federal funds. Expansively broad applicability to federal funds — including state and local government pass-throughs. A few examples include:

• Education grants (public and private)
• School nutrition programs
• Public health and human services programs and hospitals
• Community development block grants for housing
• Infrastructure programs
• Economic development
• Public safety
• DOJ
• Disaster relief
• Native American governing bodies
• Non-profit efforts

…the food bank on the corner, the domestic violence shelter in the next city over, the schools in rural and urban America, roads, utilities…the list goes on.

We Must Get This Moment Right

During two Uber rides in Las Vegas, I met drivers who shared that they were involved with nonprofits — one addressing homelessness, the other, addiction. We had interesting conversations about the OMB proposed rule and how it would negatively impact these charities. I left with their business cards in hand, and they left with mine, where I carefully wrote the URL to the OMB regulations site for comments. Will they engage? Possibly. Regardless, creating broader awareness is critical — and that is also a mission we must each take on — whenever, wherever, however we can, we engage.

Positioning our Comments as Transformative

The OMB opened the public comment period through July 13, 2026, although extensions have been requested. Notably, a thoughtful multi-sector joint letter organized by the American Association for the Advancement of Science (AAAS), Research!America, and others spells out the complexity of the proposed rule and the fact that this never appeared on the Unified Agenda of Regulatory and Deregulatory Actions as a regulatory action being undertaken by OMB. This letter also points out that OMB itself envisions the proposed revisions as ‘far-reaching.’

With or without the extension, the OMB is required by law (specifically, the Administrative Procedure Act) to substantively respond to all significant, relevant, and fact-based comments that could alter the proposed rule. This detail makes responding to the OMB proposed rule an “all hands on deck” moment for all of us. Creating a significant collection of thoughtful, deliberate individual responses focused on personal impact demonstrates the truly transformative nature of this proposed rule — this is the central path we can all engage in today.

Without focusing on the additional advocacy actions that are happening or likely to happen if this rule proceeds, and without dismissing the submission of op-eds as also being important for Congress to understand and weigh the size of potential disruption, the readership of this blog is both well-informed and capable of creating deliberate responses that showcase the personal impact and must be responded to by OMB. A large collection of personal impact comments would create a substantive record that serves both valuable legal purposes (if the rule advances, there is clear standing for many stakeholders) and provides levers for Congress to take action under the auspices of the Congressional Review Act down the road.

Ten Tips for Responding to the OMB Proposed Rule

It is challenging to learn in a singular blog post how to properly comment on the OMB ruling to avoid getting your comments tossed out (a reminder — and yes, also to myself — there is an entire profession of smart policy experts who are in this field as their career calling). However, a few starting pointers here may save a number of valuable comments — and that is the goal. Not comprehensive, but a big-picture approach with some basic practical tips that improve our collective record. Here are my top ten tips on taking your response forward:

1. Start by taking time to thoughtfully develop and debate your strategy. Review the proposed rule and identify those issues impacting you and your organization. Map the position you wish to take in support of those issues.
2. Respond to as many of the issues that are applicable to you and the stakeholders you represent. Yes, The Scholarly Kitchen is a publishing-focused audience and can be expected to comment on publishing impacts. I encourage you — do not limit yourself to publishing as the sole issue you address. The proposal has broad and expansive impacts, and I challenge each of us to find something more than publishing to address in our comments.
3. Begin each comment with the appropriate section number in brackets. This creates clarity and context for your comments to avoid any misinterpretations.
4. Use personal terms to describe the impact. Specifically describe the harm the proposed rule would do. Respond in your own words. Form letters are less powerful and can be grouped by OMB and count as one (caution with copying or pasting text for the same reason). Sign-on letters are treated as a singular comment by OMB — if you have already signed on, do not stop — engage and create your own separate response.
5. Provide data and be specific. Evidence-based critiques — concrete data, scientific evidence, or cost-benefit analysis are powerful. Cite legal and statutory challenges where feasible. If you believe the OMB is exceeding its authority, cite the section of the authorizing statute for OMB that is exceeded. Offer an alternate solution, where feasible, to the challenges identified and feel free to provide exact proposals for alternative text.
6. Avoid ad hominem attacks, blanket statements without a rationale, off-topic remarks, and the slippery slope of if/then. In short, do not make this personal to any individual or group of individuals in the administration or OMB; keep it focused, do not try to make connections with other actions happening elsewhere.
7. Check with your employer in case there are internal policies that you should be aware of with respect to using your organizational email or professional title. You have the option to submit anonymously, or with your email.
8. Mind the limitations — comments are limited to 5,000 words and up to twenty files may be attached, each under 10MB, with some limitations on file types (docx, pdf, txt, xml are all accepted).
9. Beat the deadline. The final deadline is July 13, 2026 — but a word of caution: the system could easily be overwhelmed or unavailable as we approach the deadline. Complete your comments and get them in as soon as you can. (Note: We are operating under the assumption that an extension will not be granted and while we would welcome the additional time, we cannot consider it a guarantee.)
10. Submit directly using this link (OMB-2026-0034). No need to submit elsewhere — this takes you directly to regulations.gov to ensure your comments are submitted and received.

There are many excellent information sources available outlining the multitude of challenges emerging in the OMB proposed rule and various strategies for addressing each issue. In addition to the insightful voices at Science,  you will encounter some new-to-us voices, including Ropes & Gray and Sarah M. Trimmer (who is deep-diving daily into one of the many provisions, and has created a handy Google Drive “OMB Comments for Busy People“). I feel certain that the June issue of Clarke & Esposito’s The Brief will have welcoming insights (although it publishes at the end of the month — Michael, we aren’t sure we can wait!).

The main message for readers of The Scholarly Kitchen is: act! Think broadly beyond your safe zone of publishing, develop your strategy, and submit your comments. This is our responsibility. This is our time. This is how we stand stronger together.