ASPET submitted a comment to express strong concerns and objections to the Office of Management and Budget’s (OMB) proposed revisions to 2 CFR 200 (Docket OMB-2026-0034).

ASPET respectfully recommends that OMB:

• Retain the current 2 CFR as guidance, rather than reclassifying it as a government-wide regulation.
• Retain the current § 200.205 to maintain peer review as the basis for award decisions.
• Retain the current § 200.340 to maintain the criteria for termination to those outlined in the grant agreement and remove the undefined “national interest” as a criterion.
• Retain the current § 200.432 to maintain the allowable usage of grant funds to attend conferences to disseminate research findings.
• Retain the current § 200.454 to maintain the allowable usage of grant funds to pay for scientific society dues to further advance workforce development.
• Retain the current § 200.461 to maintain the allowable usage of grant funds to pay for publishing costs to make findings publicly accessible.