
OMB's Proposed Grant Rule — What Researchers Need to Know

A bi-weekly newsletter where I share news, opinion, grant opportunities, success tools and tips on personal growth.

Oliver's Note
OMB's Proposed Grant Rule — What Researchers Need to Know
On May 29, 2026, the Office of Management and Budgetpublished a proposed rulethat would reshape how nearly all federal research grants are awarded and managed.
Ars Technica's science editor John Timmercovered it in a pointed analysis piece; the underlying document is now open for public comment. Here's what it would do.
Peer review becomes secondary. The proposal formalizes a shift away from expert review as the deciding factor in funding. The document states that peer review "remains advisory and does not replace agency discretion." In practice, that means political appointees — not subject-matter staff — would make final funding calls, and they're instructed not to routinely defer to reviewers. Grant programs would also need to be "aligned with administration policies and priorities." The recent stepping back from paylines makes room for this close political oversight.
Grants could be canceled at any time. After losing 2025 court cases over grant terminations that followed no formal procedure, the administration's new rule would declare that agencies need no reason to cancel. Every award would carry language warning recipients that funding can be pulled whenever an agency decides the grant is "no longer in the national interest." This will make planning research very hard.
Content restrictions. The document bans funding tied to several topics, including research on disparate-impact liability, efforts framed as DEI, and what it terms "gender ideology" — defined broadly enough that Timmer notes it could sweep in basic research on human chromosomal disorders. It also introduces an affiliation screen reminiscent of the McCarthy era, letting agencies weigh an applicant's ties to organizations deemed to undermine public safety or national security.
Collaboration and publishing get harder. The rule suggests an outright ban on federally funded collaborations involving Chinese researchers and a "domestic-first framework" that treats even allied-nation partnerships as a last resort. Separately, publication costs and conference travel would become unallowable unless required by statute or approved in advance, case by case.
One thing it doesn't do: Despite widespread expectation, the proposal does not cap indirect cost reimbursement rates — a change many university research offices had braced for.
Why the rulemaking route? This is a deliberate procedural choice. Because the administration's executive orders have repeatedly been vacated in court, OMB has folded the relevant directives into the formal federal rulemaking process, which is harder to challenge and would convert prior agency-by-agency guidance into binding government-wide rules.
My take:Timmer's piece is openly critical, characterizing the proposal as a document designed to "finish the job of crippling American science" and flagging internal contradictions — most notably that it demands "viewpoint neutral" conduct from recipients while itself banning specific viewpoints. If this is true, it is a serious cause for concern for anyone who understands how vital science is to all of us.
Supporters of the changes would frame it differently: as restoring elected officials' accountability over how taxpayer research dollars are spent.
How much insulation from political direction the grant systemshouldhave is a genuinely contested question.
For grant writers, the practical reality is concrete: public comment is open now, and if finalized, these rules would change how your work is reviewed, funded, published, and presented.
It's worth reading the actual text and weighing in during the comment period which ends July 13. At the time of writing there were already more than 1,300 comments -add your own. I just submitted mine.
In Case You Missed It
Brains in a bucket?
Science reported recentlyabout a startup using intact human brains to test drugs. In buckets.

Bexorg, a biotech startup, is using disembodied human brains to test drugs, particularly for neurodegenerative diseases like Parkinson's, Alzheimer's, and amyotrophic lateral sclerosis.
The company'sBrainExplatform sustains the brains, allowing researchers to study how potential therapies work inside the brain, and has already been used to test over 700 brains.
The use of human brains is seen as a more realistic and effective method for testing drugs than traditional animal models or cell cultures, with collaborators like Biohaven already launching clinical trials based on data gathered from Bexorg's brains.
According to their website the brains do not and cannot wake up. They show no electrical activity, but just to be sure, the perfusate contains anesthesia.

Growth Mindset
Write for the Reviewer, Not for Yourself
Grants are written for a very small, but very critical audience. Getting that right can make all the difference.
NIH reviewers are expert scientists, but they're also overworked, reading eight to twelve applications per meeting with limited time for each.
A proposal that requires effort to understand is a proposal at a disadvantage.
Clear organization, logical narrative flow, consistent terminology, strategic use of headers and white space, and readable figures all reduce cognitive load.
Make the reviewer's job easy. Give them what they need to become your champion, not another item on an overwhelming to-do list.
The takeaway: Clarity is not just good writing — it's competitive strategy.
Success Tools
Foreign Components in NIH Grants — What's Changed and What Hasn't
NIH has been reminding people of the rules around Foreign Components. I am not sure they have increased clarity or just triggered anxiety. Here is my take.

What hasn't changed:
The definitionof a "foreign component" is the same.NOT-OD-26-084(May 27, 2026) confirms NIH has increased oversight but not expanded the definition: the performance of any significant scientific element of a project outside the U.S., by the recipient or a foreign-employed researcher, whether or not grant funds are spent.
The same triggers apply: human/animal subjects at a foreign site, extensive foreign travel for data collection, foreign facilities or instrumentation, financial support from a foreign entity, and co-authorship-generating collaborations. Travel purely for consultation still doesn't count.
Co-authorshipguidance is unchanged: most foreign co-authorship is a component, but trivial contributions (e.g., a single reagent) may not be. Report it to your IC as soon as you're aware.
What has changed:
Foreign subawardscan no longer be nested under a parent grant. NIH has replaced that structure to strengthen oversight and accountability.
The new mechanismis the Collaborative International Research Project (PF5)(Parent AnnouncementPA-26-002, posted January 2026): a domestic prime award with independent foreign awards linked to it.
Foreign organizationscan't apply directly — non-U.S. entities are ineligible, but foreign components are allowed and at least one International Project is required.
New required application pieces: an Overall component with a Dispute Resolution Plan, at least one Research Project, and one International Project per foreign organization, each needing a Letter of Support from the foreign organization's authorized representative.
The takeaway: the rules forwhat countsas a foreign component are stable; thevehiclefor international work has changed. The question is no longer "how do I add a foreign subaward?" but "does this fit the PF5 structure, and have I built in the required components?"



