91��ý

After gathering feedback from across its research community, 91��ý has submitted recommendations to the White House Office of Management and Budget (OMB) on proposed revisions to the federal regulations governing research grants and other forms of federal financial assistance.

The university submitted its comments before the July 13 public comment deadline after reviewing more than 100 responses from faculty, researchers, research administrators, graduate students, postdoctoral scholars and staff. Campus leaders also considered analyses from peer institutions and national higher education organizations in developing the university's response.

“Federal research investments produce their greatest value when they support scientifically rigorous research, encourage innovation, foster collaboration, train the next generation of researchers and enable discoveries to be communicated broadly for the benefit of society,” said Chancellor Justin Schwartz. “The university believes the requested revisions would strengthen the proposed regulation by preserving these foundational characteristics while advancing OMB's objectives.”

91��ý leaders said the university's recommendations are intended to help ensure federal regulations continue to support scientific discovery while maintaining appropriate oversight of taxpayer-funded research.

The university's response focuses on seven broad priorities:

• Preserving the stability and competitiveness of the U.S. research enterprise
• Maintaining independent expert peer review as the primary basis for research funding decisions
• Preserving research continuity through predictable award administration and clearly defined termination standards
• Recognizing publication, conferences and scientific communication as integral components of federally funded research
• Strengthening research security while preserving legitimate international scientific collaboration
• Applying risk-based administrative oversight that improves accountability without creating unnecessary burden
• Providing clear, operationally implementable regulatory requirements that support consistent implementation across federal agencies

In its comments, 91��ý noted that while many of the proposed OMB changes appear administrative when considered individually, their combined effect could increase uncertainty throughout the research lifecycle—from proposal development and award administration to scientific communication, workforce development and international collaboration.

The university's recommendations encourage OMB to evaluate the proposed regulations as an integrated whole and to preserve the stable, transparent and merit-based processes that have supported decades of federally funded research.

"These recommendations reflect a coordinated campus perspective informed by both local experience and broader developments across the national research enterprise, offering constructive feedback intended to strengthen stewardship while preserving the stability, transparency and competitiveness of the U.S. research enterprise," said Massimo Ruzzene, senior vice chancellor for research and innovation and dean of the institutes.��

The 91��ý response also emphasizes the importance of maintaining independent expert peer review as the primary basis for evaluating research proposals. University leaders argue that transparent, consistently applied scientific review supports innovation, long-term planning and responsible stewardship of federal investments.

91��ý further recommends maintaining predictable award administration and clearly defined standards for award termination to support long-term research projects, graduate education and institutional planning. The university also urges OMB to continue recognizing publication, conference participation and the dissemination of research findings as essential components of federally funded research.

Additional recommendations call for aligning research security requirements with existing federal frameworks while preserving legitimate international scientific collaboration and adopting risk-based administrative oversight that strengthens accountability without imposing unnecessary burdens on research institutions.

The university also encourages OMB to provide greater regulatory clarity to support consistent implementation across federal agencies and to preserve rigorous scientific inquiry and evidence-based research.