Communications
On May 29, the federal government’s Office of Management and Budget (OMB) released proposed revisions to what is known as the “Uniform Guidance” — the primary framework governing federal grants, cooperative agreements and other forms of federal financial assistance. If finalized as proposed, these changes would represent a significant overhaul of federal award management requirements for all institutions that rely on federal funding, including Brown University. The Association of American Universities (AAU) provides an effective summary and resources that are helpful for understanding the key proposed revisions.
These proposed changes could have far-reaching implications for Brown’s research operations, compliance obligations and the overall administration of federal awards — and, by extension, the positive impact we make in the world through research at Brown. The proposed revisions are open for public comment until July 13, and Brown will formally submit an institutional comment on the impact these changes will have on our research enterprise.
It is equally important that members of our community understand the potential impacts and consider the opportunity to provide feedback to the OMB. We encourage all faculty and staff to review the proposed changes, consider how they may affect your work and our community, and consider submitting individual comments. Your direct input, based on your experiences with federally funded research, can help shape the final regulations. Because of that, please share this message with your Brown colleagues. When submitted, your comment becomes part of the public record.
How to Submit Comments
All comments are due by July 13, 2026. Individuals may submit comments based on their own experiences with federally funded research, teaching, training, clinical work, publication, conferences, collaboration and/or research administration.
To prepare and submit a comment, we recommend that you take the following steps:
(1) Choose the Provision(s) You Want to Address: You do not need to comment on every proposed revision. Consider selecting one or two provisions that would most directly affect your work if implemented in their proposed form. The most persuasive comments from individuals provide specific, real-world examples from your own experience.
(2) Draft Your Comment: A useful comment can be short. It should identify who you are, the proposed revision you are addressing, what the proposal would do, how it would affect your work and what you recommend.
Some tips to consider in drafting:
- Write on your own behalf. Include a statement that makes clear you are writing as an individual — for example, “I submit this comment in my individual capacity and not on behalf of Brown University” — and do not use Brown University letterhead. However, you may refer to yourself as affiliated with Brown and use your Brown University email address. You may also submit a comment anonymously, should you wish. Do not include confidential or non-public information, as all comments are public when submitted to the federal government.
- Refer to the relevant section number. Begin each comment with the relevant section number, such as [200.205] for a comment on 2 C.F.R. 200.205.
- Use real examples appropriate for public disclosure. Explain the real-world impacts where you can, noting effects on (for example) staff time, delayed milestones, unrecoverable costs, disruptions to students or trainees, or effects on research participants. Do not include confidential or non-public information, as all comments are public when submitted to the federal government.
- Avoid form-letter language. One well-supported, individualized comment is significantly more influential than identical submissions or an edited “form letter.”
Consider the length of your comment. Submissions of less than 5,000 characters (including spaces) can be submitted directly through the federal website; longer submissions must be saved as a separate file (.docx, .pdf, etc.) and uploaded through the website.
(3) Submit Your Comment
- Go to the Regulation for Federal Financial Assistance page.
- Use the comment function for the proposed rule.
- Submit by 11:59 p.m. ET on July 13, 2026.
- Save a copy of your comment before submitting.
- If you wish for Brown to consider your individual comments in developing its official comment letter, please send a copy of your comment to federalupdates@brown.edu.
Participation from those whose work will be impacted is essential in ensuring that the voices and experiences of Brown community members are considered in this important federal process, and we appreciate you considering the submission of an individual comment.
Sincerely,
Francis J. Doyle III
Provost
Greg Hirth
Vice President for Research
Vice President for Research