Update: The Planetary Society has added a side by side comparison of the old and new regulations at: https://dashboards.planetary.org/rules-change/
This is the text of a presentation I made to the DUNE collaboration on June 5, 2026
New proposed US regulations on grants
New draft regulations have been published in the federal register
The deadline for comments is July 13, 2026
These will have a direct impact on most of what DUNE does. I’m including some of the ones that most directly impact DUNE. For a longer explainer and list of provisions please see:
https://elizabethginexi.substack.com/p/summary-of-key-changes-in-ombs-proposed
(their suggestions on how to comment at the end of these slides)
APS will also have guidelines available by June 18
How to read/comment
Document is long…
Starts out with explanation
Actual wording is near the end
I take the provision #’s and search to find the wording.
Page 15 –Section 200.205 (Federal Agency Review of Merit of Proposals)
“Consistent with the Executive Order, senior appointees must conduct these reviews and apply specific principles when evaluating proposals. These principles include ensuring that discretionary awards advance the President’s policy priorities…”
The proposal further states that:
“Peer review remains advisory and does not replace agency discretion.”
Page 28 –Section 200.340 (Termination and Suspension)
“(2)At the discretion of the Federal agency or pass-through entity.The Federal agency or pass-through entity, to the extent permitted by law, may terminate a Federal award in part or its entirety if the Federal agency or pass-through entity determines that a termination is in the interest of the Federal agency or pass-through entity, including if a Federal award does not effectuate program goals, Federal agency priorities, or the national interest as they exist at the time of the termination. See also § 200.341;”
Note: Universities would need to accept this condition and have no recourse if a grant were terminated due to a policy change.
Page 56 – Section 200.220 (Prohibition on Use of Federal Funds for Covered Foreign Collaborations)
The proposal defines a “covered foreign country” as any country designated by statute, Executive Order, or other federal authority as:
A foreign adversary;
A country of particular concern; or
A country subject to sanctions or restrictions relating to national security, defense, or intelligence activities.
Other provisions
200.206 Membership in “organizations engaged in activities that violate Federal law, undermine public safety or national security, or advocate for the overthrow of the United States Government”
200.421 Restrictions on spending on outreach
200.432 Conferences must be pre-approved
200.461 Publication charges not allowed
How to write an effective comment
Make it completely unique! Do not cut and paste.
[From: https://elizabethginexi.substack.com/p/this-new-omb-rule-is-bigger-than]
1:Say who you are and why you are qualified to comment. You do not need credentials. Being affected is enough, and simply being a concerned citizen is perfectly fine.
2:List the exact provision #s that concern you, and explain what they would do. You do not need to quote the rule directly. Just explain what you understand it to mean in plain terms.
3:Explain the concrete harm. What would happen to you, your community, or your state if this provision takes effect?
4:Closing: State clearly what you want OMB to do. This can be as simple as: “I urge OMB to withdraw these specific provisions:§200.340, §200.202, §200.205.” or “I urge OMB not to finalize this rule.”
Submit your comment here:https://www.regulations.gov/document/OMB-2026-0034-0001
The deadline is July 13, 2026.
onequestionaweek 