On 4 November 2026, a coalition of university, scientific, nonprofit and state and local government organizations sent a letter to Congress arguing that federal agencies are folding pieces of the Office of Management and Budget’s (OMB) proposed Uniform Guidance overhaul into their own grant policies, even though Congress barred OMB from finalizing or implementing that rewrite through 11 December 2026. The American Institute of Biological Sciences (AIBS), one of the signers, reported on 6 November that the letter carried 116 signatories in total. The Inside Higher Ed report of 5 November names the Association of American Universities (AAU) and the American Association for the Advancement of Science among them.
What the letter says
According to Inside Higher Ed, the coalition describes agency actions as “in direct contradiction to bipartisan language” Congress passed in September in a temporary funding measure. The same report says the letter raises “separation-of-powers concerns,” warns of uncertainty for grant recipients, and argues that letting agencies circumvent appropriations “diminishes Congress’s ability to control the use of federal funds.”
Inside Higher Ed reports that the letter says the National Science Foundation (NSF) and the Education Department have proposed rules that mirror OMB’s, and that NASA, the Department of Agriculture, the Department of Energy and the Department of Housing and Urban Development have sought to incorporate parts of the OMB rules into their grant policies. AIBS’s account of the letter names NSF, the National Institutes of Health (NIH), USDA and NASA. The sources differ slightly on which agencies are listed; this page reports each as attributed.
AIBS summarizes the coalition’s requests of Congress as: conduct oversight of agency actions that incorporate the proposed revisions; extend the restriction in any further continuing resolution; and include protections in FY 2027 appropriations legislation to stop agencies from implementing the proposed regulation or substantially similar provisions. Inside Higher Ed’s brief report does not itemize a specific request.
Context
The restriction at issue is a provision of the continuing resolution that AIBS describes as barring OMB from finalizing or implementing the changes through 11 December 2026. Our earlier coverage traces how that provision came together: see the Senate continuing resolution that blocks the OMB political-appointee grant rule. Inside Higher Ed adds that OMB received at least 164,000 comments on its proposal.
This letter should be read alongside a separate NSF development. In late October, NSF revised its own proposed grant-policy changes and, according to AIP FYI, dropped provisions that rested solely on the OMB proposal; see NSF drops OMB-based grant policy changes after 3,000+ comments. The coalition’s characterization of NSF’s proposal as mirroring OMB’s and NSF’s own stated revision are not necessarily in conflict, since the letter may address other elements of the NSF package. Researchers should treat the agency-by-agency claims as the coalition’s assertions, not as findings of fact, and check the agency documents directly.
What it means for researchers, universities and research offices
- Do not assume the OMB rule is a dead letter. The bar covers OMB through 11 December 2026 only. The coalition’s request to extend it in a further continuing resolution and in FY 2027 appropriations is exactly what is not yet settled.
- Watch agency terms and conditions, not just OMB. Where agencies adopt similar requirements through their own notices, award terms or policy statements, the change reaches your awards without an OMB final rule. Sponsored programs offices should compare new agency terms against current ones at each award and renewal.
- Track comment dockets and information-collection notices. NSF’s guidance is in an open comment process; the deadline listed by AIP FYI is 28 November 2026 (see our NSF post for details).
- Prepare for divergence. The coalition’s own concern is “conflicting requirements” and added administrative burden across agencies (AIBS). Offices that manage multi-agency portfolios may want to log which agency has adopted what, and when.
- Institutional associations are the channel. Several signers are membership associations that submit comments and brief Hill staff; research offices can feed examples of concrete compliance impact to them.
This page is analysis of reported developments, not legal advice. Agency positions may change quickly before 11 December.
Sources (read 12 November 2026)
- AIBS, “Call for oversight of agency implementation of Uniform Guidance changes,” 6 November 2026: 116 signatories, agencies named, requests to Congress.
- Inside Higher Ed, “Coalition Warns Congress That Trump Is Changing Grant Rules,” 5 November 2026: signers, agency actions, quoted language.
- Coalition letter, hosted by AAU (dated 4 November 2026): the letter itself.
- CASRAI: NSF drops OMB-based grant policy changes and CASRAI: Senate CR blocks OMB grant rule.
