Dear Members of the HMS Community:
I have heard from many of you since the release of the proposed changes to the Uniform Guidance from the White House Office of Management and Budget (OMB) on Friday, May 29. I share your deep concern about the impact this new regulation would have, if implemented as drafted, on biomedical research and all who benefit from our life-changing work.
The message below from Harvard Vice Provost for Research John Shaw provides details on the proposed changes and an update on how the University is planning to respond — including, importantly, gathering feedback from each school submitted by members of their community. I know many of our affiliated hospitals and research institutions are also coordinating responses.
I encourage you to consider your involvement in this process through the following actions:
- HMS Quad-Based Faculty, Researchers, Staff, and Students: Share your feedback — including specific examples, data, and operational impacts — on the proposed regulations with our HMS Office for Academic & Research Integrity. We will collect and share this feedback with the Office of the Vice Provost for Research (OVPR) and the Office for Sponsored Programs (OSP) to ensure the unique perspective of our HMS community is well represented in Harvard’s submission as part of the public comment process. Please send your feedback to ari@hms.harvard.edu no later than Tuesday, June 23. Questions can also be sent to this email.
- HMS Hospital/Affiliate-Based Faculty: Share your feedback directly with your hospital or primary institution through the channels provided. Please know that my leadership team and I will be discussing feedback with hospital leadership and coordinating as appropriate.
- All Faculty, Researchers, Staff, and Students: Consider additional opportunities to provide comment in your individual capacity through scientific and professional societies, such as the American Association of Cancer Researchers, American College of Physicians, American Medical Association, Association of American Medical Colleges, and other medical and specialty associations.
Thank you in advance for your contributions to this process. The work that each of you does in service to HMS’ mission and for the betterment of human health is critically important and irrefutable. We will continue to champion the value of our work.
Sincerely,
George Q. Daley
Dean of the Faculty of Medicine
Harvard University
INTERNAL COMMUNICATION
Dear Colleagues,
As you may have heard, the White House Office of Management and Budget (OMB), jointly with federal grantmaking agencies, recently released a proposed rule intended to substantially overhaul federal award management requirements at 2 C.F.R. Part 200, commonly known as the “Uniform Guidance.” The Uniform Guidance serves as the government-wide framework for managing grants, cooperative agreements, and other forms of financial assistance.
The proposed changes, which are intended to apply uniformly across federal agencies, are significant and would substantially change the federal grant management process across the full award lifecycle. Specifically, among other changes, the proposed rule:
- Establishes a pre-issuance review of all discretionary awards by senior political appointees to ensure alignment with Administration priorities; peer review would be advisory only.
- Applies new factors to the grant review process, including preferences for institutions with lower indirect cost rates.
- Expands the ability of funding agencies to suspend or terminate federal awards mid-stream if they no longer advance program goals, agency priorities, or the national interest.
- Restricts the use of federal funds to support collaborations, programs, and activities with certain foreign countries and entities of concern.
- Expands risk assessment of award applicants to include an applicant’s history of certain “questionable practices,” financial capacity, memberships or affiliations, and history of compliance with federal foreign gift and contract disclosure requirements.
- Prohibits conference attendance (unless specifically approved by the awarding agency) and publication fees as allowable costs.
- Codifies elements of certain executive orders issued since January 2025, including those focused on diversity, equity, and inclusion (DEI); gender; and merit-based opportunity.
The OMB is accepting comments from the public on the proposed rule through July 13, with the goal of implementing the final regulation in October.
We are working closely with our internal stakeholders and national associations in Washington, D.C. to respond to the proposed changes. To help these collective efforts, we would appreciate your assistance on the following:
- Please provide your feedback on these proposed regulations to your designated School point of contact — for HMS, this is the Office for Academic & Research Integrity at ari@hms.harvard.edu — no later than the end of day June 23. Most helpful will be information that explains how the proposed changes would impact your research, including specific examples. We welcome input from academic leadership of Schools and units, as well as from individual faculty, researchers, and administrators.
- Faculty members may also wish to offer input in their individual capacity to the many scientific and professional societies that are planning their own comment letters. We would encourage them to participate in those processes.
Thank you for your engagement in this important matter.
Best regards,
John
John H. Shaw
Senior Vice Provost for Research
Harry C. Dudley Professor of Structural & Economic Geology
Earth & Planetary Sciences
Professor of Environmental Science and Engineering
School of Engineering & Applied Sciences
Harvard University