Communications from the Chief Scientific Officer

Dear Colleagues,

As follow-up from Thursday’s Town Hall on the proposed changes to the uniform guidance (2 C.F.R. 200), the Office of Research Services (ORS) will continue discussion tomorrow at noon.

Wednesday, June 24

12:00pm

Zoom Link

Missy Peloso and team will address outstanding inquiries and invite new questions. Our ongoing thanks to ORS, the Office of General Counsel, and all of you for your continued efforts.

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Sent June 18, 2026

Dear Colleagues,

We write to share an important update regarding proposed changes to the federal Uniform Guidance, the government-wide framework that governs how research grants and funding awards are administered. These proposed revisions could have meaningful implications for how universities receive, manage, and collaborate on federally funded research.

Opportunity to Learn More The Office of Research Services (ORS) will host a Town Hall TODAY, June 18 at 12:00 PM, to provide an overview of the proposal, share what we know to date, and discuss potential impacts. We encourage you to attend. Denene Wambach from Office of General Counsel (OGC) and Missy Peloso from ORS will lead the discussion. To attend, please enroll via this Workday link.

What We Know Penn’s Office of Government Relations, Office of the Vice Provost for Research, and OGC are actively reviewing the proposal to assess potential impact. National higher education organizations, including the Association of American Universities (AAU), the Association of American Medical Colleges (AAMC), and the Council on Governmental Relations (COGR), have also identified several significant areas of concern, including:

• Expanded federal agency discretion in funding decisions, which could increase uncertainty in grant awards
• Changes to the role of peer review in the grant selection process
• Potential involvement of political appointees in proposal review
• New restrictions on allowable uses of grant funding
• Increased authority for agencies to suspend or terminate grants on short notice
• Changes to indirect cost treatment and other allowable expenses, with potential budget implications
• Provisions that could favor institutions with lower indirect cost rates
• New restrictions on international collaboration and increased oversight of subrecipients
• Elimination of certain flexible funding mechanisms (e.g., fixed-amount awards and subawards)

Key Issues Under Review The proposal, issued by the White House Office of Management and Budget (OMB), would shift the Uniform Guidance from advisory guidance to formal regulation—potentially giving OMB broader authority to make changes across federal agencies. This represents a significant structural change with potential long-term implications for federally funded research.

How You Can Engage Individual faculty, staff, and learner perspectives can be valuable in helping policymakers understand the real-world impact of these proposed changes. If you choose to engage in your personal capacity, you may wish to:

• Provide comment on the proposed regulation:
  • Information on how to write a comment letter can be found here.
  • Share examples of how the proposed changes could affect your research, collaborations, or funding

The public comment period is currently open, with a deadline of July 13, 2026. Click here to submit your comment. Please note, when commenting on each issue, it is important to call reference to the specific regulation section (e.g., [200.414]).

Additional Resources We encourage you to review the following materials:

• Executive summary of key issues developed by AAU, AAMC, and COGR, which include:
  • Talking points for communicating with policymakers
  • Resource pages with additional background and guidance
  • Instructions on commenting, including the instruction to cite specific sections of the regulations when commenting

We recognize that these proposed changes raise important questions, and we are committed to keeping you informed and engaged as this process evolves. Please do not hesitate to reach out with questions or input.

Sincerely,

E. Michael Ostap, PhD

Professor of Physiology

Senior Vice Dean and Chief Scientific Officer,

Perelman School of Medicine at the University of Pennsylvania