Comment is due Sunday, July 12 by midnight ET through the Project’s secure portal
The Basics
On this page, you will find detailed information about the proposed rules and guidance for commenting. In short:
Commenting on proposed rules is important because it gives the public a formal, legally recognized way to influence what the final policy looks like—and whether it moves forward at all. They are one of the most effective tools we have to slow, weaken, or stop harmful policies—and to protect access to care.
Before submitting a public comment, individuals should thoughtfully evaluate their personal and professional risk. Public comments play an important role in advocacy efforts and can be valuable in future legal challenges, but participation should only occur if it feels safe to do so. Providing identifying information may carry risks, including the possibility that individuals or locations named in a comment could be subject to scrutiny. Anonymous commenting is permitted. The Project’s portal is a private and secure method for submitting your comment on the rules.
It is critical that your comment be unique. Please avoid using text pasted from a template; comments using the same language are bundled together and largely ignored by the Federal Register.
Have detailed questions? Need help?
Resources are available:
Webinar: Lawyers for Good Government is hosting an informational webinar on June 23. Registration is required
Contents
Click on any of the subjects below to jump to that section.
Background
Title 2 of the Code of Federal Regulations (2 CFR Part 200), commonly referred to as the Uniform Guidance, establishes the overarching rules that govern most federal financial assistance programs. These requirements apply to a wide range of funding mechanisms, including grants, cooperative agreements, formula-based funding, and certain loan programs, covering a wide range of sectors including healthcare, education, scientific research, transportation, environmental programs, housing, public safety, agriculture, and international assistance. Collectively, these regulations govern the administration of approximately $1.3 to $1.5 trillion in federal financial assistance distributed annually.
The proposed rule would attach new political and ideological requirements to federal funding, making it harder for organizations to receive or keep grants if their work conflicts with the administration’s priorities. It would prohibit the use of federal funds for activities related to what the administration defines as DEI initiatives, “gender ideology,” or gender-affirming care for transgender youth, creating uncertainty for schools, healthcare providers, researchers, and nonprofit organizations.
This rule impacts 42 federal agencies. Equity programs in schools, research and/or support of gender-affirming care and other healthcare programs, LGBTQ+ arts and culture initiatives, and a long list of others will be revoked if the grantee organization does not comply with the rules excluding DEI and gender identity/expression. It would affect every state, school district, most hospitals and universities, and tens of thousands nonprofits and community organizations nationwide. Examples of grants include:
Department of Education grants, including Head Start, magnet schools, programs assisting first-generation college students, and a host of others: $2 billion
Department of Justice community-oriented hiring programs and violence against women grants: $900 million
National Endowment for the Humanities, National Endowment for the Arts, and the Institute for Museum and Library Sciences grants supporting arts and culture: $700 million
National Institute of Health and National Science Foundation research grants: $42 billion
Substance Abuse and Mental Health Services Administration community and mental health grants: $5 billion
The proposed rule is not yet in effect. It is subject to a 45-day public comment period which closes July 13, 2026. After reviewing submitted comments, OMB may choose to finalize the rules as written, revise them, or decline to move forward.
The Rule
Regulation for Federal Financial Assistance (OMB-2026-0034)
Summary
The OMB’s proposed overhaul of the federal government’s Uniform Guidance significantly alters the regulations that govern most federal grants and financial assistance programs. If adopted, the proposal would make far-reaching changes to the way federal funding is awarded, administered, and monitored across virtually every sector that receives federal support. The proposed revisions would grant agencies expanded authority to impose political and ideological priorities on funding decisions, fundamentally altering the longstanding framework that governs federal financial assistance. Key changes include:
New Political and Ideological Conditions on Federal Funding: The proposal would attach a number of new restrictions to federal grants and other forms of financial assistance, making it harder for organizations to use federal funding if their work conflicts with the administration’s political priorities. Under the proposed rules, organizations could lose funding for activities related to diversity, equity, and inclusion (DEI), support for transgender people, or gender-affirming care for minors, depending on how federal agencies interpret those terms.
Weakened civil rights protections: The rule would make it more difficult to challenge policies that disproportionately harm certain groups, even when discrimination is not explicit. Critics argue that these changes would allow the federal government to use funding as a tool to pressure organizations into adopting specific viewpoints, weakening longstanding civil rights protections. The proposal would formally establish special protections for faith-based organizations receiving federal funding, raising concerns about whether all recipients would be held to the same standards and requirements.
Greater Political Control Over Federal Grants: The proposal would strip the role of independent experts and peer reviewers and hand political appointees significantly more influence over which organizations receive federal funding and whether that funding can continue. Before many grants could be awarded, senior political officials would be required to determine whether a project aligns with the administration’s priorities and interpretation of the national interest. For programs involving research, science, public health, education, and other specialized fields, expert evaluations would be overridden by partisan and ideological political considerations.
The proposal would also allow federal agencies to cancel grants that have already been awarded if agency leaders determine that the project no longer aligns with their priorities. Organizations could lose funding even if they have complied with all grant requirements, and they would have fewer opportunities to challenge those decisions.
Commenting
Why is it important to comment?
Commenting on proposed rules is important because it gives the public a formal, legally recognized way to influence what the final policy looks like—and whether it moves forward at all. They are one of the most effective tools we have to slow, weaken, or stop harmful policies—and to protect access to care.
Here’s why it matters, especially in this moment:
It shapes the final rule: Federal agencies are legally required to review and consider public comments before finalizing a rule. Substantive comments—those that raise legal, medical, economic, or implementation concerns—can lead agencies to revise, narrow, or withdraw proposals.
It builds the record for legal challenges: Public comments become part of the official administrative record. If the rules are finalized and challenged in court, judges look closely at whether the agency adequately responded to concerns raised during the comment period. Strong comments help expose flaws, contradictions, and unlawful reasoning.
It demonstrates real-world impact: Comments from individuals, families, providers, advocates, and organizations document how the proposed rules would affect people’s lives, health, and access to care. This evidence counters abstract or misleading claims made by the agency.
It forces accountability: Once concerns are raised in the public record, the agency cannot claim ignorance. Ignoring well-supported comments increases the risk that a rule will be overturned for being arbitrary, unsupported by evidence, or contrary to law.
What is commenting?
Under the federal rulemaking process, an agency generally begins by publishing a proposed rule and opening a public comment period. During this time, members of the public may submit feedback, which the agency is required to review and take into account before issuing a final rule. Once finalized, the rule carries the force of federal law. Additional details about this process are available in this guide.
Are there risks to commenting?
Before submitting a public comment, individuals and organizations should thoughtfully evaluate their personal and professional risk. Public comments play an important role in advocacy efforts and can be valuable in future legal challenges, but participation should only occur if it feels safe to do so. Providing identifying information may carry risks, including the possibility that individuals or locations named in a comment could be subject to scrutiny.
Some commenters—such as transgender youth, family members, or providers of gender-affirming care—may face heightened vulnerability and should carefully consider whether to comment, what information to include, and if it should be submitted anonymously.
It is also important to note that all submitted comments are published on regulations.gov and are publicly accessible. Once a comment is submitted, it cannot be edited or withdrawn.
If you are submitting a comment as an individual, be mindful of the potential risks associated with sharing personal details such as your full name, home address, email, or phone number. You are not required to include identifying information and may choose to submit your comment anonymously. Any personal or medical information included in a comment will be visible both to the administration and to the public.
Individuals may also want to avoid sharing details that could make themselves or others identifiable, such as exact ages, locations, or the names of healthcare providers. For example, rather than describing specific circumstances that could point directly to you or a provider, you can speak more generally about your experience. Framing your comment around the broader impact of gender-affirming care—without unnecessary identifying details—can help reduce risk while still making your perspective clear.
We recommend:
- Using the Project’s portal to comment. Doing this protects your identity—data like your IP address, location, and other critical information will not be shared with the government. Or anyone else, for that matter.
- Removing all personal metadata if you are uploading a comment document:
- If you are submitting comments directly through the federal register and are concerned about privacy, do not use a personal device. You can use a computer at your local library.
Do anonymous comments matter?
Anonymous comments are permitted by the Administrative Procedure Act, the law governing the process of rulemaking. Like all comments, they become public and are posted online, but without your personal details. The Federal Register does not verify the identity of anonymous commenters.
Yes, anonymous comments can matter for the Federal Register and the rulemaking process, as agencies must consider all relevant, timely public input, but they are often weighed differently than identified comments, especially if they lack specific details. The quality of anonymous comments is essential for having the most impact.
To make your anonymous comment effective, do the following:
Explain Impacts: Clearly describe how a proposed rule will affect you, your community, or the public.
Avoid Identification: Be careful not to include details that could inadvertently identify you or others, like names, ages, provider information, specific locations like towns, occupations, schools…essentially anything that someone could use to identify you and your family.
Be Specific: Provide facts, data, and detailed explanations, not just opinions.
Focus on the Rule: Concentrate on the substance of the regulation rather than personal identifiers.
Tips for commenting
Focus on what you know and what you’ve lived. You are not expected to address every section of the proposal or respond to every argument it makes.
Write as much or as little as feels right to you. Effective comments don’t need to be long to be meaningful. Both the substance of comments and the number submitted play an important role in this process, so don’t let concerns about length prevent you from participating.
These prompts may be helpful as you think about what you want to share:
- How could this rule affect your child’s access to services? Has your child benefitted from programs, like education or healthcare, supported by federal funding?
- What does equal access mean for your family?
- How would uncertainty in federal funding impact your community?
- What values should guide federal funding decisions?
Formatting your comment
It is essential that your comment be unique. Please avoid using text pasted from a template; these comments are bundled together and largely ignored by the Federal Register.
Introduction: state that you are submitting the comment in opposition to OMB-2026-0034, Regulation for Financial Assistance, and are urging its withdrawal.
Your interest in the rule: a short paragraph detailing why this rule is important to you.
Opposition to the rule: detail on your disagreement with the proposed rule. This could be whatever length necessary. We recommend using subheadings for longer comments. Examples of subheadings:
-Concerns about access to healthcare
-Potential impacts on mental health services
-Why Equal Access Matters
-Concerns about politicizing federal funding
-Protecting Civil Rights and Opportunity
Conclusion: urge withdrawal of the proposed rule in its entirety. Include a closing and your name like you would on a business letter if you are choosing to not be anonymous.
Examples of short public comments on this rule
- Comment submitted on June 8, 2026:
I am a parent and active member of my child’s school community in Fremont, California. I volunteer regularly at school events, stay closely involved in what happens in our classrooms, and have seen firsthand how much federal funding matters to the families and students in our district.
I am writing to express serious concern about two provisions in the proposed changes to 2 CFR Part 200.
The first is §200.206, which allows federal grants to be denied based on an organization’s affiliations. The language in this provision is broad enough to disqualify the kinds of community organizations that actually do the work: nonprofits that serve immigrant families, civil rights groups, public health organizations, and parent advocacy groups. Many of the programs that reach students who need the most support are run by exactly these kinds of organizations. Cutting them off from federal funding does not just hurt the organization. It cuts off services to real kids in real schools.. - Anonymous comment submitted June 8, 2026:
I am the parent of a nonbinary child, and I am submitting this comment because I am deeply concerned about the impact this proposed rule could have on my family and families like mine.
My child will be starting middle school next year. That transition is challenging for any child, but it can be especially stressful for a young person who is navigating questions of identity while trying to find their place among new peers, teachers, and expectations. We have been fortunate to live in a welcoming community on the East Coast and to be part of a school district where teachers, counselors, and administrators have consistently supported my child.
Because of that support, I have watched my child grow into a more confident and engaged young person. They have found their voice in ways that I never could have imagined a few years ago. They have spoken at Pride events in our community, and those experiences have given them the confidence to take on leadership roles at school. Seeing them develop that sense of self, confidence, and willingness to stand up in front of others has been one of the greatest joys of parenting. They are learning how to advocate for themselves, how to participate in their community, and how to become a thoughtful and responsible young person.
I worry that this rule could undermine the ability of schools to provide the kind of support that has helped my child thrive. Even if schools want to continue creating safe and inclusive environments for all students, policies like this can create confusion, fear, and pressure to withdraw support from transgender and nonbinary students. Families should not have to wonder whether their child’s school will still be able to treat them with dignity and respect.
…
My child is not asking for special treatment. They deserve the same things every parent wants for their child: a safe school environment, access to healthcare, supportive adults, and the opportunity to grow into a healthy and successful adult. They deserve the chance to enter middle school focused on learning, making friends, and discovering who they are—not worrying about whether the adults and institutions they depend on will continue to recognize and support them.
How to Submit Public Comments
Using the Project’s secure portal:
We created a comment portal that individuals can use, providing a private, secure method for commenting. Comments will be submitted to the Federal Register by the Out Accountability Project.
Step 1: Open the secure comment portal
Step 2: Choose if you want to submit your comment(s) anonymously
Step 3: Enter contact information
Step 4: Select the rule(s) you wish to comment on:
Step 5: Enter the comment text in the box. Alternatively, you can upload a PDF or a Word document. If you are uploading, simply enter “See attached file” in the required text box.
Step 6: Ship it!
