BMES Comments on OMB’s Proposed Revisions to Guidance for Federal Financial Assistance

On July 9, 2026, the Executive Committee of the BMES Board of Directors, sent the following Comment to the Office of Management and Budget, which has proposed significant changes to the rules that govern federal grants across all agencies of the government, including NIH, and NSF. Specifically, this Comment pertains specifically to areas impacting BMES the most – the peer-review system and attendance at scientific conferences such as the BMES Annual Meeting and others. We encourage our members to submit their own letters. The deadline for submissions is July 13, 2026.

The Honorable Russel Vought
Director, Office of Management and Budget
725 17th Street NW
Washington, DC 20503

RE: Comments on Proposed Revisions to Guidance for Federal Financial Assistance (OMB-2023-0017 / RIN 0348-AB83)

Dear Director Vought,

The Biomedical Engineering Society (BMES) appreciates the opportunity to comment on the Office of Management and Budget’s (OMB) proposed revisions to the Guidance for Federal Financial Assistance. As the professional home for biomedical engineering researchers, faculty, students, and industry, clinician, and government groups, BMES supports the administration’s goals of transparency and accountability. However, we write to express grave concern regarding proposed changes to Section 200.461 (Publication and Printing Costs) and Section 200.432 (Conferences), which will severely disrupt scientific publishing and conference participation.

Biomedical Engineering is Essential to America’s Future
This year, as the nation marks its semiquincentennial, BMES launched American Health Discovery (www.AmericanHealthDiscovery.org), an alliance of clinicians, researchers, and industry leaders celebrating 250 years of lifesaving biomedical breakthroughs. From the pacemaker and the MRI to advanced prosthetics and insulin delivery systems, biomedical engineering has served as the backbone of modern American healthcare. We also encourage you to view this 10-minute video BMES in America 250 | Connecting the Healthcare Ecosystem.

These OMB proposed restrictions will create immense administrative burdens, stifle innovation, and actively harm the translation of biomedical discoveries from the lab to the patient.

We would like to focus our letter on two specific items:

1. Restrictions on Publication Costs (Section 200.461) Harm Open Science
The proposal to classify journal publication costs, including Article Processing Charges (APCs), as unallowable without explicit prior agency approval directly contradicts federal mandates for public access to federally funded research.

• Impact: Biomedical engineering is a rapidly evolving, multidisciplinary field. Open-access publishing ensures that healthcare providers, industry partners, and the public can immediately access lifesaving research.
• Consequence: Removing publication costs from standard allowable grant expenses forces researchers to choose between paying out-of-pocket, using limited institutional funds, or delaying publication. This slows down medical innovation and creates equity issues for early-career or underfunded researchers.

2. Conference Pre-Approval Requirements (Section 200.432) Stifle Collaboration
Requiring written agency pre-approval in the initial award for all future scientific conference attendance is functionally impossible for dynamic research environments.

• Impact: Peer-reviewed conferences like the BMES Annual Meeting are critical venues where researchers present preliminary data, form cross-disciplinary partnerships, and find industry collaborators.
• Consequence: Scientific breakthroughs happen quickly. A researcher cannot predict three years in advance which abstract will be accepted or which symposium will be vital to their project. This rule will lead to missed opportunities, delayed project timelines, and decreased workforce development.

While the OMB intended to streamline grant management and reduce recipient burden, these specific mandates achieve the exact opposite. The proposed revisions to the Uniform Guidance (2 CFR 200) will overwhelm university grant offices and federal program officers with an unmanageable volume of pre-approval paperwork for routine academic activities.

Furthermore, by effectively making publication costs—such as open-access fees, page charges, and article processing charges (APCs)—unallowable without prior agency approval, these rules push a massive financial burden directly onto individual researchers. Early-career academics and those without institutional discretionary funds will be forced to shoulder exorbitant publishing fees out-of-pocket to meet public access requirements, critically undermining the dissemination of federally funded science.

This administrative friction threatens the very foundation of the scientific enterprise by targeting conferences and journals at the most critical stage of the research lifecycle. For early-career researchers, academic conferences and peer-reviewed journals are not administrative luxuries; they are essential incubators where nascent ideas are tested, refined, and validated. Conferences provide a unique, real-time environment where junior scholars gain access to vital mentorship, receive expert guidance to steer their projects away from costly dead-ends, and build collaborative networks that sustain their careers. Restricting access to these venues through burdensome pre-approval processes isolates emerging scientists, starves projects of early-stage guidance, and severely diminishes the return on federal research investments.

BMES strongly urges OMB to maintain journal publication fees and scientific conference attendance as standard allowable direct costs on federal awards without requiring pre-approval.

Thank you for your time, consideration, and continued support of the American scientific enterprise.

Sincerely,

The Executive Committee
Biomedical Engineering Society Board of Directors
July 8, 2026