FAQ

Does my comment actually matter? Isn’t this decided already?

Yes, it matters. Notice-and-comment rulemaking is a legal process under the Administrative Procedure Act. Agencies must consider significant comments and respond to them, and rules have been delayed or struck down in court when agencies failed to. A specific, substantive comment from an affected expert is exactly what creates that obligation.

Will a big pile of identical comments work?

No — and it can backfire. Agencies routinely treat large numbers of identical or near-identical form letters as a single comment. What carries weight is volume of distinct, substantive points the agency must address. A hundred individual expert comments are far stronger than a thousand copies of one letter. Write your own.

Do I have to be a U.S. citizen or a scientist to comment?

No. Public comment is open to anyone — researchers, students, staff, patients, taxpayers, and organizations. The most persuasive comments come from people the rule directly affects, writing from their own experience.

What’s the deadline and where do I submit?

July 13, 2026. Submit at regulations.gov, Docket OMB-2026-0034. Begin each comment with the relevant section number in brackets, e.g. [200.205].

Will my comment be public? Can I be anonymous?

Comments become part of the public record on regulations.gov. You can comment without providing detailed personal information, but do not include private or confidential information in your comment — it cannot be removed once posted.

Is it okay to use AI to write my comment?

Using AI to help draft is fine — but the comment must be genuinely yours. Read it, rewrite it in your own voice, verify every fact, and never submit text you haven’t personalized. See Draft with AI for guidance and guardrails. Unedited, duplicated AI text is both less effective and a credibility risk.

What about the 15% indirect-cost cap I heard about?

This rule does not change negotiated indirect cost rates. Congress blocked a proposed 15% cap in the FY2026 appropriations bills, so the rule leaves the indirect-cost system as-is. The changes that matter here are about peer review, terminations, prohibitions, and communication costs — see the section guide.

When would this take effect?

OMB has indicated the package is intended to take effect October 1, 2026, applying to Fiscal Year 2027 funding — which is why comments before the July 13 deadline matter now.

I’m not affected directly. Should I still comment?

If you care about U.S. science, yes. Department chairs, institutions, scientific societies, patient groups, and members of the public all have standing. Organizational comments carry distinct weight — consider asking yours to file one.