AANEM Urges OMB Not to Undermine Scientific Infrastructure in Proposed Grant Rules

AANEM has submitted formal comments to the Office of Management and Budget (OMB) on the proposed revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200). The letter expresses concern that several proposed changes would significantly weaken the scientific infrastructure that allows federally funded research to translate into better care for patients with neuromuscular diseases.

In its comments, AANEM highlights three core areas where the proposal would restrict the use of grant funds:

• Publication costs including article processing charges, page charges, and open-access fees, even as agencies increase requirements for public access to federally funded research.
• Professional memberships and journal subscriptions which are critical for access to specialized literature, standards development, and expert networks in highly specialized fields such as neuromuscular medicine.
• Conference participation by requiring advance agency approval and inclusion in award terms, creating new administrative hurdles for scientific meetings that are essential venues for presenting results, building collaborations, and supporting early-career investigators.

AANEM emphasizes that these activities represent a small fraction of overall research spending yet are essential to ensuring that federally funded discoveries are disseminated, validated, and incorporated into clinical practice. The letter warns that restricting support for publication, professional society engagement, access to scientific literature, and scientific meetings would likely reduce the visibility and impact of federally funded work, slow the movement of knowledge from laboratories to clinics, and diminish the overall return on federal research investments.

OMB’s proposed revisions are subject to the formal federal rulemaking process, including review of public comments and issuance of a final rule is currently targeted for an October 1, 2026 effective date. AANEM will monitor this process closely on behalf of its members and will provide timely updates, analysis, and practical guidance as OMB responds to stakeholder input, refines the proposal, and moves toward final implementation