NPHC Public Comment on OMB Proposed Rule

Regulation for Federal Financial Assistance, OMB-2026-0034

The National Public Health Coalition (NPHC) submits this comment in opposition to OMB’s proposed Regulation for Federal Financial Assistance. NPHC is a grassroots organization whose mission is to educate about and advocate for the protection of public health as a vital government service, now and in the future. NPHC’s work is based on data-driven decision-making, transparent communication, community partnership, and protection of public health practice from bias and political interference.

Federal financial assistance is essential to public health work across the country. The proposed rule would make public health less stable, less evidence-based, and more vulnerable to political and ideological interference.

NPHC urges OMB to withdraw the proposed rule and not finalize it. At a minimum, OMB should substantially revise the provisions below.

[200.202, 200.205, 200.300] Proposal Review and Public Health Decision-Making

NPHC is concerned that the proposed rule would shift public health funding decisions away from expert, evidence-based review and toward political review. Public health grants require technical evaluation by epidemiologists, laboratorians, statisticians, clinicians, behavioral scientists, emergency preparedness experts, health communicators, community partners, and more. Projects to strengthen, for example, wastewater surveillance, study maternal mortality, improve vaccine access, evaluate violence-prevention programs, or analyze the health effects of extreme heat should be reviewed based on statutory purpose, community need, scientific merit, feasibility, and expected health impact.

Allowing political appointees to supersede expert judgment risks undermining confidence in federal funding decisions and discouraging important public health work that does not align with shifting political priorities. OMB should remove the political appointee review requirements and preserve expert, merit-based review as the foundation of federal public health awards.

[200.340, 200.341, 200.343] Termination and Suspension

NPHC is also concerned that the proposed expansion of discretionary termination authority would make public health programs unstable and unpredictable. Public health work often requires sustained, multi-year investment in staff, laboratories, surveillance systems, data infrastructure, community partnerships, and workforce development. These investments cannot be responsibly planned if awards may be terminated midstream for reasons unrelated to performance, compliance, or the original statutory purpose of the award.

Abrupt termination could strand prior federal investments, interrupt services, damage research integrity, dissolve trusted partnerships, and leave workers, trainees, students, and local agencies without support. The harm would be especially serious for local health departments, smaller nonprofits, academic partners, and community-based organizations without reserves to absorb sudden funding loss. OMB should remove the discretionary termination standard and maintain safeguards against arbitrary termination.

[200.218, 200.300] Public Health Data, Disparities Analysis, and Equity-Related Work

Public health often requires analysis by geography, race and ethnicity, age, disability, sex, occupation, income, housing status, language, and other factors relevant to disease risk, exposure, access to care, and health outcomes.

The proposed restrictions on disparate-impact studies and related activities would stymie lawful and essential public health research, evaluation, and program improvement. If public health programs cannot measure disparities, they cannot target resources effectively, evaluate whether interventions work, or protect communities facing the greatest preventable risks. OMB should remove these restrictions and clarify that lawful demographic, geographic, disparities-related, and equity-related public health work remains allowable when tied to the purposes of the award.

[200.432, 200.454, 200.461] Dissemination of Public Health Evidence

Public health practice relies on rapid learning across jurisdictions. Conferences, professional associations, subscriptions, journals, publication costs, and other dissemination activities are not luxuries. They are how outbreak findings, evaluation results, implementation lessons, clinical guidance, workforce practices, and emerging threat information move from one community to another.

Restricting these costs would slow dissemination, reduce transparency, and weaken the public health workforce. It would also burden early-career professionals, smaller health departments, community-based organizations, and academic partners that rely on federal support in sharing and applying findings from federally funded work. OMB should preserve reasonable publication, subscription, conference, membership, and professional activity costs when tied to the award.

[200.201, 200.333] Flexible Award Mechanisms

The proposed elimination of fixed-amount awards and fixed-amount subawards would create barriers for smaller public health entities. Many local health departments, nonprofits, and community-based organizations operate with limited reserves and lean administrative capacity. These are often the partners closest to communities most affected by public health threats.

Federal grants policy should expand meaningful participation by trusted local partners, rather than favoring only larger institutions with the cash flow and infrastructure to manage more burdensome reimbursement systems. OMB should retain flexible award mechanisms with appropriate accountability safeguards.

NPHC supports accountability, lawful grantmaking, transparency, and responsible stewardship of taxpayer dollars. But accountability is not served by replacing expert review with political review, making long-term public health awards vulnerable to shifting priorities, restricting lawful analysis of health inequities, or limiting the channels through which public health evidence reaches the field.

For these reasons, NPHC urges OMB to withdraw the proposed rule and not finalize it. If OMB proceeds, it should at minimum: strike the political appointee review requirements in [200.205]; remove the discretionary termination standard in [200.340]; protect lawful public health data, disparities, and equity-related work; preserve allowable costs for dissemination and professional activities; and retain flexible award mechanisms that allow smaller and community-based organizations to participate meaningfully in federally funded public health work.

Respectfully,

National Public Health Coalition
info@nationalphc.org