The Natural Science Collections Alliance (NSC Alliance) has submitted formal comments on the Office of Management and Budget’s (OMB) proposed rewrite of the Uniform Guidance for federal financial assistance, urging OMB to abandon the rule in its current form and warning that it would burden collections-holding institutions and disrupt the long-term research that natural science collections make possible.
The comments focus on the provisions of greatest consequence to the collections community: a pre-issuance review that would let political appointees displace independent scientific merit; expanded authority to terminate active awards midstream; new restrictions on international collaboration; the elimination of fixed-amount subawards used by multi-institution digitization networks; and limits on public communication, conferences, and open-access publishing.
“Collections-based science is inherently long-term and cumulative: specimen digitization, biodiversity surveys, and time-series studies build value over decades and rarely align neatly with any single administration’s near-term priorities,” NSA Alliance argued. “Subjecting this work to a political filter applied under undefined standards, with no meaningful appeal, threatens precisely the kind of foundational, slow-to-mature research that collections exist to support.” The Alliance also emphasized that “natural science collections are inherently global,” and that blanket limits on international engagement would impede specimen loans, joint expeditions, and shared databases.
Noting that the rule was issued with only a 45-day comment period and no analysis of its costs, NSC Alliance urged OMB to “abandon the rule in its current form and to approach any future major revisions to federal grantmaking policies with meaningful stakeholder consultation.”