kay so i spent a long time writing this comment, and i would like to share it cause it made me tired and sad, but also cause it might help other people write comments in less time, which is good. please forgive how i had to word certain arguments, as i felt if i presented too explicitly on the left my arguments would be thrown out. like obviously the proposed revisions are transphobic and racist as fuck, but those words are like water off a duck's back, they don't care because they refuse to believe trans people and racism exist. i even threw in some "i thought u guys hated communism, why USSR shaped" bc it really is that fucking bad. really fucking bad. please comment. take whatever you want from mine, or from any pre-script, but please comment.
Docket OMB-2026-0034 claims that the proposed revisions, or rather massive overhaul to the federal grant funding system, are warranted due to, basically, misuse of funds. The document outlines three specific reasons ("improve transparency, accountability, and oversight", "clarify status of OMB's policies and requirements...and oversight", and "reduce recipient burden"), but they all amount to a core belief that the current federal grant system is misusing money and that for the grave crime of misusing federal funds, individuals attempting to misuse money should held fully accountable and punished. The document argues that “misuse” is that which is maligned with the policies of the Trump Administration as described in Trump’s Executive Orders, including the ambiguously or at best erroneously defined “DEI Initiatives”, “gender ideology”, and “transition”. The revisions within this document demand that the scientific community abide by not only these faulty definitions, but broadly and forevermore the opinions and ideology of the Republican party. This document is hypocritical, as it accuses the scientific community of catering to the opponent ideology, when it explicitly demands that grant applicants toe their party line. By prohibiting and threatening scientists with termination for investigating the reality Americans live with everyday, not only do these revisions throw into doubt the conclusions of federally funded research, it denies Americans the very "meaningful results” which the document demands of funding applicants. Rather than patch public trust in the American scientific community, the proposed revisions will destroy all authority the scientific community currently holds.
This argument hinges on the underlying belief that the OMB guidelines prior to the Biden Administration was fully fair and operational, and that ideology-informed changes to policy has irreparably ruined the grant system to the point that a massive over-correction is warranted. However, these claims are not born out of historical fact. The scientific fields studying class differences, gender expression, and racial discrimination have not, historically, been well funded fields. Indeed, it is well documented that the academic community could fairly be criticized as discriminatory against minorities such as black and brown people, women, immigrants, disabled people, transgender, non-heterosexual, and individuals of any number of overlapping labels. The belief that, within one presidential term, that broad trend (which to be fair has diminished in recent years) was flipped to the point of requiring aggressive correction is tenuous at best. The support for this claim largely rests on presenting a number of terms which are left undefined (“woke”, “leftist extremism”, “neo-marxist perspectives”) and are thus designed to be used strategically to apply to whatever becomes counter to the current administration’s ideology. This ideology is proven to be amorphous and worth nothing, as it is based entirely on the whims of Donald Trump. Take for example his about-face on AI. This document spurns “AI censorship”, and yet Trump has in the last few months been a loud supporter, dismissing AI critics as “extremists” and refusing to sign any AI regulation legislation into law. Rather than worrying about DEI initiatives and transgender individuals, nothing has damaged public trust more than the president’s own actions.
As such, I disagree that these revisions are at all required. If it is believed by the drafters of these revisions, as implied throughout the document, that the pre-Biden policies were acceptable, then revert those relevant changes if you must. If the administration believes misuse of federal funds demands accountability, perhaps it would better restore public trust if they could address the flagrant misuse of federal funds by the head of state in order to rebuild a ballroom, plan a victory arch, bungle the reflecting pool, and other such egotistical projects. It has not been proven anywhere in the document that the potential misuses in grant funds has at all approximated the money wasted by the head of the administration in the pursuit of self-flattery. The revisions proposed are extreme, unwarranted, politically motivated, and will result in a dictatorial level of control over the scientific community which is plainly incompatible with the pursuit of truth.
Any policy requires flexibility in how regulations are interpreted and enforced, and to require otherwise is either to demand excessive control or to admit to no control at all.
Disagree: 2 CFR [200.111] English language.
As there is no official language of the United States, this seems to be an irrelevant change. The vast majority of grant application information is only available in English, and requires a high level of English to write. However, the United States is one of the most linguistically diverse nations in the world; to demand English be used in order to access federal funding implies that the only Americans worthy of funding are those who can write in English at an incredibly high level (a level higher than the authors of these revisions). Rather than serve the American people, as the author has stated the purpose of these revisions to ultimately be, this requirement only serves to make federal funding more restrictive.
Disagree: 2 CFR [200.202] Program Planning and Design.
"...the goals and objectives must aim to achieve meaningful results.” OMB also proposes to clarify that “goals and objectives must be consistent with the public purpose of Federal authorizing legislation and aligned with administration policies and priorities." I find this requirement highly objectionable. For one, 'meaningful results' is not meaningfully defined; elsewhere, this document states that it was unacceptable that federal funding went to projects which were not concerned with "transportation, infrastructure, scientific research, public health, and other essential public goods", so assuming this is what is meant by meaningful results, I am highly concerned that the results of the humanities and social sciences may be broadly dispatched with. Moreover, considering the lack of care with the phrasing of this section, I'm inclined to believe that the ambiguous definition of “meaningful results” is intentional, in order to provide a broad warrant to deny any application. This is supported by the second sentence of this section: “objectives must be consistent with the public purpose of Federal authorizing legislation and aligned with administration policies and priorities.” In other words, not only are applications required to be symphonic with both the law and the spirit of the laws being debated by the current House and Senate, but also with the ideology of the current president's administration. In other words, applications must be savory to the Republican party. This is bald-faced political manipulation which endangers the integrity of the entire American scientific community. Perhaps there is ground to demand that science be useful (though is it science if it is not? And is something not useful if it is useful only to one person?), but there is no ground to demand that science agree with a party ideology. Just as this document accuses the Biden administration of abuses of power, the Trump administration does so here. Science cannot be required to admit the factuality of Trump's unsupported beliefs. The scientific community must be empowered to experiment and arrive at conclusions counter to any political ideology. To demand otherwise is to destroy science in favor of creating a propaganda machine. The objectives of any federally funded project becomes so questionable as to be useless to the pursuit of truth. In other words, this clause results in an end which is unstoppably, inherently counter to the first sentence, to provide "meaningful results" for the betterment of the American people. Take for instance the scientists who study how gender is perceived within a culture, a commonly cited member of the "DEI"/"woke" projects. It is very useful to understand ho gender works, as these conclusions can help explain the experience of every American: everyone has a gender. It has been proven to generate meaningful results, informing treatment plans for individuals with severe gender dysphoria. However, this entire field of study would be wiped out wholesale under this revision, as according to the administration's policies, there is no such thing as gender dysphoria or indeed gender at all, only sex. Investigation will not only be hampered but strangled if the administration is given the right to declare existence or nonexistence, worth or worthlessness of anything which comes under the party’s crosshairs.
Disagree: 2 CFR [200.205] Federal Agency Review of Merit of Proposals
Once again, according to EO 14332, anything which is "woke" is presumed to be counter to national interests, presumed to be discriminatory, presumed to be impermissible subject matter. However, as "woke" is never clearly defined, the subjects which the "woke" label might be applied to is equally broad to the point of arbitrary, authoritarian control. So too, did the Soviets deny and prosecute anything which was deemed "American" or "capitalist" or "Trotskyist" with nary an argument for why. The definitions are not provided because they are supposed to be meaningless, they are simply a warrant to deny that which goes against party lines. This Agency Review, designed to ensure nothing "woke" gets through the door, is liable to deny research such as the medical needs of women, wealth inequality across race and gender, vaccine research and development, etc. Nowhere in this document is it stated that the needs of women, people of color, immigrants, veterans, transgender individuals, or disabled individuals, all of whom are Americans, will be protected. All these populations are regularly attacked under the artifice of "wokeness", when these individuals are not only Americans, but communities who are in dire need of help. The extent to which they need help cannot even be determined under this revision. This particular regulation makes it clear that only friends of the party will be in charge of reviewing grants, and that they will be interpreting "national interests" and "woke" in whichever way pleases their supreme commander rather than what is actually to the benefit of the people.
Disagree 2 CFR [200.211] Information Contained in the Federal Award
While providing a physical copy of the terms and conditions may be out-dated, recipients should be given access to a downloadable PDF that they can refer to offline. Shifting political motivations has resulted in government websites being irreparably changed or rendered inaccessible. As access to the terms and conditions is imperative to ensure they avoid violating any restrictions that could result in termination, I find it incredibly odd that the OMB would no longer be required to provide that information explicitly. It can be challenging to navigate numerous different government websites due to, again, the inconsistent changes to their interfaces and content, and as users are excessively in danger of missing information pertinent to them, I think that federal agencies should be required to provide the recipient with electronic access to the complete terms and conditions.
Disagree 2 CFR [200.218] Prohibition of Using Federal Awards To Promote or Support Theories of Disparate-Impact Liability
The language of this revision would prohibit not only the research on individuals who are affected by disparate-impact liability (disproportionately being negatively affected by a law), but also projects which "promote or support" the "theory". This is another example of the current political ideology in power asserting control over facts. John Ehrlichman, Nixon's aid during his administration, admitted that the War on Drugs was started to warrant extreme policing of black communities. While prosecuting drug offenses isn't explicitly racial, the point was that it would be interpreted and enforced as such. Poll taxes were outlawed for the same reason; as black Americans are disproportionately poor, by requiring money to be paid to vote, you are disproportionately prohibiting black people from voting. This is historical and political fact. It is a strategy that has been admitted to over and over again, and is not a theory. One of the purported purposes of these revisions is to prevent discrimination; if that is the case, all manners of discrimination should be investigated with the full weight of the scientific community, and yet this revision demands that the most basic mechanism of systematic discrimination not be investigated. In fact, that it should be dismissed outright as untrue. It is absolutely unacceptable for scientists who are aiming to discover truth to admit to known falsehoods to please the party leader and toe the party line. At this point, Donald Trump is simply following in Uncle Joe's footsteps.
Disagree 2 CFR [200.300] Statutory and National Policy Requirements
In order for a policy to be reasonably enforced on the federal scale, vacuous terms must be made explicit, or else it falls to the judicial branch to decide how to interpret such terms. The Executive Orders released by the current administration fail to define its own critical terms so universally and so dismally that almost every single EO has been challenged in court. In court, despite years of legal argument, “DEI programs” have not been found to be unlawfully discriminatory (such as in Honeyfund.com Inc., et al. v. DeSantis, Do No Harm v. Pfizer, etc.), and thus do not serve as a legitimate warrant for national policy. Affirmative action was outlawed in the 2023 decision, but affirmative action is not a by-word for “DEI programs”, despite how this document pretends that it is. The definitions for "gender ideology" and "transition" do not reflect current scientific consensus and are mere unsupported opinion. Though they may be the opinions held by a very powerful individual, and by individuals who were raised with a prescriptivist understanding of the human experience, it is worth nothing in the face of scientific discovery, which has as its explicit goal to dissect "doctrine felt as fact" and arrive at a more accurate, objective truth. It is not an opinion that there are individuals who wish to be the opposite gender, and thus it is also not a lie or manipulation that these individuals were once children. These are Americans whose right to self expression and to their own bodies must be protected, and this revision and these definitions disregard and dismiss them at best, and endanger and prosecute them at worst. As gender is a well documented human experience, and is obviously experienced by Americans by extension, researching how gender works in humans is beneficial and has provided meaningful results for hundreds of thousands of people nationwide. To pretend otherwise is, at this point, political strategy and hatefulness rather than a legitimate basis for policy revision. Claims of discrimination against cisgender people have been found to be spurious and malicious in nature with no bearing on reality (there are fewer than two dozen trans athletes, for example, and do not constitute a threat to women's sports). The definition of "discrimination", as seen in this proposed revision, is not used in the standard sense or any rational sense; it is used to mean "anything which makes explicit the disparity between races or between minority and majority groups". Take for example the sentence, "In particular, [the DOJ] clarified that Federal antidiscrimination laws apply to programs or initiatives that involve discriminatory practices, including those labeled as DEI programs." “DEI programs” is too broad a descriptor to be unlawful or to be discriminatory, but this document presupposes that they are inherently so. The point of this revision is to stop discrimination, and in the same language, prohibits the investigation of whether any non-white community may be experiencing discrimination. What is this, if not doublethink?
Disagree 2 CFR [200.340] Termination and Suspension
As I have argued, not only are the supposed purposes warranting these revisions highly dubious, but to suddenly switch from guidelines to restrictions is to demand the power to control the entire American scientific community. This is blatant authoritarianism, especially when there is no factual or legal basis, but rather the administration's own political ideology. This document positions the political ideology of the Trump Administration as one which is correct and neutral, when it demands throughout this entire document that the scientific community accept obvious falsehood over informed fact. It is unacceptable that any grant be terminated for such reasons.
