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AHPA submitted comments on: Regulation for Federal Financial Assistance; Docket ID OMB-2026-0034. Click here for the full article. Below are some key takeaways.

• Preserve stability and predictability for federal award recipients. AHPA urges OMB to ensure that federal awards supporting patient care, research, workforce development, rural health, disaster resilience, and infrastructure cannot be terminated or suspended based solely on broad or changing agency priorities. Post-award action should generally be limited to clearly defined circumstances, such as material noncompliance, failure to meet award requirements, or lack of appropriated funds.
• Establish procedural and financial protections before terminating or suspending awards. AHPA recommends requiring advance written notice, an opportunity for recipients to respond, and a documented explanation before discretionary termination or suspension. OMB should also require reimbursement of necessary, allowable, and unavoidable costs incurred in reasonable reliance on an award, including staffing, equipment, contracts, project closeout, and efforts to preserve patient safety or project integrity.
• Protect existing multiyear projects from disruptions caused by changing priorities. AHPA recommends clarifying that existing awards and continuation funding will not be terminated solely because agency or administration priorities change, provided the recipient remains compliant and the project continues to satisfy program requirements. This protection is particularly important for long-term research, rural health, clinical, and infrastructure projects that require substantial upfront investment.
• Preserve independent expert peer review as the foundation of research funding decisions. AHPA urges OMB to maintain independent scientific and technical peer review as the primary method for evaluating research merit. Senior political appointees may review legal compliance, program alignment, and stewardship of funds, but should not substitute non-expert judgment for scientific review or override peer recommendations without a documented, objective, and transparent basis.
• Create clear, prospective, and administrable standards for research and recipient oversight. AHPA recommends clearly defining new research expectations such as “Gold Standard Science,” national policy requirements, and standards governing prime recipients and subrecipients. Requirements should apply prospectively, include sufficient implementation time, and be tied directly to federal awards rather than vague concepts such as reputational harm or the national interest.