ASE Submits Comments on the OMB Uniform Guidance Proposed Rule

On July 13, ASE submitted comments to OMB on the proposed revisions to 2 CFR Part 200 governing federal financial assistance (OMB-2026-0034). The letter raises concerns that the rule would add a pre-issuance review layer allowing senior political appointees to override scientific peer review, impose an undefined “Gold Standard Science” standard as an award criterion, and make publication costs, including article processing charges and open-access fees, unallowable. The letter also flags expanded termination authority under §200.340-341 and restrictions on foreign collaboration under §200.220. ASE urges OMB to withdraw the rule or, at minimum, revise it to preserve peer review as the primary basis for funding decisions, anchor “Gold Standard Science” to existing research integrity standards, and retain publication costs as allowable expenses.

These changes would directly destabilize the funding environment for cardiovascular imaging research. NIH-funded echocardiography grants, including R01, K, and T32 awards and multicenter consortia, could clear peer review yet still be held or denied at the appointee stage, and imaging grants already tend to receive lower impact scores than higher-risk therapeutic proposals, leaving them disproportionately exposed. The publication cost prohibition would strip the primary mechanism investigators use to satisfy federal public-access mandates, slowing dissemination of echo research, guidelines, and standards to clinicians and patients.