The National Academy of Education, together with 19 other scholarly and professional societies representing more than 85,000 individual members, today filed a formal comment urging the U.S. Office of Management and Budget (OMB) to withdraw its proposed rule, “Regulation for Federal Financial Assistance”, calling it “unlawful, unworkable, and would cause serious and in many cases irreversible harm to American education research.”
The coalition — whose members include faculty, researchers, practitioners, and students at research universities, academic and scientific organizations, and think tanks across the country — argues that the proposed rule, if finalized, would inject political control into what has been a rigorous, independent federal research enterprise, ban entire categories of legitimate scholarly inquiry, and conflict with multiple federal statutes including the General Education Provisions Act (GEPA), the Education Sciences Reform Act (ESRA), the CHIPS and Science Act, the America COMPETES Act, Title VI of the Civil Rights Act, and Title I of the Elementary and Secondary Education Act.
The comment identifies two broad categories of harm. The rule's substantive restrictions would prohibit federally funded researchers from studying diversity, equity, and inclusion, examining topics related to gender identity and immigration, and conducting disparate-impact studies — areas where federal statutes independently require, or courts have protected, exactly the research OMB seeks to ban. The rule's procedural changes would require political-appointee approval of research prior to funding which would fundamentally compromise the integrity of peer-reviewed education science; authorize termination of active grants without notice or appeal based on a simple determination that the research no longer aligns with the administration’s interests; penalize research infrastructures by giving merit preference to applicants with low indirect cost rates; eliminate publication and conference costs that many grants explicitly require; and impose new administrative burdens in violation of the Paperwork Reduction Act.
The comment also raises a separate, independent legal ground for withdrawal: none of the 41 agencies co-signing the proposed rule provided any agency-specific explanation for how the rule comports with their own statutory mandates — a deficiency the organizations argue independently violates the Administrative Procedure Act's notice-and-comment requirements.
The organizations urge OMB to withdraw the proposed rule in its entirety and have offered to work with OMB and co-signing agencies to develop grant management reforms that improve efficiency and accountability without compromising scientific independence and rigor.