Submitted on Monday, July 13, 2026
These comments are submitted in response to OMB-2026-0034, the revised Guidance for Federal Financial Assistance, on behalf of the Council of Professional Associations on Federal Statistics (COPAFS). COPAFS is a U.S.-based nonprofit organization devoted to educational activities and to preserving the public good represented by federal statistical collections. Since 1981, COPAFS has provided an open dialog between those who use federal statistics in professional contexts and the federal statistical agencies that produce those statistics for the public good. Supporting organizations include professional associations, businesses, research institutes, and others that help to produce and/or use federal statistics.
Federal research grants are essential to the work which COPAFS members engage in and provide a further return on investment for federal statistics. These grants are used to fund high-value longstanding data collections like the Panel Study of Income Dynamics (PSID), to fund collaborations between federal statistical agencies and subject matter experts to develop and implement improvements in federal statistics, and to support research that uses federal data to produce policy insights, raising the return on federal data assets.
The changes proposed in the Guidance for Federal Financial Assistance OMB-2026-0034 will cause significant harm to the ongoing collaboration between federal statistical agencies and those who utilize these data to gain further insights into the nation’s economy, infrastructure, and health. We ask that the proposed changes be withdrawn in their entirety.
Accurate, objective, and timely data is the bedrock of public policy, economic forecasting, and scientific progress. By introducing political oversight, sudden funding instability, and broad self-censorship requirements into the grant-making process, this rule directly threatens the integrity, continuity, and accessibility of vital research undertaken by American researchers, including COPAFS members.
These new proposed rules undermine the time-tested methods of the scientific enterprise and, as a result, threaten the data integrity and objectivity of much needed research. Section 200.205 wouldgrant political appointees ultimate veto power over grant awards and allow administration agendas to dictate what data is collected and how it is structured. This is poor policy regardless of the administration in office; subjecting methodology to ideological litmus tests destroys the perception of federal data as neutral, reliable, and evidence-based. Overly broad bans on concepts like “disparate impact analysis” effectively censor critical research into demographic, health, and economic disparities, leaving policymakers blind to persistent systemic issues.
Multi-decade longitudinal studies rely on stable, multi-year grant funding to maintain statistical trends and baseline measurements. Section 200.340 expands the authority to terminate active grants without cause. This provision would create catastrophic data gaps that can permanently ruin years of continuous tracking. Abruptly pulling funding from active data collection infrastructure wastes billions in taxpayer dollars and leaves vital databases incomplete.
Prohibitions on organizational affiliations and specific concepts, as outlined in Sections 200.218, 200.219, and 200.220, will force grantees to alter, delay, or completely withhold public data releases to avoid open-ended liability. Inhibiting international collaborations and penalizing complex data-sharing partnerships restricts the global flow of open data. The resulting compliance confusion will reduce the frequency of data updates, leaving businesses and local governments to rely on outdated, less reliable information.
The loss of U.S. scientific leadership resulting from the proposed changes will slow the development of critical methodological and scientific advances, undermine our international standing in the sciences, and compromise the integrity and utility of federal statistics by restricting engagement with external specialists. For these reasons, COPAFS requests that the proposed revision of the Guidance for Federal Financial Assistance be withdrawn in its entirety.