.png?lang=en-US&ext=.png){kind=logo}
.png?lang=en-US&ext=.png){kind=logo}
Published on : July 14, 2026
CSWE, SSWR Comment on Proposed Revised Uniform Guidance for Federal Financial Assistance
On July 10, CSWE and the Society for Social Work and Research (SSWR) jointly submitted comments on the Office of Management and Budget's (OMB) Proposed Rule, Guidance for Federal Financial Assistance (Uniform Guidance)
The Honorable Russell T. Vought Director
Office of Management and Budget
725 17th Street, NW
Washington, D.C. 20503
Submitted electronically via www.regulations.gov Re: Docket No. OMB–2026–0034 — Guidance for Federal Financial Assistance (2 CFR Part 200 and related parts)
Dear Director Vought:
The Council on Social Work Education (CSWE) and the Society for Social Work and Research (SSWR) submit the following comments on the Office of Management and Budget's (OMB) Proposed Rule, Guidance for Federal Financial Assistance, published in the May 29, 2026 Federal Register (91 FR 32198).
CSWE is the national association representing social work education in the United States, with members including over 900 accredited baccalaureate, master’s, and practice doctorate degree social work programs and thousands of individual social work educators, practitioners, and agencies. SSWR is a member-based organization representing more than 200 universities and institutions, including faculty in schools of social work, research staff in public and private agencies, and graduate students.
CSWE and SSWR thank OMB for the opportunity to comment on proposed revisions to the Uniform Guidance. We support OMB’s efforts to improve accountability and transparency in Federal financial assistance, and we recognize that responsible stewardship of public funds is a shared obligation.
At the same time, we are deeply concerned that several provisions of the proposed rule would, if finalized, significantly harm the ability of social work educators and researchers to carry out the federally authorized work they have been funded to conduct, which includes but is not limited to, preparing a desperately needed behavioral health and social services workforce, conducting rigorous research on the health and social conditions of vulnerable populations, and partnering with communities to translate evidence into practice.
Social work research plays a critical role in Federal evidence-building by evaluating whether programs improve outcomes, identifying effective interventions, and informing future policy decisions across health, behavioral health, child welfare, education, housing, and justice systems.
The provisions we address below would impose new restrictions, new standards of political review, and new burdens on activities that Congress has specifically authorized and that Federal agencies have funded because they serve the public good. We recommend OMB consider withdrawing the rule and reexamine the revisions to ensure they serve OMB’s actual intent for accountability and transparency in grant making.
We also want to flag, at the outset, our concern about the timeline for this rulemaking. OMB has provided only a 45-day comment period for a proposal that would rewrite government-wide standards governing virtually every aspect of Federal grant administration, and OMB has stated its intention to issue a final rule effective by October 1, 2026, only two and a half months following the end of the comment period.
Given the scope and significance of the changes under consideration, this timeline does not allow OMB to meaningfully absorb and respond to public comment, nor does it give stakeholders a realistic opportunity to understand, prepare for, and implement changes before they become binding. We urge OMB to at minimum adopt a new implementation date for the rule that is no less than a year from the release of the final rule.
OMB Should Not Convert the Uniform Guidance into a Binding Regulation
Before turning to specific provisions, CSWE and SSWR oppose a foundational change in the structure of this rulemaking which is the proposed reclassification of 2 CFR part 200 from OMB guidance into a binding Federal regulation. Since 2013, the Uniform Guidance has taken effect only after each Federal agency completes its own notice-and-comment process to adopt it into the agency’s own regulations. That extra step has mattered. It has given stakeholders affected by a given policy a second opportunity to weigh in on how that policy will impact their specific program.
The proposed rule would eliminate that step entirely. We are concerned that this change does more than streamline an administrative process. It removes a meaningful, agency-specific check on exactly the kind of provisions discussed throughout this letter. We urge OMB to withdraw this proposed reclassification and retain the Uniform Guidance as guidance, subject to the existing requirement that each Federal agency adopt it, and any future substantive changes to it, through its own notice-and-comment rulemaking.
[§§200.202–200.206] Strike Undefined Political Criteria in Merit and Risk Review
Social work research is grounded in a commitment to evidence, community partnership, and the rigorous examination of the social, behavioral, and structural conditions that shape health and well-being. For decades, that commitment has been recognized and supported through the federal government’s merit-based peer review system, which evaluates proposals on the basis of scientific quality, significance, and the expertise of principal investigators. The proposed rule would add a new layer of review, conducted not by scientific peers but by senior political appointees, that would evaluate whether proposals selected through merit-based review “demonstrably advance the President's policy priorities” or avoid promoting what the rule calls “anti-American values.” Neither of these terms is defined. Neither is anchored to any scientific standard.
CSWE and SSWR are deeply concerned about what this means in practice for social work researchers. Research on trauma and adverse childhood experiences, on the structural conditions that drive substance use and mental illness, on the disparate health burdens carried by communities of color, and on the social determinants of health does not always fit neatly into any given administration’s stated priorities. That is not a failure of the research but the nature of rigorous science, which follows evidence rather than political direction.
Social work research already receives a relatively small share of Federal research funding compared to biomedical disciplines. An additional, non-scientific layer of political review would disproportionately disadvantage interdisciplinary and social science projects, compounding an existing funding disadvantage and further concentrating Federal research investment away from the behavioral and social sciences that our members study. A pre-issuance review process that allows political appointees to reject meritorious, fundable proposals on the basis of undefined terms like “the national interest” or “anti-American values” creates a direct path for the suppression of legitimate scientific inquiry into the most pressing behavioral health and health disparity challenges facing the country.
We are equally concerned about the new risk-review factor at §200.206(b)(2)(viii), which would allow agencies to weigh an applicant's membership in organizations that “undermine public safety or national security.” Social work researchers routinely belong to professional associations, advocacy organizations, and community coalitions that engage in policy work alongside their scientific mission. The absence of any definition of what it means to “undermine public safety,” and the absence of any notice-and-response process before a membership is used against an applicant, creates a mechanism for chilling participation in exactly the kind of civic and professional engagement that produces better, more community-connected science. We urge OMB to strike the undefined political criteria from §§200.202–200.206, limit pre-issuance review to verifying legal compliance, and add clear definitions and procedural protections to the memberships and affiliations risk factor.
[§200.300, §200.218] Remove Restrictions on Research Addressing Health Disparities
Two related provisions of the proposed rule would, together, restrict the ability of social work researchers to study the structural and social conditions that drive health and behavioral health outcomes.
The proposed revisions to §200.300 would embed administration policies on “unlawful DEI,” “gender ideology,” and related activities into the Uniform Guidance, directly affecting social work research grants and cooperative agreements. Studying structural inequities, racial and ethnic health disparities, gender-based health outcomes, and social determinants of health is central to social work research and education—not ideology. These lines of inquiry support evidence-based interventions in maternal health, children’s mental health, substance use treatment, housing instability, and community violence prevention, and they are embedded in accredited social work competency standards. Restricting Federal support for this work would narrow the scientific record and undermine federally funded workforce development at a time of serious shortages in behavioral health, child welfare, and aging services.
The proposed revision of §200.300 also lacks the definitional clarity necessary for institutions to comply with it. Terms such as “unlawful DEI,” “gender ideology,” and “radical political ideologies” are not defined, and their reach is unclear. Social work educators and researchers who train students to understand person-in-environment frameworks, who study how neighborhood conditions affect child development, or who conduct community-based participatory research with marginalized populations cannot reliably determine from the proposed rule whether their work falls within or outside these categories. The result will be self-censorship, not compliance. We urge OMB to strike the proposed additions to §200.300 that are not grounded in existing statutory anti-discrimination law.
CSWE and SSWR are also concerned that §200.300 could extend beyond activities directly supported by Federal award funds. Although OMB states in the preamble that recipients may pursue DEI activities outside Federal awards using non-Federal resources, the proposed text does not consistently preserve that limitation.
Section 200.300(b)(1) would bar recipients from using Federal awards to “fund, promote, encourage, subsidize, or facilitate” unlawful DEI practices. Because “facilitate” is undefined, agencies could read it to reach privately funded DEI infrastructure, even where no Federal dollars directly support that work.
Similarly, §200.206(b)(2)(vii)(C) and (D) would allow agencies to consider an applicant’s history of activities deemed inconsistent with Federal civil rights laws, without limiting that review to federally funded activities. This could allow agencies to deny or condition awards based on privately funded DEI commitments.
Together, these provisions could pressure social work education programs and research institutions to dismantle privately funded equity and inclusion infrastructure to remain competitive for Federal awards, threatening CSWE accreditation compliance, workforce preparation, and the profession’s mission. We urge OMB to revise §200.300 and §200.206 to clarify that the prohibitions apply only to activities directly supported by Federal award funds, not broader organizational activities funded by other sources.
CSWE and SSWR also strongly oppose proposed §200.218, which would direct Federal agencies to eliminate the use of disparate-impact liability in Federal awards and require that awards not be used to support “disparate-impact studies” or related activities. The provision defines “disparate-impact liability” broadly as a theory in which differences in outcomes among races, sexes, or similar groups give rise to a presumption of discrimination. This provision, if finalized, would strike at the scientific core of the social work research enterprise.
Documenting and understanding differential outcomes by race, gender, income, geography, is the basic methodology of health disparities research, implementation science, and prevention science. Social work researchers are specifically funded to measure and document how trauma, maternal mortality, child welfare involvement, mental health access, and the effectiveness of community-based interventions differ across racial, economic, and social groups. The communities they serve depend on that work being done.
The proposed definition does not distinguish between a civil-rights legal claim and an epidemiological or social science finding that a given condition is more prevalent, more severe, or less well-treated in one group than another. The predictable result is that researchers will avoid studies examining differential outcomes by race, gender, or other protected characteristics, funders will decline to support them, and a generation of evidence on health disparities and minority health will not be produced. We urge OMB to withdraw proposed §200.218.
[§200.340] Expanded Discretionary Termination Authority Would Harm Communities and Rupture Research Relationships
The proposed rule would authorize Federal agencies to terminate any discretionary award, in whole or in part, whenever doing so is deemed to be in the agency's interest or consistent with “the national interest,” based only on a brief written summary and with no administrative hearing rights. CSWE and SSWR are concerned about the operational and community-level consequences of this authority for the kind of research social work researchers conduct.
Social work research depends on trust built through years of community engagement and partnership. Longitudinal studies, clinical trials, and implementation projects cannot be abruptly paused or restarted without harming participants who have shared sensitive information, adjusted their lives to participate, and begun to benefit. Terminating an award for shifting administrative priorities, rather than research performance, breaks that trust and can damage future research relationships with affected communities.
This concern is not hypothetical. Recent months have already seen abrupt terminations of behavioral health and health disparities studies, disrupted training grants, and cancelled support for community-based research partnerships, with serious consequences for participants, institutions, and researchers. The impact on the future social work research pipeline is especially troubling. Doctoral students, postdoctoral scholars, and early-career faculty frequently depend on federally funded projects not only for research support but for training, mentorship, dissertation completion, and career development.
When awards are terminated for reasons unrelated to scientific performance, those pathways are interrupted in ways that are difficult to reverse. Doctoral students and postdoctoral scholars whose training grants, mentors' labs, or research projects have been cut short are leaving the field or the country at a time when behavioral health, child welfare, and aging workforce shortages are most acute, weakening the very pipeline the profession depends on to address those shortages in the years ahead.
Codifying open-ended discretionary termination authority in the Uniform Guidance would make these disruptions a permanent feature of Federal grantmaking rather than an exception. We urge OMB to withdraw the proposed standard, require terminations to be grounded in documented performance failures, and restore administrative hearing rights so researchers and community partners have a meaningful opportunity to be heard before their work is stopped.
[§§200.432, 200.450] Restrictions on Dissemination, Community Engagement, and Advocacy Hinders Advancement of Social Work Research
The proposed rule would disallow conference participation costs absent specific agency pre-approval (§200.432) and would add new restrictions on the use of Federal funds for “issue advocacy or public messaging that promotes or opposes a particular social, political, or public policy position unrelated to the statutory objectives or performance requirements of the Federal award, including messaging designed to influence public attitudes” (§200.450). Both provisions raise serious concerns for CSWE, SSWR, and the broader social work research and education community.
Scientific conferences are essential for social work researchers to share findings, learn from related fields, mentor early-career scholars, and connect evidence with practitioners, policymakers, and community leaders. Presenting at national meetings is not merely a professional activity; it is a primary way Federal research investments generate impact beyond individual grants. Requiring case-by-case agency pre-approval for conference participation, without clear standards, would delay projects, increase administrative burden, and limit opportunities for early-career researchers and trainees who rely on conferences for mentorship and career development.
The proposed §200.450 restrictions are particularly concerning because the line between federally authorized activity and prohibited “issue advocacy” is undefined. Social work education and research frequently involve community awareness efforts, translation of research findings into practice recommendations, engagement with policymakers and public agencies about program effectiveness, and public education about the evidence base for behavioral health and social services. These activities are often a required deliverable or a core measure of impact under the terms of the Federal award itself. A restriction broad enough to cover “messaging designed to influence public attitudes” could reach public-facing dissemination of research findings, community education sessions conducted as part of a grant’s implementation strategy, or presentations to policymakers about what the funded research shows. Overly broad restrictions on these activities would undermine the translational impact of social work research.
The proposed changes to §200.450, combined with proposed §200.454(d)’s undefined restriction on membership costs for organizations whose “primary purpose” is lobbying or issue advocacy, also create a risk to the professional and scientific societies to which social work researchers belong. Both CSWE and SSWR engage in policy advocacy and public education on behalf of the social work profession and the communities it serves, including but not limited to submitting comments such as this one, engaging with Federal agencies and Congress on research funding, and informing policymakers about the evidence base for behavioral health programs. This advocacy is undertaken to advance the mission of the profession and of the populations social workers serve, not as a political enterprise, and it is not funded through Federal awards.