Submit a Public Comment on the OMB Rule

The American Musicological Society (AMS) encourages the submission of public comments on the Office of Management and Budget’s (OMB) proposed revisions to the “Regulation for Federal Financial Assistance.” The American Musicological Society has already submitted a joint public comment with the Society for Music Theory (SMT), co-signed an American Council of Learned Societies (ACLS) statement, and co-signed a joint letter with 322 other organizations asking that the comment period be extended. But we need many more people to speak out before the comment period closes on 13 July 2026. So, the AMS strongly urges you to submit your public comment on the OMB’s proposed rule now.

Comment Now

Why Comment?

The proposal, which is slated to go into effect in October 2026, would radically rewrite the rules of federal grantmaking in ways that could disrupt not just the American Musicological Society’s programs, but the work of every organization, university, or municipality that relies on funding from the US federal government to do its work. That is roughly $1.1 trillion dollars in federal funding for everything from music programs to medical research to road maintenance in your town or city.

What does the rule do?

Politicizes grantmaking: It empowers political appointees to block funding, terminate grants, or revise federal grant terms at any time and for any reason without appeal or review

Demotes peer review: It demotes peer review in scientific and educational grantmaking to “merely advisory”; politics are elevated

Increases paperwork: It requires tons of new paperwork for grantees, a burden that will fall disproportionately on small organizations like the AMS

Bans disparate impact: It bans “disparate impact” assessments that target support where it is most needed – to the disabled, economically disadvantaged, racially or ethnically marginalized, and many others

Undermines international collaboration: It strongly discourages international scholarly collaborations

It is binding: It makes this OMB “guidance” into a regulation that is binding for all federal agencies, regardless of agency preferences

Other organizations have published an explanation of the rule’s impact:

• ​AAU / APLU / COGR
• National Council of Nonprofits
• American Physical Society
• National League of Cities
• Association of Research Libraries

Many reputable organizations have already submitted public comments and published community statements delving into the details of the OMB’s proposal. If you share the Society’s concerns, submit your own public comment. The best public comments are individualized, serious in tone, and focused on the substance of the proposal.

The voices of both individuals and institutions matter. The more public comments that are submitted, the more likely it is that the OMB will change its proposal or that Congress will take notice and get involved. Still, even if nothing changes and the rule is implemented as planned in October 2026, a public outcry against this proposal could form the basis for subsequent legal and administrative challenges. So, please make your voice heard.

The deadline for submitting public comments is 13 July 2026.