Yesterday, the American Crystallographic Association submitted formal comments to the U.S. Office of Management and Budget (OMB) regarding its proposed revisions to the Uniform Guidance (2 CFR Part 200), the federal regulations that govern how research grants are awarded and administered.
At first glance, changes to federal grant regulations may seem like something that only affects university administrators or grant offices. In reality, these policies have far-reaching implications for researchers, students, national user facilities, scientific societies, and the pace of scientific discovery itself.
That is why the ACA believed it was important to participate in the public comment process.
Read the Comments
Why This Proposal Matters
Many ACA members rely on long-term federal support to conduct research in crystallography, structural biology, chemistry, materials science, and related disciplines. Their work often depends on sustained funding, access to synchrotron and neutron facilities, specialized instrumentation, and collaborations that span multiple institutions and many years.
Our comments focused on several areas that we believe are essential to maintaining a strong and productive research enterprise.
First, we emphasized the importance of preserving independent scientific peer review as the primary basis for evaluating research proposals. Peer review has long been the cornerstone of federal research funding, ensuring that scientific merit, innovation, and technical excellence remain at the heart of funding decisions. We encouraged OMB to clarify that any additional review considerations should complement—not replace—expert scientific assessment.
We also expressed concern about proposed changes that could expand the circumstances under which federal research awards may be modified or terminated. Scientific research often involves multi-year projects, long-term collaborations, and significant institutional investments. Greater uncertainty surrounding awarded grants can disrupt ongoing research, affect students and postdoctoral researchers, and discourage ambitious scientific projects.
Finally, we encouraged OMB to continue reducing unnecessary administrative burden. Every hour researchers spend on duplicative reporting or excessive compliance requirements is time that cannot be devoted to conducting research, mentoring students, training the next generation of scientists, or making new discoveries. Simplifying grant administration while maintaining appropriate accountability benefits both researchers and taxpayers.
Underlying all of these recommendations was a common theme: scientific research depends on stability, transparency, and predictability. Institutions need confidence that they can recruit talented researchers, invest in infrastructure, and pursue long-term scientific questions without unnecessary uncertainty.
Advocacy Is Part of Our Mission
One of the responsibilities of a professional scientific society is to advocate for the environment in which science can thrive.
The ACA exists not only to support the exchange of scientific knowledge through meetings, publications, and educational programs, but also to represent the interests of our members when policies have the potential to affect research. By submitting comments during the federal rulemaking process, we ensure that the voices of crystallographers and structural scientists become part of the official record considered by policymakers.
While no single comment determines the outcome of a proposed rule, collective participation from scientific organizations, universities, researchers, and professional societies helps agencies better understand the real-world impacts of their decisions.
Public comment opportunities are one of the few times that scientists can speak directly to policymakers before regulations become final. You do not need to be a policy expert to participate. Your experience as a researcher, educator, facility scientist, student, or grant recipient provides valuable insight into how proposed policies affect the scientific enterprise.
When opportunities like this arise, we encourage ACA members to take part. Whether you submit comments individually, through your institution, or as part of a scientific society, your perspective helps ensure that policymakers understand the real-world impact of their decisions.
Yesterday's submission is one example of the ACA working on behalf of our community, and we remain committed to engaging in opportunities that promote a strong, stable, and innovative research enterprise.
By participating in the public comment process—both as scientific societies and as individual researchers—we help ensure that decisions affecting science are informed by the people who know science best.
