For Immediate Release
Oak Brook, Illinois — Comments to OMB Proposed Rule to revise 2 C.F.R. Part 200, aka Uniform Guidance
Submitted by the Society for Laboratory Automation and Screening
July 13, 2026
These comments are submitted by the Society for Laboratory Automation and Screening (SLAS). SLAS is a 501(c)3 not-for-profit association headquartered in Oak Brook, Illinois. Our mission is to foster knowledge sharing and collaboration that unites scientists, educators and industry professionals to co-create solutions for a healthier world. We have over 23,000 members in our community, with 73% residing in the U.S., including academic, industry and government researchers, as well as developers and providers of laboratory automation technology and tools.
Our comments focus on three areas of the proposed rule, Section 200.432, 200.454 and 200.461
200.432 – Conferences proposes, “…to add a requirement that costs for attending conferences are allowable if participation in the conference is expressly approved by the agency and included in the terms and conditions of the award.” This requirement fundamentally misunderstands the nature of scientific research and the role of professional conferences in advancing federally supported work. The OMB must recognize that scientific research is both dynamic and collaborative. Scientific conferences are not discretionary activities, but an essential component of the research process, providing opportunities to disseminate findings, receive critical peer feedback, establish new collaborations, and accelerate scientific discovery. Restricting investigators' ability to attend scientifically relevant conferences would diminish the impact of federally funded research and reduce the return on the public's investment in science. At the time of applications, researchers often cannot predict which conferences will be most relevant to disseminate their findings, build collaborations, or keep abreast of a rapidly evolving field. Requiring pre-award agency approval for specific conference attendance freezes this flexibility and will impede responsive, high-quality science. The requirement will increase the federal agency administrative burden. Every conference attendance decision, including low-cost, highly relevant events, will require advance agency review, approval, and documentation. This will increase bureaucratic overhead that the OMB’s framework was designed to reduce. The requirement will disproportionately impact early-career researchers who rely on conference participation to build professional networks, present findings, and access career development resources, activities essential to sustaining federal research.
200.454 – Memberships, Subscriptions and Professional Activity Costs proposes, “…to clarify that the only allowable costs under this section are those necessary to fulfill award requirements.” And “…add a requirement for prior approval of the Federal agency.”
Professional memberships are moderate in cost, widely accepted as standard practice in research, and directly support the scientific work being supported. This requirement will generate substantial paperwork with negligible return in terms of cost savings. It will block critical membership-dependent activities, including journal access, conference registration discounts, and collaborative scientific society programs. It will restrict access to peer-reviewed journals, technical databases, and subscription-dependent resources to conduct literature reviews, avoid duplicating prior work, remain current with the field, and produce rigorous results. The requirement is inconsistent with other federal policies, including promoting evidence-based research and rigorous use of scientific literature. Denying the cost of accessing the literature while requiring its use is contradictory.
200.461 – Publication and Printing Costs proposes, “OMB is revising the section to make publication costs unallowable unless such costs are expressly required by statute or approved in advance by the Federal agency on a case-by-case basis.” The text goes on to state, “Publication costs are not inherently necessary to carry out the core programmatic objectives of most Federal awards.” This is not true. In fact, NIH has launched an initiative, Strengthening Replication and Reproducibility of NIH-funded Research, “to elevate replication and reproducibility studies as foundational to the conduct of gold standard science.” The proposed change is inconsistent with longstanding federal policy on scientific transparency and open access and will create a direct contradiction at the heart of federally supported research. An August 25, 2022 memorandum from the Office of Science and Technology Policy (OSTP) directed all federal agencies to develop and implement policies ensuring that peer-reviewed publications resulting from federal funding be made publicly available. Open-access fees are the primary mechanism by which researchers satisfy these mandates. Making fees unallowable effectively prevents compliance with open-access requirements, creating an irreconcilable conflict between two federal policy directives. Secondly, dissemination of research results is an integral component of scientific research. Peer-reviewed publications are the primary vehicle through which federally funded research achieves its purpose: advancing knowledge, enabling replication and validation, and informing policy. Treating publication costs as categorically unallowable severs the link between federal investment and public benefit. The provision would reduce the visibility and impact of federally funded research, limiting its return on public investment. Finally, the proposal would discourage researchers from publishing in open-access journals, which best serve public transparency goals and meet federal requirements, and push them towards free options that lose public access or skip peer-review processes, increasing the likelihood of irreproducible and scrutinized research. The outcome is precisely the opposite of what federal science policy should encourage.
While these provisions are presented as a way to reduce burden and cost, they will do the opposite. Conference attendance, society membership, and publication are high-frequency, low-dollar activities. Replacing the current reasonableness standard with case-by-case agency pre-approval does not remove these costs. It moves them onto federal program staff, who must review, approve, and document large numbers of small and individually reasonable requests. In NIH’s own analysis, publication costs average well under one percent of the direct costs of a research award. The administrative effort to screen each request will, in many cases, exceed the value of the cost being controlled. The result is more burden on the agencies the rule is meant to relieve, which runs directly counter to the rule’s stated objective of reducing burden.
These provisions will have the following impact:
In summary, we request that the above Rule proposals be withdrawn. We believe instituting these rules will run counter to the stated objectives of improving transparency and reducing the recipient burden. In fact, they will have such a chilling effect on the scientific process that the development of medicines, devices and diagnostics will be reduced and public costs increased.
OMB is accepting public comments until July 13, 2026. If finalized, the rule will take effect on October 1, 2026.
We urge our community to submit comments to protect the future of scientific advancement. Additionally, we recommend that our community send copies of their comments to their respective federal representative and senators.
When submitting comments, specificity is vital to explain your concerns. Consider addressing how the changes would impact your ability to:
Publish research findings and access essential scientific literature.
Attend and present at conferences necessary for sharing scientific research and collaboration.
Participate in and benefit from professional societies like SLAS.
Collaborate with international partners and co-publish scientific research.
To submit a comment, visit https://www.regulations.gov/document/OMB-2026-0034-0001 and follow the instructions to submit a comment on any/all parts of the proposed rule. You can submit as an individual, organization or anonymously (any "interested person" can submit a comment).
For questions regarding SLAS’s participation in submitting a comment, please email SLAS CEO Vicki Loise, CMP, CAE.
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SLAS (Society for Laboratory Automation and Screening) is an international professional society of academic, industry and government life sciences researchers and the developers and providers of laboratory automation technology. The SLAS mission is to bring together researchers in academia, industry and government to advance life sciences discovery and technology via education, knowledge exchange and global community building.
SLAS publishes two peer-reviewed and MEDLINE-indexed scientific journals, SLAS Discovery and SLAS Technology. For more information about SLAS and its journals, visit www.slas.org/journals.
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Jill Hronek
Director of Marketing Communications
Telephone: +1.630.256.7527, ext. 103
E-Mail: jhronek@slas.org
