Glen Allen, VA—July 9, 2026—KnowledgeWorks Global Ltd. (KGL) has submitted formal comments to the Office of Management and Budget regarding its proposed revisions to the Uniform Guidance for Federal Financial Assistance.

While supporting the goals of accountability and responsible stewardship, KGL encourages OMB to consider how changes to research funding policy may affect the broader scholarly communications infrastructure—including peer review, research integrity, accessibility, preservation, and the systems that transform federally funded research into trusted, discoverable knowledge. Our comments reflect the perspective of an organization that supports publishers, societies, and research institutions across the full publication lifecycle.

Read KGL’s full letter below and at https://www.kwglobal.com/news/kgl-submits-comments-to-omb-on-proposed-federal-financial-assistance-regulations.

Docket No. OMB-2026-0034

Dear Office of Management and Budget:

KnowledgeWorks Global Ltd. (KGL) appreciates the opportunity to comment on the Office of Management and Budget’s proposed Regulation for Federal Financial Assistance. We support the federal government’s longstanding commitment to accountability, transparency, and responsible stewardship of taxpayer resources. Strong public confidence in federally funded research depends on effective oversight of public investments and policies that maximize their long-term scientific and societal value.

KGL’s perspective

KGL offers a perspective that differs from that of research institutions and grant recipients. We do not receive federal research funding. Instead, we support the scholarly communications infrastructure through which federally funded research is evaluated, communicated, preserved, and incorporated into the permanent scientific record. Through editorial services, publishing technology, accessibility, consulting, and research integrity programs, KGL supports thousands of journals and hundreds of thousands of manuscript submissions and published articles annually. This work provides a unique perspective on how federal research policy ultimately shapes the evaluation, communication, and long-term stewardship of federally funded research across disciplines, publishers, and research communities.

Our perspective begins where most discussions of federal research policy end. The proposed rule appropriately focuses on the administration of federal financial assistance. KGL’s work begins after funding has been awarded, as research moves through editorial assessment, peer review, publication, dissemination, accessibility, preservation, and ongoing stewardship of the scientific record. These activities are often viewed as downstream functions, yet they determine whether publicly funded research becomes reliable, discoverable, reusable knowledge that advances science, improves health, informs policy, strengthens economic competitiveness, and delivers lasting value to taxpayers.

Our concern, therefore, is not with the objectives of the proposed rule. Rather, it is that several proposed revisions, viewed collectively, may influence not only the administration of research awards but also the broader ecosystem that enables federally funded research to achieve its greatest public value. We respectfully encourage OMB to evaluate these broader effects as it considers the final rule.

Supporting the complete research lifecycle

Federal research achieves its greatest public value when scientific discoveries become trusted knowledge. That transformation depends upon an interconnected scholarly communications infrastructure that includes editorial assessment, independent peer review, publication ethics, accessibility, metadata standards, digital preservation, indexing, research integrity, and the professional communities that sustain these activities. Collectively, these functions provide the independent scrutiny, transparency, permanence, and discoverability that allow federally funded research to become part of the enduring body of scientific knowledge on which future discovery depends.

For that reason, KGL believes the proposed rule should be evaluated across the complete research lifecycle rather than solely through the administration of federal financial assistance. Stewardship of taxpayer resources includes responsible management of research awards, but it also includes preserving the conditions under which those investments achieve their intended scientific, medical, economic, and public benefit.

This broader perspective is particularly important because the United States has long led the world not only by investing in scientific research, but also by building an unparalleled ecosystem for evaluating, communicating, preserving, and applying scientific knowledge. That ecosystem supports biomedical innovation, advanced manufacturing, artificial intelligence, national security, education, and economic competitiveness. Policies affecting federally funded research should therefore be evaluated not only for their administrative consequences, but also for their effects on the broader scholarly communications infrastructure that enables scientific discovery to generate lasting public and economic benefit.

The effects of increased administrative uncertainty

Several provisions of the proposed rule illustrate why this broader perspective is important. KGL recognizes that the proposed revisions to 2 C.F.R. §§ 200.205 and 200.206 are intended to strengthen oversight during the pre-award process and that the proposed revisions to 2 C.F.R. § 200.340 seek to provide agencies with additional flexibility regarding suspension or termination of awards. We recognize and support OMB’s commitment to ensuring that federal agencies have the tools necessary to protect taxpayer resources and administer federal assistance responsibly.

Our concern is not with preserving appropriate agency discretion. Rather, it is that increased uncertainty regarding the initiation, continuation, or completion of long-term research programs may influence decisions throughout the broader research ecosystem. Scientific uncertainty is inherent to discovery. Administrative uncertainty is different. Investigators, institutions, publishers, scholarly societies, and technology providers all make long-term investments based upon reasonable expectations regarding the continuity of research activity. When those expectations become less predictable, organizations naturally become more cautious in pursuing ambitious research initiatives, developing collaborative programs, investing in new technologies, creating new jobs, or expanding the infrastructure that supports scientific communication.

Those effects may not be immediately visible in the administration of individual awards, but they emerge over time throughout the research enterprise. Editorial offices observe changes in submission patterns. Publishers adjust investments in new technologies and publication services. Professional societies reconsider educational initiatives, standards development, and scientific meetings. Collectively, these decisions influence how efficiently federally funded research is evaluated, disseminated, preserved, and incorporated into future scientific discovery.

From KGL’s perspective, this broader infrastructure deserves greater consideration within the proposed rule because it is essential to realizing the full return on the nation’s investment in research.

Research integrity in scholarly communication

The proposed rule appropriately emphasizes accountability in the administration of federal financial assistance. KGL strongly supports that objective. We respectfully submit, however, that accountability extends beyond financial stewardship. Taxpayers expect confidence not only that public funds have been spent responsibly, but also that the resulting research is rigorous, transparent, reproducible, and worthy of becoming part of the permanent scientific record.

That confidence depends upon a sophisticated scholarly communications infrastructure that receives comparatively little attention in the proposed rule but has become increasingly important to the success of the nation’s research enterprise. Editorial assessment, independent peer review, publication ethics, accessibility, metadata standards, digital preservation, persistent identifiers, and research integrity programs collectively provide the quality assurance systems through which scientific findings are scrutinized, improved, communicated, preserved, and made available for future discovery. These functions are not ancillary publishing activities. They are essential mechanisms through which federally funded research achieves credibility, permanence, and lasting public value.

Every federally funded article passes through multiple independent evaluations before it becomes part of the scientific record. Editors assess scientific scope, reporting quality, and ethical compliance. Independent peer reviewers evaluate methodology, interpretation, and originality. Publishers ensure adherence to reporting standards, accessibility requirements, metadata quality, and long-term preservation. Increasingly, manuscripts also undergo plagiarism detection, image analysis, authorship verification, and other research integrity assessments before publication. Together, these independent evaluations strengthen confidence in the scientific record and maximize the return on the nation’s investment in research.

The importance of these functions has grown substantially over the past decade. Publishers, scholarly societies, universities, and technology providers have invested heavily in improving editorial quality, expanding accessibility, strengthening publication ethics, enhancing preservation, and developing technologies that improve the efficiency, transparency, and reliability of scientific communication. These investments have become increasingly important as the research community confronts paper mills, manipulated images, fabricated data, fraudulent peer review, identity fraud, and other sophisticated forms of publication misconduct.

Emerging challenges require continued investment

Artificial intelligence has further accelerated both the opportunities and the challenges facing scholarly publishing. AI offers meaningful opportunities to improve scientific productivity and editorial efficiency, while simultaneously creating new risks involving fabricated text, manipulated images, synthetic data, hallucinated references, and increasingly sophisticated attempts to evade traditional editorial review. Responding effectively requires sustained investment in experienced editors, reviewer development, editorial technologies, publication ethics, and research integrity programs. Stable policy environments encourage those investments. Increased uncertainty may discourage them.

The same principle extends beyond editorial quality and research integrity. Professional societies establish reporting standards, publication ethics guidance, reviewer education, and disciplinary best practices. Scientific meetings provide opportunities for researchers to challenge preliminary findings, establish collaborations, recruit reviewers and editors, and strengthen the quality of subsequent publications. Publishers invest continuously in accessibility, preservation, digital platforms, metadata, discoverability, and technologies that improve the dissemination and long-term usability of scientific research. Although these activities receive comparatively little attention within discussions of federal research policy, they are indispensable to ensuring that publicly funded research remains accessible, reliable, and useful for decades after individual grants have concluded.

This broader perspective is equally relevant to implementation of the proposed revisions affecting international collaboration, including 2 C.F.R. § 200.220. KGL recognizes the importance of protecting federally funded research from inappropriate foreign influence and other legitimate national security risks. At the same time, scientific progress increasingly depends upon responsible international collaboration, particularly in disciplines where expertise, specialized facilities, clinical populations, or unique data resources are distributed across multiple countries. Implementation guidance should distinguish carefully between collaborations that present genuine security concerns and the overwhelming majority of legitimate scientific partnerships that strengthen United States research leadership, improve reproducibility, and accelerate discovery.

Taken together, these considerations illustrate a broader principle. Federal research policy influences not only how research is funded, but also the systems through which scientific discoveries are evaluated, communicated, preserved, and ultimately translated into public benefit. KGL respectfully encourages OMB to evaluate the proposed rule according to its effects across the complete research lifecycle, recognizing that responsible stewardship includes preserving the infrastructure through which federally funded research becomes trusted scientific knowledge.

Recommendations

For these reasons, KGL respectfully encourages OMB to implement the proposed rule in a manner that preserves its important objectives of accountability and responsible stewardship while minimizing unintended consequences for the broader research enterprise. Specifically, we encourage OMB to:

1. preserve transparent, merit-based scientific review in implementing the revised pre-award provisions in 2 C.F.R. §§ 200.205 and 200.206;
2. provide greater predictability and appropriate procedural safeguards regarding expanded authority under 2 C.F.R. § 200.340;
3. implement 2 C.F.R. § 200.220 in a manner that protects research security while preserving responsible international scientific collaboration; recognize scholarly communications infrastructure, including editorial assessment, peer review, accessibility, preservation, and research integrity, as an essential component of the federally funded research enterprise; and
4. evaluate the proposed rule according to its effects across the complete research lifecycle rather than solely through the administration of individual awards.

KGL appreciates the opportunity to provide these comments and shares OMB’s commitment to strengthening public confidence in federally funded research. The United States has built one of the world’s most respected research enterprises because it has invested not only in scientific discovery, but also in the institutions and systems that validate, communicate, preserve, and build upon that discovery. We encourage OMB to ensure that the final rule strengthens both. Doing so will maximize the return on the nation’s investment in research while reinforcing the long-term integrity, competitiveness, and public value of the United States research enterprise.

Respectfully submitted,

Atul Goel

President, KnowledgeWorks Global Ltd.