Opposition to Proposed Rule OMGB-2026-0034-0001, CHLP (2026)

On July 13, 2026, CHLP submitted a comment demanding a full withdrawal of the proposed rule OMB-2026-0034-0001 “Regulation for Federal Financial Assistance,” which would catastrophically overhaul the federal process of issuing and administering grants and cooperative agreements.

The comment underscores that the shifts would radically redefine the award determination process by labeling specific categories, such as services for migrants and transgender people, as prohibited and prioritizing awards consistent with the “President's policy priorities.” It also objects to the awardee “risk assessment” evaluating association with or membership in organizations “engaged in activities that violate Federal law, undermine public safety or national security, or advocate for the overthrow of the United States Government.” CHLP warns that these shifts would discourage investments in Black, brown, and LGBTQ+ communities, particularly threatening the health of people living with and deeply impacted by HIV.

CHLP further notes that the “pre-issuance review” would consolidate power in the hands of political appointees advancing the administration’s white, Christian nationalist priorities, instead of deferring to peers who are qualified to evaluate scientific merit. Additional provisions would impede awardees in conducting research, sharing their findings within their field, and advocating for the implementation of effective solutions.

The comment further calls out the proposed changes as the latest attempt to deprive Black, brown, and LGBTQ+ communities of effective solutions and resources to address systemic issues, such as the HIV epidemic. These modifications would additionally expose more people living with and deeply impacted by HIV to HIV criminalization and would inhibit research and implementation of evidence-based alternatives to carceral tactics, such as HIV criminalization.