Research Updates Summer 2026

July 13, 2026

 

The Honorable Russell Vought

Director

Office of Management and Budget

725 17^th Street NW

Washington, DC 20503

 

Dear Director Vought

Montana State University appreciates the opportunity to provide comment on the Office of Management and Budget’s (OMB) proposed changes to the Uniform Guidance (2 C.F.R. Part 200) for Award Recipient Organizations. Montana State University shares the Administration’s commitment to maximizing the return on taxpayer investments, streamlining processes to eliminate waste, and ensuring transparent fiscal responsibility. Montana State University writes — with great concern and a vested interest — to highlight critical, unintended consequences that these regulatory changes will introduce.  Lean, public, land-grant institutions will be disproportionately penalized. 

For background, Montana State University is the original land-grant Institution for the state of Montana. Chartered under the Morrill Act of 1862, Montana State University has a uniquely public purpose and a tripartite mission: to educate students, conduct innovative research, and transfer knowledge developed through research and education to our communities through extension. Montana State University provides educational opportunities to more than 17,000 students enrolled in our academic programs, conducted more than $288 million in research activities in Fiscal Year 2025, and delivers extension services in all 56 counties in this rural state. Montana plays a vital role in Montana’s prosperity and future.

Research at Montana State University relies on partnership with and support from the federal government. Unlike private institutions with multi-billion-dollar endowments that can weather periods of uncertainty, MSU operates a highly efficient research enterprise in which more than 90% of research funding comes from federal agencies and must be used for the specific projects for which it is awarded. Federal support funds research ranging from wildland fires and firefighting technologies to quantum materials discovery and testing to monitoring and controlling the spread of diseases like brucellosis. There are no available funds to bridge a gap or a reduction in federal support that would allow MSU to continue responding to the unique challenges and needs of Montana.  Montanans cannot innovate to create new opportunities in the state with inconsistent federal partnership.

Montana State University has a unique perspective on how individual provisions of the new rules will impact our students, researchers, and communities across our state. This comment letter will seek to address each portion of the proposed rule that impacts Montana State University and our efforts.

Notice of Funding Opportunities § 200.204

 

The proposed changes in this section will allow agencies to abbreviate the time that funding opportunities are available to as little as 30 days. Agencies that misuse this flexibility will create a barrier to entry for smaller institutions, such as Montana State University. We do not have large grant writing teams to rapidly respond to requests for proposals and for land-grant institutions, which commonly develop proposals with non-academic stakeholders.  That is, we often partner with farmers and ranchers, rural school districts, industry partners, and rural and tribal colleges.

The proposed change also curtails the ability for researchers to assemble high-quality, cross-disciplinary teams to tackle the complex issues facing American society. Researchers and faculty have additional responsibilities, including teaching and service to the University community, and they must weigh current obligations against the time and effort needed to pursue new opportunities. When faced with tight deadlines for new opportunities, researchers will often choose instead to focus on performing high-quality work on their existing projects and on developing excellent Montana-based scientists and researchers in the classroom. Short timelines will lead to fewer grant submissions and fewer awards for Montana-based researchers. Fewer awards will lead to fewer answers to the unique challenges facing Montana families, businesses, and the agricultural community.

Additionally, Montana State University has a leaner operation than most R-1 research institutions. A recent space study conducted by the Smith Group for the University of Idaho discovered that MSU had the highest research expenditures per square foot of the R-1 institutions in the study—nearly double the average expenditures of the other institutions. This helps keep Montana State University’s overhead rates (indirect cost) among the lowest of R-1 Institutions.  Our effective indirect cost rate is 17%, competitive with the most efficient non-profits and private business. Low overhead rates allow more money to go directly toward scientific discovery and innovation. Montana State University is very serious about its commitment to steward taxpayer resources.

Further, the proposed change to timelines would reduce engagement with external industry. On complex projects, it takes significant time to align stakeholders, reach agreement on contract mechanisms, and establish appropriate safeguards for receiving and spending federal monies. External stakeholders who do not routinely work with the federal government require a higher level of effort in partnerships. Stakeholders with less capacity, such as the 114 Montana school communities we have partnered with to place teachers into rural schools, become unrealistic partners.

 

Finally, the proposed rule on Notice of Funding Opportunity would allow for the Administration to select grant recipients without a competitive process. This would harm institutions like Montana State University that are not proximate to a national lab or any of our nation’s major science agencies. Montana State researchers rely on the opportunity provided by competitive proposals to make a convincing case. A system that allows the government to pick winners and losers without a full review will erode the scientific enterprise and lead to the United States ceding our scientific advantage to China and Europe.

Pre-Issuance Review § 200.205

The proposed pre-issuance review regulation is a drastic change to grant issuance that will have significant impact on Montana State University. First, pre-issuance review causes unnecessary delays in the distribution of awards. Such delays lead to the University having to expend funds to keep researchers employed and positioned to conduct the work when a grant is finally issued. Money spent to bridge these gaps is money that is not being used to improve student outcomes, plan for future University needs, or serve our communities, including Montana’s farmers and ranchers through MSU’s agricultural research stations.

When grants do not arrive in a timely fashion, 1,400 Montana families start to wonder where their next paycheck is coming from. They start to wonder if they can pay their mortgages or fix their cars. They start to wonder if Montana is a good place to raise their family. As emphasized above, Montana State University does not have unused funds sitting in an endowment or an account waiting to be spent to bridge reimbursement delays and shore up this uncertainty.

Pre-issuance requirements subject research of immediate importance to unnecessary political interference in the scientific process. For example, Montana State University hosts the Western Sustainable Agriculture Research and Education (SARE) program, which serves farmers and ranchers in Alaska, Arizona, California, Colorado, Hawaii, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming. As the host institution for Western SARE, Montana State University awards grants for research and education on sustainable agriculture issues. Western SARE’s administrative council and its grant reviewers are tasked with selecting high impact, innovative, sustainable agriculture projects for funding through a competitive process. These projects must center on innovative producers, supporting the “Farmer-First” mantra. So, in this example, if political appointees are making grant funding decisions, it would negate the locally focused Western SARE process that serves to identify regionally impactful sustainable agriculture research and education projects that have positive economic impacts for a large contingent of American producers. Adding political appointees to the process only thickens the red tape and bureaucracy involved.

Examples abound for how delays and pre-issuance review impact the work of Montana State University. One research grant has been delayed for more than 470 days. This grant, from the Federal Aviation Administration, is aimed at research to support commercial pilot safety and their interactions with unmanned aerial vehicles. The Administration has delayed this essential safety research for well over a year due to the pre-issuance reviews the Administration has undertaken with no formal authority to do so. Certainly, it is not the intention of the administration to endanger American pilots in the air, but nevertheless, this is a result of the pre-issuance review inaction.

Further, such delays cause Montana State University to delay admission for potential graduate students in areas of national interest, such as quantum sciences, cybersecurity, biotechnology, and critical minerals research. In fact, Montana State University has seen a marked decline in graduate student enrollment since our 10-year peak in 2021.  Uncertainty in funding is already  accelerating this trend and could impact the University in important ways such as loss of R-1 research designation.

In an uncertain environment, students will choose other universities, such as the University of California, Berkeley, that have the resources to bridge a funding gap or — an even worse outcome — these talented individuals may opt out of pursuing advanced degrees in these critical fields due to delays in their funding. This harms the development of the science and innovation workforce in Montana and also across the United States, which is in direct contradiction to the Administration’s goals.

Additionally, subjecting science to the pace of government and the changing whims of administrations is irresponsible. This regulatory change would ask scientists to try to anticipate the direction of the political winds. Montana State University prefers that researchers focus on their areas of expertise, conduct sound science, and stand proudly by those findings. Researchers ought to be able to speak truth to power, even when the truth is uncomfortable and, perhaps more importantly, when the research upends decades or centuries of incorrect thinking.

With the pace of change in science, it would be impossible to expect political appointees to stay abreast of developments across their entire spectrum of responsibilities. Gold Standard Science — which the President calls for in Executive Order 14303 — requires the input and evaluation from other scientists, not from individuals who lack understanding of the scientific methodologies or experience in a scientific field.

 

Administrations change, political perspectives change, public opinions change. Science does not fit neatly into election schedules or terms of office. Cancelling grants as administrations turn over wastes taxpayer resources and results in an incomplete knowledge record. We experienced this when programs were cancelled in January 2025.

Subawards and Subrecipient Monitoring § 200.332

The Administration’s proposed regulations on subaward monitoring are severely detrimental and will exclude small or novel entities from the subaward-making process. As a land-grant Institution, Montana State seeks to involve Montanans and those outside the University system in research. MSU partners with subawardees on 19% of our grants —almost one in every five grants. Many subawardees do not regularly receive federal grant money and are not as experienced with the various rules and regulations involved. MSU already scores all these subawardees to assess their risk to the University and will work with them to ensure the appropriate processes and regulations are followed.

The rule makes clear that pass-throughs must ensure the subawardee does not “significantly damage the reputation” of the pass-through entity; however, it does not define what the Administration considers damaging and how each case would be viewed. In the interest of reducing risk, Montana State University would be forced to spend substantially more taxpayer dollars to enhance scrutiny of funds passing through to rural communities, school districts, or industry to avoid enforcement action by the federal government.

This proposal would have a contradictory effect compared to other portions of the rule that call for broader awarding of federal grants. Montana State University would be actively disincentivized under this rule to bring a novel perspective to create solutions.

For example, the above-mentioned Western SARE has a significant subaward portfolio granting program that initiates subawards throughout the western United States. Increased complexity of subaward contracts would significantly increase award management challenges and would complicate funding for Western SARE projects that include farmers and ranchers. 

A signature program of Western SARE is the Farmer Rancher Research and Education Program, which provides direct funding to producers based on their detailed and approved project budgets. The purpose of this direct funding approach is to put funds in the hands of the producers who know best how to manage their project. The proposed rule would increase paperwork for producers and make award management significantly more complicated. 

 

Under the proposed rule, Montana State University will invariably reduce subawards to entities across the state including those who participate in programs such as Western SARE to ensure compliance with a more complex process. 

Foreign Collaborations § 200.220

The Administration proposes further restrictions on foreign collaborations in this section of the Uniform Guidance changes. Montana State University argues that existing regulatory frameworks, including but not limited to National Security Presidential Memorandum 33 and recent bipartisan legislation, already address the key concerns of the Administration by better tracking and mitigating interactions with foreign countries and entities.

Universities have faced increased scrutiny in their foreign collaboration efforts. Montana State University, along with many of our peers, has taken the appropriate steps to ensure research with national security implications is protected.

As a part of our compliance with NSPM-33, Montana State University researchers must certify that they have completed research security training that expressly covers misappropriation risks associated with international collaborations. Under current regulations, researchers must further certify they are not a party to a malign foreign talent recruitment program. Vigilantly fulfilling our obligations, Montana State University routinely and pre-emptively screens all foreign vendors and all foreign parties to research collaboration agreements against federal restricted party lists, including but not limited to the Section 1286 List, to ensure compliance with the prohibition provided within FY25 NDAA Section 238(a) as extended by the FY26 NDAA.

Lastly, Montana State University has invested substantial resources to ensure appropriate protection of Controlled Unclassified Information (CUI) pursuant to the Cybersecurity Maturity Model Certification program and the anticipated CUI Federal Acquisition Regulation (FAR) clauses proposed under FAR Case 2026-001 published in the Federal Register on June 23, 2026. The latter proposed rule will empower all federal agencies sponsoring academic research to define, on a project-by-project and task-by-task basis, research data and outcomes that require additional procedural and technical protections against misappropriation by foreign adversaries.

With appropriate protections, such as those mentioned above, foreign collaborations often yield a net benefit to American researchers. Montana State University’s space research teams, for example, routinely partner with international researchers. In one case, the researcher uses instrumentation exclusively developed in the United Kingdom. Other projects are run out of the European Space Agency (ESA) but partner with U.S. researchers and utilize U.S.-based instruments. Without these partnerships, it is impossible to work with data from these missions in a meaningful way and draw conclusions to improve the instrumentation needed for long-distance space travel.

Beyond the inability to collaborate, Montana State University researchers have already seen an impact of hostility toward foreign nationals. Recently, an MSU researcher approached an international snow science group to host an upcoming conference in Bozeman, Montana, the home of MSU.  This would have been a significant economic benefit to the community. Organizers flatly denied the request, noting the U.S. appeared unwelcoming to non-American visitors and noting the difficulty in securing necessary documents such as visas. It is truly a missed opportunity to elevate Bozeman and the rest of Montana as a leader in snow science, and a loss to the local hospitality economy in the region.

Publications § 200.461 and Conference Fees §200.432

American domination in science, technology, and innovation has relied on institutions such as Montana State University to develop a steady pipeline of talent to work in those fields. To gain the expertise and knowledge to be effective, students and early-career faculty need exposure to the current scientific questions in their field. They need opportunities to engage with experts from institutions across the country, if not the world. Additionally, the more specialized the field, the fewer the experts, and those specialized fields have the highest potential to produce significant discoveries that could eradicate disease, secure American infrastructure, or vastly improve daily life. Cutting American scientists off from the conversations in their field will severely disadvantage researchers and ultimately the industries that rely on their output.

Another negative outcome of this proposed regulation is that knowledge paid for by American taxpayers would be less accessible. The rule would make it more difficult for citizens to see what their tax dollars have supported because scientific findings would no longer be broadly shared with the public. Instead, access to those findings would be controlled by the government and provided only at its discretion, rather than being openly available to the people who funded the work.

To share research with communities around Montana, Montana State University extensions agents require publications have an open access license. Publishing papers as open access can cost up to $10,000 per article. Montanan State has limited funds, about $75,000, to assist researchers in publishing research. Therefore, without the use of grant funds to cover publication costs, MSU would only publish 8-10 of the nearly 1,200 articles our researchers wrote in 2025 alone. Limiting publication costs erodes the ability for researchers to develop meaningful careers in their fields and for the public to benefit from federally funded science.

 

Expanded Discretionary Termination § 200.340

To see how an expansion of discretionary termination of federal grants would affect research institutions of higher education, Montana State University does not need to look back any further than January 2025, when the Administration issued memo M-25-13 from the Office of Management and Budget. The memo paused all grant funding to review which grants were aligned with priorities of the Administration, prompting University concern for the 1,400 employees paid from grant funds.

The January 2025 situation provided an example of how a prolonged — or constant — uncertain funding environment ultimately leads to the University employing fewer Montanans and fewer professionals with advanced training in specific fields such as quantum sciences, plant pathology, or nursing. Facing uncertainty or a lack of employment opportunities, those with specialized skills are likely to leave Montana, harming MSU’s research and academic output and, more importantly, shrinking the state’s economy.

The uncertain funding environment will lead to under-investment in core facilities at Montana State University. Core facilities support research in the national interest such as in the fields of critical minerals, national security, and domestic pharmaceutical development. Under-investment would have severe consequences for the Montana State researchers, students, and local industry relying on these facilities.

Allowing discretionary termination on the premise that terminations are in the national interest opens all grant making to the shifting sands of politics. Currently, Montana State University has 89 grants that extend beyond the end of the current Administration into 2029. Under the proposed rule, nothing will stop a future administration from cancelling those grants, or others awarded during the current Administration, based on what is deemed at the time to be in the national interest.

Further, the current Administration will seek to issue new grants in the final years of the President’s second term. Montana State University may choose to not pursue grants in areas of interest to the current Administration for fear that a future administration could cancel them on a whim with no appeal process. Thus, the cancellations would diminish the impact of the President’s second term.

Finally, at Montana State University, there is deep reverence for the founding documents of our nation and a strong respect for the federal delegation elected by the people of our state. Montanans rely on our representatives to advocate for us through the legislative process to ensure our voices are heeded and included in legislation impacting our lives. An expansion of discretionary termination stifles the voice of Montanans by allowing an executive authority to determine what is in our interest rather than the representatives elected by the people of Montana. Those representatives retain broad authority over the appropriating of funds under Article I of the U.S. Constitution. Montana State University strongly prefers that authority remains with the legislative branch, not the executive.

Payment Justification § 200.305

The proposed regulation change regarding payment justification is overly burdensome and hampers the ability of Montana State University to conduct scientific research. The University submits an annual report to our funders, such as the National Science Foundation, and undergoes a robust audit each year to ensure financial compliance and transparency. The federal government already has pages of regulations and best practice rules for spending federal grant dollars. The new regulations will duplicate current rules and sow confusion.

The proposal would also lead to even longer delays in repayment for expenses already incurred by Montana State University. The current system is already unfeasible. In the last year, MSU has routinely carried negative balances of $20 million to as much as $50 million in delayed repayments. Running such high negative balances is unsustainable. If delays are increased by regulations such as this, Montana State’s expansive research enterprise would necessarily shrink.

Montana State University understands the unique responsibility it has as a recipient of federal funding. While this regulation is an overreach, Montana State University is sympathetic to its intent. As such, the University would welcome an opportunity on an annual or semi-annual basis to provide more detailed documentation of research spending. Should this regulation move forward, more money would funnel to compliance, raising the facilities and administration rate the University must recover, and reducing the dollars to fund scientific research.

Conclusion

Montana State University has serious concerns about the proposed changes to the Uniform Guidance that has governed recipients of federal financial assistance for decades. The University has benefitted from federal investment in both facilities and faculty. The investment has allowed Montanans to play a central role in this country’s research enterprise. In the last ten years, Montana State University has grown from $107 million in research expenditures to $288 million with a net decrease in our effective indirect cost rate. That means that we are receiving more money from the federal government and putting more of it to work in labs and fields across campus. The impact of that money is felt in all 56 counties of the Treasure State. 

 

Montana State University is one of the nation’s emerging success stories in higher education, with rising enrollments and a growing research enterprise rooted in Montana values. These regulations would jeopardize that progress and weaken the economic, educational, and societal benefits MSU provides to Montana.

Montana State University urges the Administration to collaborate closely with the higher education community and Congress to ensure these changes have the desired outcome of increasing the effectiveness of every federal dollar while ensuring greater transparency and accountability.

Sincerely,

Alison Harmon, PhD

Vice President for Research and Economic Development

State of MSU Research 

Compared to last year at this time, our expenditures are up 19%!  Congratulations to you all for keeping research strong during a year of uncertainty. 

We realize that there have been some centers and departments that have instead seen decreases in expenditures and funding opportunities and the RED team is here to support sustaining your good work in a variety of ways.  Please reach out if you need help.  Collection of indirect costs has not kept up with expenditures, so we are still being very careful with budget allocations.  However, we are confident enough to re-start some of the programs faculty have come to appreciate. 

• As of January 1, 2026, we have re-started the Institutional Research & Development (IRD) Program: Procedures for RED Institutional Research and Development (IRD) Fund/Index Management - Office of Sponsored Programs | Montana State University 
• We are offering an opportunity to apply for Scholarship and Creativity Grants (S&Cs) this semester: Scholarship & Creativity Grants Program - Office of Research & Economic Development | Montana State University
• We are providing support in a variety of ways for faculty who started in the AY2025-26 without start-up resources from the VPRED office. This support will assist with purchasing key equipment and hiring graduate student researchers to ensure they have the resources to accelerate their research programs. Please contact Carl Yeoman if you have questions carl.yeoman@montana.edu 

Introducing the MSU Certified Green Labs Initiative

Montana State University is excited to launch the Certified Green Lab Initiative, a program designed to recognize and support laboratories committed to sustainable practices across campus.

Participating is simple: complete the MSU Green Laboratories Checklist, available on the Research Integrity and Compliance, Sustainability webpage. This comprehensive checklist will help your lab identify opportunities to reduce environmental impact while maintaining excellent research standards. Once the survey has been completed, we will arrange a short Green Labs audit of your lab and assign you a score.

Labs can achieve graded levels of Certified Green Lab:

• Green: Awarded to labs that achieve 100% lab assessment scores
• Gold: Awarded to labs that achieve ≥95% lab assessment scores
• Silver: Awarded to labs that achieve ≥90% lab assessment scores

Join us in building a more sustainable research community at MSU. Whether you're just beginning your sustainability journey or already implementing green practices, the Certified Green Lab program provides a framework to track your progress and earn recognition for your efforts. Ready to get started? Visit the Research Integrity and Compliance Sustainability webpage to access the checklist and begin your lab's certification process today.

For questions about the program, please contact Mark DeWald mark.dewald@montana.edu or Mary Gauvin mary.gauvin@montana.edu.

Let's work together to make MSU laboratories leaders in environmental stewardship!

Research Security Training 

Certain federal sponsors are now requiring Research Security Training be completed prior to submission of proposals.  Please see our MSU Research Security Training webpage for more information and instructions how to complete the required training:  Research Security at MSU - Office of Research & Economic Development | Montana State University

Questions or concerns regarding Research Security Training may be directed to Quinton King (quinton.king@montana.edu) or John Harrison (john.harrison1@montana.edu) 

New Requirements for Institutional Support

Effective immediately, Research and Economic Development (RED) will require MSU principal investigators (PIs) to work with the Office of Research Development (ORD) during application development in the following cases:

• When planning to submit requests for RED cost-share or other institutional support for external funding proposals;
• When leading major institutional-level proposals, such as for large research centers or research trainee programs;
• When approved to move forward for a competitive limited submission funding opportunity following an internal competition.

Partnership with ORD is intended to ensure RED supports the most competitive and institutionally advantageous proposals possible while facilitating communication and coordination of commitments. Partnering with ORD outside of these scenarios remains at the discretion of the PI. 

PIs approved for limited submission opportunities will receive guidance from ORD at time of decision. Limited submission approval will remain conditional on the basis of sufficient ORD involvement. Outside of limited submissions, PIs can request proposal development support from ORD directly from their  website. Support should be requested as soon as possible, but no later than 6 weeks out from the sponsor’s deadline.

Any requests for RED institutional support made without ORD’s involvement in the application will be returned. Moreover, requests made outside of RED’s official request channels will also be returned and redirected to InfoReady (request RED cost-share here and other institutional support here). PIs are reminded to discuss potential requests of RED with their respective Deans and/or Associate Deans of Research prior to initiating these processes.

NIH Common Forms 

NIH now requires the use of new Common Forms for Biosketches and Other Support for due dates on or after January 25, 2026. You will need to submit a biosketch form, generated and certified in SciENcv. Please carefully review the steps below to comply with the transition. You can view the full notice here: NOT-OD-26-018.  

• Set up ORCID iD: This is required for all senior/key personnel. Check the ORCID registry or create your ID: https://orcid.org/  

• If you complete your ORCID profile, you will be able to use the data to populate your SciENcv forms. 
• Link accounts: 

1. Link your ORCID iD to your eRA Commons Personal Profile. 
2. Associate both your ORCID iD and eRA Commons account with SciENcv. 

• Add a Delegate (Strongly Recommended): Assign a delegate in My NCBI (e.g., admin or other staff) who can edit your biosketch and bibliography if needed.

Support. The Office of Research Development hosted an NIH Common Forms workshop January 9. Contact ORD for workshop slides or for one-on-one assistance. 

An MSU librarian is also available to assist you with ORCID: https://guides.lib.montana.edu/orcid