OMB-2026-0034-43152 – HealthHIV Comments

July 7, 2026 

Submitted via Regulations.gov

Re: RIN OMB-2026-0034-0001 – Regulation for Federal Financial Assistance

To Whom It May Concern: 

On behalf of HealthHIV, we appreciate the opportunity to provide comments on Docket ID OMB-2026-0034-0001 – Regulation for Federal Financial Assistance.

As background, HealthHIV is a national nonprofit that advances effective HIV, viral hepatitis, sexually transmitted infection (STI), mpox and LGBTQ health care through education and training, technical assistance and capacity building, advocacy, communications and health services research and evaluation. HealthHIV supports health care organizations, providers, public programs and community partners working to maintain uninterrupted access to treatment, prevention and related care across chronic, infectious disease and public health needs.

That day-to-day work is why HealthHIV is speaking up in strong opposition to the proposed rule, including changes addressed under 2 CFR §§ 200.205, 200.300 and 200.340. 

For nearly 20 years, HealthHIV has worked in and with federally funded programs that deliver public health services. When OMB changes the rules for how awards are reviewed, conditioned, spoken about or ended, we are commenting from the service side of the grant, putting health first. And while the HIV response is where HealthHIV brings deep experience, our concerns are broader. Across public health, federal financial assistance has to be predictable enough for programs to plan services, hire staff, use evidence and communicate plainly with the people they serve.

As Executive Director of HealthHIV, I also bring our experience with the public health workforce, capacity building, policy and community-based care to this comment, including what it takes to make access easier for people and communities most likely to be left out when systems become harder to navigate. From that experience, I have learned and witnessed the importance of federal financial assistance. It has been—and still is—a central operating principle for the services, staff, data systems, research, partnerships and care coordination that public health programs rely on every day; and when that principle becomes unstable, the people and communities I have spent decades working with feel it across prevention, care and treatment.

Under § 200.205, OMB would unnecessarily place senior political appointees into the award process before discretionary awards are issued. It would also erode peer review by treating it as advice that can be set aside, even when the award depends on scientific or public health expertise.

The HIV response has for forty-five years relied and depended on funding decisions that respect scientific judgment and the realities of People living with HIV. That approach—that discipline—together with community engagement, participatory research and public health expertise, has helped keep federal investments tied to real needs; or, to borrow from research language, to the Specific Aims of the work.

As read, OMB’s proposal could make grants less stable because an award could be judged against changing agency priorities after the organization has already built staffing, community services and planning around that funding. For HIV and public health programs, that kind of uncertainty makes it harder to hire people, keep services running and maintain trust with patients and consumers of health care.

The same concern appears in the proposed changes to § 200.300. Public health programs need to be able to name the barriers their patients and consumers of health care face, whether that is housing instability, discrimination, behavioral health, immigration concerns, geography, coverage rules, sexual orientation, gender, identity, or other health-impacting conditions that shape whether a person can get into care or stay there. That naming is part of how effective programs are designed and how trust is built with the people they serve.

If the proposed rule makes programs second-guess the language they use with patients, staff and community partners, the cost shows up before anyone measures a health outcome. And staff may soften what should be clear. Data may miss what people are actually facing. People who already have reason to hesitate may not come back. Across HealthHIV’s work, that shows up in whether people are reached, understood, and kept connected to care.

No matter the proxy cultural war or turf fight, the (monetary and human) cost to the system, whether federal, state or local, is very real; and the work becomes that much harder to hold together.

The proposed changes to § 200.340 carry that same concern forward. By these new standards, OMB would allow an award to be ended—in whole or in part—when an agency determines, at that later point, that the award no longer effectuates their program goals, agency priorities or their view of the national interest. That gives too much later-stage discretion over services that may already be funded, staffed and underway.

Public health programs need enough certainty to plan once an award is made. HIV programs are built through continuity. Patients build relationships with care teams over time. Community partners build referral networks. Workforce training takes time. Implementation work takes more of that time. Research follows its own timeline and can also be broken midstream when an award is ended or narrowed after the work begins.

To the rule’s benefit, OMB’s goals around transparency and accountability are important, and we agree on their importance. Our primary concern is that this proposal would make grants more vulnerable to political review at multiple points in the grant process and winnow community-facing language, with termination standards that programs cannot reasonably plan around. Across the public health work HealthHIV supports, including the HIV response, federal funding has to remain anchored in scientific peer review, clear enough for programs to speak plainly with the communities they serve, and stable enough to keep services working after an award is made.

As partners and communicators together in this work, we urge OMB to preserve a federal funding framework that public health programs can plan around, staff against and use to serve people with honesty and continuity.

Thank You for the opportunity to comment.

As additional context regarding those aging with HIV:

1. Aging with HIV is now a core federal HIV-care reality. More than 1/2 of People with diagnosed HIV > 50 or older, and nearly 1/2 of Ryan White clients were > 50 as of 2024. Grants have to be able to respond to the population actually being served.

2. Older People with HIV require more complex, coordinated, care. Federal HIV guidelines recognize explicitly the higher burdens of cardiovascular disease, multi-morbidity, polypharmacy, cognitive issues, mental health needs, and other aging-related conditions—and specifically calls for coordination across HIV specialists, primary care, and other providers. A grant review that narrows what programs can describe or address can interfere with that clinical reality.

Point of Distinction: Federally, the NHAS (National HIV/AIDS Strategy) has not disappeared. The CDC was still describing the National HIV/AIDS Strategy in the present tense on 05.07.26—are are still tracking its indicators, and are still saying that it establishes the national goal of reducing HIV infections 90% by 2030. The CDC also continues to use NHAS as a monitoring framework. Aging therefore is part of those strategic clinical and QoL implementation science efforts.

3. Political alignment review should preserve program expertise and continuity. The EO (14332) and OMB rule codification process gives senior appointees independent review authority, so the practical ask for Older Persons and People Aging with HIV is: When an HIV or aging proposal is questioned, bring the division/program experts into that conversation before funding is changed, delayed, or rejected.

The people who understand Ryan White, Title XIX TCM, and HIV Treatment and Aging should be able to explain why an activity, population, or piece of language is clinically and programmatically necessary. The EO, and OMB rule itself, contemplates discussion between review panels/program offices and the senior appointee or designee.

1. Publish the alignment criteria. Recipients shouldn’t have to guess what a political reviewer considers inconsistent with HHS priorities.

2.  Keep subject-matter expertise in the room.

3.  Build a cure process. If language or a particular activity triggers concern, give the applicant an opportunity to explain or modify it before the application is killed.

4.  Require written programmatic rationale for overrides. Ensure written records connecting the decision to the authorizing statute and published NOFO objectives.

5.  Protect continuity of care. Existing TASP, HIV prevention, treatment, workforce, and linkage programs shouldn’t suddenly lose funding because terminology or priorities change.

6.  Separate language from activity. We need to name ourselves (“the Other in us all”)  in our research and out implementation science reports. On the auspices, or face-value alone, that naming or semantic appearance shouldn’t itself establish that an activity is impermissible.

7.  Track what the alignment review is doing. How many applications are flagged, changed, delayed or rejected after merit review? By which program? On what grounds?

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