The AHA July 13 commented on proposals by the Office of Management and Budget and other federal agencies to revise the Uniform Grants Regulation governing federal financial assistance. The proposals would give federal agencies broader discretion to modify federal award conditions, impose additional requirements during the life of a federal award, and suspend or terminate funding based on evolving agency priorities or determinations regarding the national interest, except instances where federal law specifically addresses the use of such funding. The AHA said the changes would create uncertainty for recipients considering long-term investments supported by federal funding and could force grantees to seek clarity in court.

“Hospitals and health systems cannot responsibly recruit principal investigators, launch multiyear clinical studies, expand residency programs, establish rural outreach initiatives or build community-based behavioral health programs if there is significant uncertainty regarding whether funding conditions may materially change after an award has been made,” the AHA wrote. “Increased uncertainty also makes it more difficult for governing boards and institutional leadership to commit matching funds or make complementary capital investments that often maximize the value of federal grants.”

The AHA said that uncertainty on the durability of federal awards could discourage participation in competitive grant programs altogether, and that the financial risks associated with accepting federal grants outweigh the potential benefits if funding can be modified or discontinued based on evolving policy priorities unrelated to recipient performance.

The AHA and four other hospital organizations July 13 also urged OMB in a letter not to impose the changes and to clarify the scope of the rule. “This would fundamentally undermine the reasonable expectation that recipients can rely on awarded grants to remain stable, which is essential to making long-term federal investments workable,” the organizations wrote. 

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