This is not a drill.
Use AI to understand a live federal rule change — and write a public comment that counts.
A real, live federal rule change with a real deadline — your job is to use AI to understand it and write a public comment that an agency would actually have to weigh.
Why it matters
This is not a hypothetical. A 108-page proposed rule is open for comment right now, and it would reshape how every federal grant — including every NIH award — is made and managed. Comment periods are one of the few formal, legally weighted channels scientists have to influence policy that governs their own work, and most scientists never use them. Learning to turn a dense rule into a sharp, defensible comment in under an hour is a genuinely useful professional skill — and a clean test of using AI for high-stakes work where being confidently wrong has real costs.
Run of show
- 0:00–0:05 · Challenge introduction (5 min)
- 0:05–0:20 · Work in your group (15 min)
- 0:20–0:22 · Post your best prompt (2 min)
- 0:22–0:32 · Share & debrief (10 min)
- 0:32–0:35 · Reset (3 min)
The challenge
The U.S. Office of Management and Budget (OMB) has just published a proposed rule that would overhaul the government-wide rules for federal grants — the “Uniform Guidance” (2 CFR Part 200) that governs how NIH and every other federal agency makes and manages awards. The proposal runs 108 pages in the Federal Register (91 Fed. Reg. 32198) and would significantly change the grant-making process both before and after an award is made — changes that could have a profound impact on science in the U.S., and in other countries to the degree they depend on NIH funding.
The proposal is open for public comment until July 13, 2026, and federal agencies are legally required to consider and respond to substantive comments. Your task is to use AI to help you understand the proposed changes and craft a response. Some kinds of comments carry more weight than others. Write a comment that aligns with your values and is built to be impactful — i.e., likely to be treated by OMB as a substantive comment. AI can help here, but you are the ones who must understand what is at stake and form an opinion.
Read the proposal: Regulation for Federal Financial Assistance (91 FR 32198). Comments are submitted at regulations.gov, docket OMB-2026-0034.
Consider breaking the task into components:
- Context — Why are these changes being proposed?
- Content — What are the most important changes?
- Impact — What will the impact be on science, scientists, and other stakeholders? (e.g., study-section functioning, awards, recruitment, trainees, clinical trials, publication compliance, collaborations, indirect-cost administration, or institutional operations)
- Response — What kinds of comments is OMB obligated to consider? What will make a comment likely to be treated as a substantive comment?
- Action plan — How can you submit your comment?
Stuck? Optional hints Click on these only if you need additional hints/info!
① Context hints · ② Content hints · ③ Impact hints · ④ Response hints · ⑤ Action-plan hints
Bad prompt to better prompt
Why it disappoints: you get a generic summary that may invent or misnumber sections, and a vague comment with no docket or section citations, no evidence, and no specific alternative. That is exactly the kind of “I’m for/against this” message an agency can group, count, and set aside as non-substantive.
You are a research-grants policy analyst helping a pain scientist write a substantive public comment on OMB’s proposed rule “Regulation for Federal Financial Assistance” (docket OMB-2026-0034, 91 FR 32198).
Focus on ONE provision: the senior-appointee pre-issuance review of discretionary awards (proposed § 200.205) and its interaction with peer review being advisory.
Do this in clearly labeled sections: 1. PLAIN-ENGLISH SUMMARY of what this provision changes, in 3 sentences. 2. CONCRETE IMPACT on NIH study sections, award timelines, and trainees — be specific. 3. THE AGENCY’S STATED RATIONALE, and whether the provision actually serves it. 4. A SPECIFIC ALTERNATIVE OMB could adopt instead (narrow, define, require written reasons, preserve peer-review primacy, etc.). 5. ANY LEGAL/PROCEDURAL ISSUES (arbitrary-and-capricious, vagueness, statutory conflict).
Then add a section “CHECK ME”: list every section number, date, and factual claim you used, rate your confidence each is correct, and flag anything I must verify against the actual rule before I submit.A strong comment names the docket and section, shows concrete impact with evidence, engages the agency’s rationale, offers a specific alternative, and is verified by a human before it is filed.
Debrief questions
- Which provision did your team comment on, and could you explain in one sentence why it matters — without re-reading the AI’s output?
- What did the AI get wrong, invent, or overstate about the rule? How did you catch it?
- What moved your comment from “a vote” to “substantive”? A section number? Evidence? A concrete alternative?
- Where did your judgment override the AI — on emphasis, tone, or what to leave out?
- Would you actually submit this? What would you change first?
Further challenges
The grant-policy landscape is unusually active right now, and several proposals are open for public comment. One worth a look:
More open comment periods NIH is seeking public input through NOT-OD-26-086, a Request for Information on a proposal to cap the number of simultaneous Research Project Grants (RPGs) per principal investigator (NIH is weighing caps of 2, 3, or 4). Rather than forcing immediate change, NIH proposes a phased approach: investigators above the cap would reduce their lead awards over time via renewals, PI changes, or relinquishment. NIH estimates this could redirect roughly $1.3–3.5 billion to support ~1,900–5,200 additional investigators. Comments are due August 3, 2026.
Read more: NOT-OD-26-086 (the notice) · NIH Extramural Nexus explainer.