Federal agencies receive many comments during rulemakings. The most useful comments are specific, factual, and tied directly to the proposed regulatory text.
A strong comment letter usually includes the following elements:
- Identify Yourself and Your Interest
Begin by explaining who you are, what organization you represent, and why the proposed rule matters to you.
Example:
I am submitting this comment on behalf of [Organization], which conducts federally funded aerospace research and partners with universities, federal agencies, and industry on technology development and workforce programs.
- State Your Overall Position
Briefly explain whether you support, oppose, or seek clarification or modification of specific provisions.
You do not need to oppose an entire rule to submit a useful comment. Many effective comments support the agency’s goals while recommending changes to avoid unintended consequences.
Example:
We support OMB’s goals of improving accountability and research security but respectfully recommend clarification to ensure that the final rule does not unintentionally discourage participation in federally funded aerospace research.
- Cite Specific Sections
Comments are more powerful when they identify the specific section of the proposed rule being discussed.
Examples for this RFI:
- 2 CFR § 200.205 — merit review
- 2 CFR § 200.206 — risk review
- 2 CFR § 200.220 — foreign collaboration or access-related provisions
- 2 CFR § 200.340 — termination
- 2 CFR § 200.432 — conferences
- 2 CFR § 200.454 — memberships and professional activities
- 2 CFR § 200.461 — publication and printing costs
- Explain the Practical Impact
Agencies benefit from real-world examples. Explain how the proposed change may affect your organization, research program, students, workforce, compliance burden, collaborations, or technology transition activities.
Useful comments often answer:
- What would this provision change in practice?
- Would it increase cost or uncertainty?
- Would it affect research participation?
- Would it affect students, early-career professionals, or smaller institutions?
- Would it affect collaboration with federal agencies, universities, or industry?
- Would it affect publication, conferences, standards work, or technology transfer?
- Provide the Facts
Where possible, include data, examples, experience with federal awards, or concrete scenarios. Avoid speculation or unsupported assertions.
Less effective:
This provision will hurt innovation.
More effective:
If prior approval is required for all award-related conference participation, federally funded graduate students and early-career researchers may face delays or uncertainty in presenting research results at technical meetings, which could reduce dissemination and slow technology transfer.
- Offer a Specific Recommendation
Agencies are more likely to consider comments that propose a workable solution.
Example:
OMB should clarify that reasonable conference, publication, standards-development, and professional activity costs remain allowable when they directly support the objectives of a federal award.
- Keep the Tone Professional
Effective administrative comments are respectful, precise, and constructive. Avoid political rhetoric. Focus on the rule, the legal or practical issue, and the recommended solution.
