Tell the Department of Education How Proposed Grantmaking Changes Could Harm Education Research

The Department of Education released a Notice of Proposed Rulemaking that would make significant changes to the Education Department General Administrative Regulations (EDGAR), which govern how the Department awards and administers grants.

AERA encourages members to review the proposal and submit comments by September 23, 2026.

Several provisions parallel changes proposed by the Office of Management and Budget (OMB) in its government-wide federal grantmaking regulations and by the National Science Foundation (NSF) in proposed updates to its Proposal and Award Policies and Procedures Guide. Both the Department of Education and NSF are proposing to implement elements of OMB’s proposed government-wide rule before OMB has issued a final rule or fully addressed concerns raised during its public comment process.

The Department’s proposal also includes additional changes that could significantly affect federally funded education research.  Among the provisions, the proposed updates to EDGAR would:

• Allow the Department to give a competitive preference to grant applicants that voluntarily agree to recover less than their federally negotiated indirect cost rate—and require them to maintain that reduction for the life of the grant. This could disadvantage institutions that are less able to absorb unrecovered research costs;
• Expressly authorize the Department to terminate discretionary grants “for convenience” and retain broad discretion to end awards based on changing program goals or agency priorities;
• Revise standards governing continuation funding for multiyear awards and establish a new definition for “frontloading” grant awards;
• Add requirements governing merit-based employment and participation decisions; compelled statements of political belief; and institutional protections for freedom of speech, inquiry, research, press, and association under Department grants;
• Require state-administered grantees and subgrantees to comply with applicable Executive Orders; and
• Revise definitions of experimental studies and different levels of evidence, while establishing a new “evidence framework” through which the Department could recognize review approaches beyond those aligned with the What Works Clearinghouse.

AERA is submitting comments and working with partner organizations on coordinated letters and other strategic actions. Input from individual AERA members will strengthen this collective effort by demonstrating how the proposed changes could affect education research and the public it serves. 

AERA encourages members to review the proposal and submit comments describing how specific provisions would affect education research, researchers, institutions, students, and the public. AERA has also developed a summary of the proposed rule and key provisions of relevance to the education research community that can be highlighted in AERA member comments.

Members should also urge the Department of Education to delay finalizing provisions that overlap with OMB’s proposed Regulation on Federal Financial Assistance until the government-wide rulemaking is complete and the concerns raised through its public comment process have been fully considered.

Comments are generally most effective when they draw on relevant expertise, identify the specific sections of the proposed regulations being addressed, and provide concrete examples of likely consequences. Members might consider questions such as:

• How would the proposed changes affect the integrity, independence, or efficiency of federal research funding?
• How might updates on evidence definitions affect the use of certain research methodologies and knowledge development?
• What would expanded grant termination authority mean for ongoing projects and research capacity?

Comments must be submitted through Regulations.gov by September 23, 2026. Commenters should include the docket number ED-2026-OPEPD-2542 at the top of their submission. As stated in the NPRM, comments should “clearly identify the specific section or sections of the regulations that the comment addresses and be in the same order as the regulations.”

Comments become part of the public record, so members should include only personal information they wish to make publicly available.