Changing the Rules of Federal Research Funding

June 29, 2026

In a previous post we have decried recent Donald Trump Executive Orders that jeopardize American science with political interference. Stable and continuous funding for scientific research — based on evaluations made by peer review of proposals and administered by funding agencies whose program managers have expertise in their fields — has fueled American economic growth, prosperity, and geopolitical dominance for three-quarters of a century. In another post on America’s Transition from Scientific Brain Gain to Brain Drain, we have described how that growth followed from the foresight of Vannevar Bush in his 1945 report Science, the Endless Frontier, which led to the 1950 establishment of the National Science Foundation (NSF).

Russell Vought and his Office of Management and Budget (OMB) are now attempting to add teeth to Trump’s Executive Orders by a sweeping overhaul of the rules of federal grantmaking published on May 29, 2026. The proposed rule change Regulation for Federal Financial Assistance aims to put political appointees in charge of grant funding decisions in order to ensure that funding goes only to proposals that “demonstrably advance the President’s policy priorities.” Peer review would then be purely advisory to the political appointees. Figure 1 illustrates the current process for research proposal review within the National Institutes of Health (NIH). The OMB proposal would add the inset step at the end of that process, in which the Institute Director or NIH Director evaluates the proposal for political alignment. Since we currently have a President and an administration that does not believe in climate change, renewable energy, or differences between sex and gender, which is skeptical of vaccines and other well-established disease research, and which seems intent on using taxpayer funds to validate its own prejudices and obsessions, such a rule change could kill essential research for the duration of the Trump administration. But over a longer term, tying scientific research to the whims of alternating administrations would destroy the concept of stable, continuous research funding that has driven economic growth and technological development in the U.S. since the end of World War II.

All proposed federal regulatory changes require, by law, a period for public comment. We have worked with other members of our group Concerned Scientists @ IU and its affiliate student organization Advocates for Science @ IU to write the comment on the OMB proposal that is reproduced below. The primary author of the comment is Tyler Morris, a graduate student in the IU School of Public Health, but one of us (SV) added quite a bit of specific references based on our voluminous records on this blog site.

The comment points out in some detail the positive effects of stable, continuous research funding evaluated by peer review, the disastrous effects that have happened in the past when political whims interfere with science, and the fundamental problems that would be introduced by the various regulatory changes OMB proposes. If the proposed rule goes through after OMB addresses public comments, there will almost certainly be legal challenges based on the rule’s exceeding OMB’s statutory authority and violating the First Amendment and the Administrative Procedures Act by imposing viewpoint restrictions on federal funding.

Comment on OMB Proposed Rule: Regulation for Federal Financial Assistance (Docket OMB-2026-0034)

Concerned Scientists @ IU

Concerned Scientists @ IU (CSIU) and their student affiliate organization, Advocates for Science @ IU, submit this comment in vehement opposition to key provisions of the Office of Management and Budget’s proposed rule, Regulation for Federal Financial Assistance. CSIU is a grassroots, non-partisan community organization consisting of over 1000 members—scientists, students, and supporters of science—from the south-central Indiana region. While many of our members are faculty, students, or staff at Indiana University, our organization does not officially represent the University. Concerned Scientists @ IU is dedicated to strengthening the essential role of science in public policy and evidence-based decision making.  

We are extremely concerned that the proposed rule would deeply undermine the leadership role that the National Science Foundation and other federal funding agencies have played in supporting fundamental scientific research. It would politicize federal research funding, weaken merit-based peer review, destabilize long-term research, restrict scientific communication, hinder international collaboration, and impose administrative burdens on universities, researchers, students, and scientific institutions across the country. The result of the proposed changes would be a loss of U.S. leadership in science and technology and an impediment to future U.S. economic growth.

Federal research funding is one of the major engines of American scientific, medical, technological, and economic progress. Since the post-World War II era, the United States has benefited enormously from a system in which federal research investments are guided by scientific expertise, peer review, and long-term national needs that extend far beyond any one Presidential administration. That success has grown out of Vannevar Bush’s foresight in his 1945 report, Science, the Endless Frontier.¹In his report,Bush stressed that “Basic research is the pacemaker of technological progress” and that the federal government could best foster it by offering stability and continuity of research funding, with the administration of grants led by citizens with a deep understanding of scientific research and education. That vision has fueled extraordinary economic growth: recent research² by Texas A&M University and the Federal Reserve Bank of Dallas estimates that stable federal non-defense R&D funding has yielded economic returns between 140% and 210% and is responsible for 20-25% of U.S. productivity growth since the end of World War II. The development of GLP-1 drugs is the latest example of the extraordinary return on federally funded basic research investment. The NIH and other agencies funded much of the early basic science on GLP-1s, leading to the award of the 2025 Breakthrough Prize in Life Sciences.³ The drugs that resulted have the potential to transform public health while earning strong profits for pharmaceutical companies. This OMB proposal would severely weaken that foundation of American progress.

We reject the premise that concerns about past politicization in federal grantmaking can be solved by giving political appointees greater authority over grant decisions. The proposed rule frames prior federal awards as having diverted taxpayer funding away from traditional public purposes and toward “favored identity groups and left-wing activists.” That claim is based on a blatantly political 2024 minority report prepared by Senator Ted Cruz for the Senate Committee on Commerce, Science, and Transportation. Cruz claimed without serious evidence to have uncovered 3,483 NSF grants awarded between 2021 and 2024 to “left-wing” or “neo-Marxist” research simply by searching for keywords that often appear in the Broader Impacts sections that have been required by law⁴ for NSF proposals since 2011 and declaring all research on climate change and clean energy to be “left-wing.” Among the allegedly “left-wing” grants identified by Cruz were research to improve the synthesis of new medications, to improve the safety of self-driving vehicles, and to understand why some proteins malfunction on the path to cancer. This framing is especially concerning given that the current administration has repeatedly taken positions at odds with established scientific consensus in areas such as climate science, vaccines, public health, and sex and gender. However, the broader principle extends beyond any one administration: federal research funding should never be made dependent on the political preferences of the party in power, because such a policy would lead to unpredictable, unstable funding that could stunt long-term scientific and technical progress in the U.S. for decades to come.

The history of political interference in research is filled with cautionary tales. Joseph Stalin considered genetics to be “bourgeois science,” and the result under Trofim Lysenko’s leadership was decades of crop failures and millions of Soviet citizens’ deaths from starvation.⁵ Adolf Hitler dismissed “Jewish physics,” and the result was a brain drain that kept Germany from competing effectively in the race to produce an atomic bomb.⁶ Some of the current U.S. administration’s own ideological decisions restricting research have the potential for similarly disastrous outcomes. Health and Human Services Secretary Robert F. Kennedy, Jr. terminated most research on mRNA technology in 2025, despite the potential of that research to save millions of lives via the development of vaccines to respond to new infectious diseases and innovative treatments to respond to previously untreatable forms of cancer.⁷ Energy Secretary Chris Wright terminated hundreds of clean energy research grants, an action that will set the U.S. back by years in addressing the critical need to reduce greenhouse gas emissions from fossil fuel burning. mRNA and clean energy research are not ideological; rather, they address clear long-term needs of the nation.

We are also concerned that the proposal relies on vague, ill-defined, partisan, and polarizing language in declaring “forbidden subjects” that are inappropriate for government-wide grantmaking rules. The current administration’s previous attempts to eliminate support for such overly broad concepts as “diversity, equity, and inclusion” (DEI) and “gender ideology” led the NIH in 2025 to terminate or fail to even evaluate many grants, including research into antiviral drugs and a study of the incidence of prostate cancer among African American men.⁷ These actions were deemed “arbitrary and capricious” violations of the Administrative Procedures Act in U.S. District Court, a characterization left to stand by the U.S. Supreme Court.⁸ Federal grant policy should be written with clear, neutral standards assessing the quality and applicability of federally funded research, not broad political language that gives political appointees wide discretion to decide which research is meeting “the President’s policy priorities.”

The proposed rule would require senior appointee review of discretionary awards, require consideration of whether such awards advance the President’s policy priorities, and clarify that peer review recommendations are advisory rather than binding. This creates a serious risk that grants judged by expert reviewers to be scientifically rigorous, meritorious, and aligned with agency missions could still be delayed, rejected, or, after initial award, abruptly terminated because they do not appear to align with the political priorities of the administration in power. The political appointees assigned to assess these programs may have little or no technical background with which to determine the scientific value of grant proposals. The OMB proposal also raises broader concerns about restrictions on scientific communication, ideological filtering, international collaboration, and administrative burdens that could weaken the federal research enterprise.

We are especially concerned about the following provisions:

1. §§200.202 and 200.205: Political alignment in program design and award review

Section 200.202 would require federal programs to be designed so that their goals and objectives “align with administration policies and priorities.” Section 200.205 would then require senior political appointee review of discretionary awards before they are issued and would require consideration of whether awards “demonstrably advance the President’s policy priorities.”

Together, these provisions would introduce political alignment tests at both the program design stage and the individual award stage. This could discourage agencies from creating funding opportunities in areas that any particular appointee judges to conflict with vaguely defined administration priorities and could allow meritorious proposals to be rejected after expert review. We believe that the National Science Foundation, the National Institutes of Health, the DOE Office of Science, and other science funding agencies should be encouraged to follow their long-standing basis for review of scientific research:  research should be evaluated primarily on scientific merit, technical feasibility, agency mission, legal authority, and long-term public benefit, not on whether it advances the political priorities of the administration in power.

We urge OMB not to adopt §§200.202 and 200.205 as proposed.

2. §200.205(d): Weakening the role of peer review

Section 200.205(d) states that peer review may be used, but that peer review recommendations must remain advisory and must not be treated as binding by senior appointees or their designees. While peer review is not discouraged in the proposal, it is not required either, allowing senior appointees to summarily reject some proposals without even bothering to have them peer-reviewed.

We recognize that the current peer review system is not perfect, but it is one of the key mechanisms for ensuring that the government supports the highest-quality research possible. It also provides central safeguards against arbitrary or politicized funding decisions. Expert reviewers are best positioned to evaluate whether a proposal is rigorous, feasible, ethical, and likely to advance knowledge. The current system still allows program managers the latitude to make final decisions on prioritization, appropriate funding levels, and required modifications to proposed research projects.

We urge OMB to preserve the central role of expert peer review in federal research funding.

3. §200.340: Discretionary termination of active grants

Section 200.340 would allow an active federal award to be terminated, in whole or in part, if the agency determines that the award no longer serves program goals, federal agency priorities, or the national interest at the time of termination.

This provision would create serious instability for multi-year research. Federal grants often support graduate students, postdoctoral fellows, research staff, clinical participants, laboratory infrastructure, state-of-the-art equipment and sample development, field sites, community partnerships, and long-term data collection. They also support national research centers, such as the National Center for Supercomputing Applications, that provide essential support for a wide range of research carried out by many universities and other research institutions. If an active grant can be terminated because a new administration changes priorities, then scientific planning becomes far more precarious.

This could interrupt clinical studies, public health research, environmental monitoring, innovative energy research, disaster preparedness research, and other long-term projects after substantial taxpayer investment has already been made. It would also harm students and early-career researchers whose training and employment depend on stable grant support and who provide the technically skilled workforce for the next generation.

We urge OMB not to adopt the proposed changes to §200.340.

4. §§200.432, 200.454, and 200.461: Restrictions on conference, subscription, and publication costs

The proposed rule would restrict several ordinary costs needed to conduct and communicate research. Section 200.432 would allow conference attendance costs only if participation is expressly approved and included in the award terms. Section 200.454 would make subscriptions to business, professional, academic, and technical periodicals unallowable. Section 200.461 would make publication costs, including page charges, article processing charges, and open-access fees, generally unallowable unless specifically required by statute or approved in advance.

Researchers need access to current literature, opportunities to present findings, and the ability to publish scientific results. Conferences allow researchers and trainees to share findings, receive critique, build collaborations, and enter professional networks. Often, the decisions about when and where to present new scientific results depend on the (largely unpredictable) path of scientific exploration and discovery. Publication and open access are central to transparency, replication, and public benefit, especially when research is funded by taxpayers.

These restrictions would likely hit students, early-career researchers, smaller institutions, and less-resourced labs hardest because they have fewer alternative funds to cover these costs.

We urge OMB not to adopt the proposed restrictions in §§200.432, 200.454, and 200.461.

5. §§200.300 and 200.218: Ideological restrictions on legitimate research

Sections 200.300 and 200.218 raise major concerns for academic freedom, scientific integrity and scientific progress. Section 200.300 includes restrictions tied to “diversity, equity, and inclusion” (DEI), “diversity, equity, inclusion, and accessibility” (DEIA), and “gender ideology.” Section 200.218 would restrict the use of federal awards to promote or support theories of disparate-impact liability.

The ideological restrictions are ill-defined and thus grant political appointees wide latitude to eliminate any grant proposal whose goals they personally disagree with. For example, the restriction on “gender ideology” could be used to rule out research studying environmental effects in the uterus on the development of white matter in fetal brains, because white matter deviations from those typical of a person’s biological sex have been noted in brain scans on transgender individuals.⁹ Is the study of the physical characteristics of transgender women who have gone through male puberty forbidden? Is further study of the correlations¹⁰ between autism spectrum and gender dysphoria diagnoses to be forbidden?

“Diversity, equity, and inclusion” is another overly broad and ambiguous term. The President’s opposition was used by NIH in 2025 to reject a grant to study the prevalence of prostate cancer among African American men. Is any research that acknowledges racial differences forbidden? Is the development of CRISPR gene editing to cure sickle cell anemia¹¹ a forbidden topic because the disease occurs primarily among black people? Are studies of health disparities between black and white Americans off limits? Leaving the interpretation of the term to political appointees guarantees abuse.

The most ambiguous of all – the most “arbitrary and capricious” – ideological restriction appears under §200.205, which bars grants that include “any other initiatives that compromise public safety or promote anti-American values.” That admonition basically gives an administration carte blanche to oppose anything it wants, for example, anything that might be perceived to help its political opponents. Many would judge, for example, that a number of the Trump administration’s own policies – promoting fossil fuels and opposing renewable energy development, rescinding the EPA’s 2009 Endangerment Finding, and changing childhood vaccine schedules — all “compromise public safety.” If, as a result of this OMB proposal, the U.S. enters an era in which alternating Presidential administrations terminate and reject any initiative started under the opposite party’s leadership, the nation and its economy will flounder.

Furthermore, the admonition against studies of “disparate-impact liability” could chill legitimate research and education in fields where population differences, unequal exposure, discrimination, disability, sex and gender, geography, environmental conditions, or social barriers are relevant to the research question. Research on health disparities, rural health and education, maternal mortality, addiction, HIV prevention, crime and public safety, disability, healthcare access, and sex- or gender-related health questions is not ideological by default. It is often necessary for understanding disease burden, improving prevention, and designing effective interventions. Federal grant rules should not pressure researchers to avoid politically contested topics, populations, or terminology.

We urge OMB not to adopt §§200.300 and 200.218 as proposed.

6. §§200.202(e), 200.220, and 200.303: Barriers to international collaboration and research staffing

The proposed rule would create new restrictions and compliance burdens affecting international research. Section 200.202(e) would require a “domestic-first framework” for research and development awards involving international elements. Section 200.220 would restrict the use of federal funds for collaborations with covered foreign countries or covered foreign entities. Section 200.303 would require recipients and subrecipients to use E-Verify for employees and contractors hired in or performing work in the United States under a federal award.

We recognize the importance of research security and the protection of national interests. However, broad or poorly implemented restrictions could interfere with legitimate international collaboration, data sharing, field work, infectious disease surveillance, climate and geophysical research, biomedical research, and access to specialized expertise or study populations. The United States has long benefited from international scientific collaboration and from attracting talented students and researchers from around the world. Furthermore, international collaborations often provide essential financial and personnel support, enabling important scientific research that would otherwise be infeasible. While China is likely to be designated as a “covered country,” U.S.-China research collaborations have a rich multi-decade history, providing important advances in fields as diverse as birth defects, treatments of diabetes, heart disease, and cancer,¹² neutrino physics,¹³ gravitational wave detection¹⁴, and probes of matter in the infant universe¹⁵. Avoidance of Chinese collaboration in all these cases would have made the pursuit of the research far more costly to U.S. taxpayers. Others have been involved in international collaboration on earthquake and volcano hazards, disaster response, and hazard mitigation. U.S. citizens benefit greatly from lessons learned from hazards occurring in other parts of the world.

We urge OMB to ensure that any research-security provisions do not unnecessarily weaken legitimate scientific collaboration or talent recruitment.

7. §§200.204 and 200.206: Transparency, risk review, and potential viewpoint-based exclusion

Section 200.204 concerns notices of funding opportunities (NOFOs), which are essential for fair and transparent grant competitions. Public NOFOs help ensure that eligible applicants can find opportunities, understand the criteria, and compete on equal footing. Any exception to public posting should therefore be narrow, clearly defined, and limited to necessary circumstances such as national security or unusual, time-sensitive research (e.g., post-disaster reconnaissance research).

Section 200.206 raises additional concerns because it would expand applicant risk review to encompass broad, potentially subjective factors, such as certain memberships or affiliations. Some risk review is appropriate, but vague criteria could be applied inconsistently or used to penalize applicants based on politically contested judgments about their research, institutional affiliations, or lawful associations rather than their qualifications or ability to complete the proposed work.

We urge OMB to narrow these provisions and ensure that any exceptions to public notice or applicant risk review are transparent and not used as tools for viewpoint discrimination, political exclusion, or reduced competition.

Broader impact: administrative burden and unequal impact across institutions

The proposed rule would make federal grantmaking more complex and less predictable. More prior approvals, senior appointee review, expanded termination risk, ideological conditions, limits on publication and conference costs, and additional personnel requirements would burden the entire research enterprise. Large research universities would be harmed by these changes, but they may have more capacity to absorb the added bureaucracy. Smaller universities, regional campuses, nonprofits, community-based organizations, early-career investigators, and students often have fewer administrative and financial resources. The result could be a system that harms everyone while disproportionately disadvantaging less-resourced institutions and researchers. That would narrow participation in federally funded research and weaken the national research enterprise.

Relevance to Indiana University and Indiana

Indiana University and institutions across Indiana rely on federal grants to support biomedical science, public health, environmental research, physical science research, education, technology, social science, community partnerships, and student training. Federal funding supports faculty, graduate students, postdoctoral fellows, research staff, laboratories, data infrastructure, and clinical studies. This proposal could affect research areas important to Indiana, including studies of agriculture and agricultural optimization, cancer, infectious disease, vaccine technology, addiction, rural health, maternal and child health, public health generally, and public health disparities specifically, nutrition and metabolic disease, neurodegenerative disorders, environmental monitoring, forestry, extreme weather, geophysical hazards, education, cybersecurity, network and grid protection and optimization.

Requested Action

We urge OMB to withdraw the proposed rule. At minimum, OMB should not finalize the provisions discussed above without substantial revision.

Federal grantmaking should be transparent, accountable, and responsible to the public. But accountability is not served by replacing scientific expertise with political review, making active grants vulnerable to shifting political priorities, restricting scientific communication, or imposing vague ideological conditions on research funding. The proposed rule would weaken the federal research system, damage public trust, and undermine the long-term public benefits that federal grants are meant to serve.

OMB should preserve a federal grantmaking system grounded in scientific merit, expert review, transparency, legal authority, and long-term public benefit.

References:

1. Vannevar Bush, Science, the Endless Frontier (Princeton University Press), https://press.princeton.edu/booksT/hardcover/9780691186627/science-the-endless-frontier
2. A.J. Fieldhouse and K. Mertens, The Returns to Government R&D: Evidence from U.S. Appropriations Shocks, Federal Reserve Bank of Dallas Working Paper 2305 (Nov. 2024), https://www.dallasfed.org/~/media/documents/research/papers/2023/wp2305r2.pdf
3. Harvard Medical School, Harvard Medical School Researcher Wins 2025 Breakthrough Prize for Work on GLP-1, Apr. 5, 2025, https://hms.harvard.edu/news/harvard-medical-school-researcher-wins-2025-breakthrough-prize-work-glp-1 
4. America COMPETES Reauthorization Act of 2010 (42 U.S.C. § 1862p‑14, Broader Impacts Review Criterion), https://www.congress.gov/111/plaws/publ358/PLAW-111publ358.pdf
5. Wikipedia, Trofim Lysenko, https://en.wikipedia.org/wiki/Trofim_Lysenko
6. Laura Fermi, Illustrious Immigrants: The Intellectual Migration from Europe 1930-41 (University of Chicago Press, 1968), https://archive.org/details/illustriousimmig00ferm
7. A. Billingsley, More Than COVID-19: 6 Other Promising mRNA Vaccines in the Pipeline, GoodRx, June 16, 2023, https://www.goodrx.com/health-topic/vaccines/other-mrna-vaccines
8. J. Timmer, Lawsuit Over Trump Rejecting Medical Research Grants is Settled, ArsTechnica, Dec. 30, 2025, https://arstechnica.com/science/2025/12/feds-researchers-settle-suit-over-grants-blocked-by-now-illegal-order/
9. Debra Soh, The End of Gender (Simon & Schuster, 2021), https://www.simonandschuster.com/books/The-End-of-Gender/Debra-Soh/9781982132521
10. N.R. Quinn, What is the Connection Between Autism and Gender Dysphoria?, March 16, 2026, https://www.appliedbehavioranalysisedu.org/what-is-the-connection-between-autism-and-gender-dysphoria/
11. S.H. Park and G. Bao, CRISPR/Cas9 Gene Editing for Curing Sickle Cell Disease, Transfusion and Apheresis Science 60, 103060 (2021), https://www.trasci.com/article/S1473-0502(21)00010-0/abstract
12. D. Seligsohn and S. Kennedy, The U.S.-China Science and Technology Cooperation Agreement is Not Yet Obsolete, Center for Strategic and International Studies, June 9, 2025, https://www.csis.org/analysis/us-china-science-and-technology-cooperation-agreement-not-yet-obsolete
13. Wikipedia, Daya Bay Reactor Neutrino Experiment, https://en.wikipedia.org/wiki/Daya_Bay_Reactor_Neutrino_Experiment
14. LIGO Scientific Collaboration, https://ligo.org/
15. The STAR Experiment, https://www.star.bnl.gov/