By now most of you have heard of the Office of Management and Budget’s proposal to dramatically revamp the federal grantmaking process. While this proposal appears to turn Federal support of research into a mechanism for driving ideologically-driven pseudoscience, it is in fact much broader and more dangerous than that.
It goes well beyond science to encompass nearly $1 trillion in funding from 42 different agencies and $882.8 billion dollars spread across 1,183 funded federal grant programs.
If you have not already done so, I urge you to submit your comments opposing this remake. If you already have, please consider submitting another one. Here is why:
This affects urban and rural communities in both Blue and Red states
In San Diego, California, social and human services programs, housing and community development block grants, public safety funds, highway/road and building projects, sanitation and water projects, after-school programs, and small businesses, in addition to scientific research, are at risk. In Joplin, Missouri, parks, stormwater drainage, and regional airport funding is at risk, as well as homeless services and food banks.
Paperwork load increases
Every reimbursement request will require written explanations. Considering how aggressively Federal agencies are being downsized, payments may well be delayed. Any program that employs contractors or workers will face substantially increased auditing and accounting work to ensure compliance with E-verify and financial use regulations.
Politics Trump Expertise
Placing sole power for approving, shaping, and terminating grants in the hands of OMB and other political appointees will seriously damage scientific and technical innovation. Expert review is considered advisory and optional. International collaborations are prohibited.
Dismantling our scientific research infrastructure, eliminating scientific experts from positions of influence, and requiring “viewpoint neutrality” and politically defined agency priorities puts us squarely on the same path as Soviet biology in the Lysenko era, which ended with massive famines in the Soviet Union and in China.
Threats to Business
Business agility and scientific progress depend on funding stability and predictability. Funding stability is not assured, as political appointees can terminate funding at any time, at will. Federal funds can’t be used to support bilateral or multilateral collaborations, programs or activities (e.g., travel, research activities, technical assistance, and indirect costs of work) with covered foreign countries or covered foreign entities.
However, what constitutes these covered foreign countries/entities is vague and ill-defined, without specific reference to a vetted list. As such, the exact constitution of the list appears to be at the discretion of the aforesaid decisionmakers. While the intersectionality of this proposed rule with Bayh-Dole legislation has not been fully explored, businesses and organizations relying on patents may face increased cost, risk, and burden of patent filings as a consequence of grant uncertainty.
Implementation Planning Rushed and Incomplete
This proposal was published the day before the Memorial Day weekend started (Friday, May 29). Comments are accepted for only 45 days; OMB refused requests to extend the comment period. The proposal is massive (412 pages) and is scheduled to take effect 80 days after comments close.
The poor assessment of how this rule potentially impacts patentability exemplifies the lax approach to implementation of this consequential rule. In contrast, the Federal regulations that govern research and development of new drugs (21CFR 312 and 314), number approximately 150 pages and have been evolving since 1962.
Not only is this proposal being rushed to implementation, not only was it made public in a way seemingly calculated to attract as little attention as possible, to top it all off, OMB may lack sufficient legal authority to implement this proposal.
Putting More Limits on Scientific Research
Separately, NIH recently released a Request for Information (RFI) seeking public input on a proposal to limit (“cap”) the number of simultaneous Research Project Grants held by a principal investigator to a number between 2 and 4. The public comment period for this proposal ends August 3, 2026.
How can we do better?
Dr. Ron Manderscheid, a highly respected behavioral scientist, suggests a minimum set of five measures that should be mandatory:
- Merit-based and objective review processes should remain the foundation of grantmaking.
- Federal agencies should be required to document and publicly justify any departure from established review recommendations.
- Grant termination authority should be limited to clearly defined statutory, fiscal, or performance-related reasons.
- Transparency requirements should apply equally to political decision-makers and grant recipients.
- Congress should strengthen safeguards that preserve the nonpartisan administration of federal financial assistance.
What Can I Do?
A former NIH grants official has articulated the threats and provided concrete, pragmatic steps for opposing this proposal. Please read them for full details.
Ask yourself: if my tax dollars are not going to be used for funds to benefit me or my community, then where are they going to go?
Then file comments here in the Federal Register docket by July 13, 2026. Stand Up for Science and the American Public Health Association portals also offer tools to simplify comment filing. Comments can be made by anyone, including non-citizens and residents of foreign countries, and can be made anonymously.
Comments to the NIH proposal to limit the number of grants held per principal investigator can be filed here.
When you write:
- Be clear (about why you are concerned),
- Be specific about which section of the proposal you are commenting on (see the hyperlinked articles),
- Be personal about how this proposal will affect you, and
- Don’t be afraid. Others (67,437 as of 6/26/26) are standing up with you, and you are the expert on what affects you.
In closing
This is a serious matter that requires us to mobilize. Please file comments expressing your concerns. OMB must review all substantive comments before implementing the rule. The entire record will be archived and can be used in future legal proceedings. Please also contact your local, state, and/or Federal legislators to urge them to oppose this proposed rule.
Ken Kobayashi