Regulation for Federal Financial Assistance
On May 29, the Office of Management and Budget (OMB) released a proposed rule that revises the "Uniform Guidance," which serves as the primary regulatory framework for federal awards distributed to research universities, nonprofits, and other recipients. The policy would fundamentally alter how federal grants and cooperative agreements are awarded, managed, and terminated across the federal government.
The rule represents a sweeping departure from decades of best practices for how federal agencies award grant applications and would shift substantial decision-making authority from scientific experts to political appointees, undermine the independence and integrity of the peer review process, and create new opportunities for political considerations to influence federal research investments.
Recommended Talking Points:
- Political involvement in grant decisions threatens scientific independence. Federal awards should not be based on partisan ideology, but rather objective criteria, innovation, public health needs, and congressional intent.
- Injecting politics into grant decision-making diminishes transparency and sets a dangerous precedent for future administrations.
- Shifting away from traditional peer review deemphasizes scientific merit as the primary factor in grant decisions and will especially harm early-stage investigators who will no longer receive meaningful feedback on their grant applications.
- Granting the executive branch unprecedented and nearly unlimited discretion over federal grants is contrary to federal law and would allow any future administration to withhold, suspend, or terminate grants mid-performance for any reason, forcing grantees to operate in an ever-shifting environment.
- Award grantees will be faced with unpredictable financial, legal, and reputational risks as well as additional administrative burdens (i.e. required e-verify compliance) that increase the costs of accepting federal awards. Many qualified grantees may be unable to accept those risks and instability and decide to leave the field entirely.
- A narrow interpretation of "gold standard science" could unintentionally exclude valuable and necessary research, for example in the oral disease space.
- The additional reviews, prior approvals, payment justifications, and subaward monitoring provisions increase bureaucratic red tape and will create uncertainty and unpredictability in grant funding that will disrupt and delay scientific discovery.
- Restrictions on subawards could make it harder for institutions to collaborate effectively. Smaller institutions, community hospitals, and community-based partners often participate in research through subawards.
- The overly broad prohibition on international scientific collaboration will disrupt partnerships and hinder scientific innovation, particularly for diseases with smaller patient populations that depend on data sharing and global clinical trials.
- Congressionally funded federal programs that help address longstanding racial, social, or other disparities or serve underserved communities are at grave risk.
- Disallowing fundings for activities such as conference attendance and journal publication harms researchers’ ability to disseminate findings and may delay the translation of discoveries into clinical practice.
