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Director Russell Vought White House Office of Management and Budget  1650 17th Street  Washington, D.C. 20006

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

Dear Director Vought,

On behalf of ÃÞ»¨ÌÇÖ±²¥, thank you for the opportunity to comment on the Office of Management and Budget’s (OMB) proposed regulation for federal financial assistance. ÃÞ»¨ÌÇÖ±²¥ is one of the oldest and largest life science societies with over 38,000 members in the U.S. and around the world. Established in 1899, ÃÞ»¨ÌÇÖ±²¥ is the home for microbial scientists from around the globe to connect, learn, discover and prepare for the future.

ÃÞ»¨ÌÇÖ±²¥ agrees with OMB that scarce federal taxpayer dollars should be directed exclusively to achieving results for the American people. This proposed rule does the exact opposite on several fronts, and most of all by politicizing science.

As demonstrated repeatedly, The United States’ federal investment in funding the research ecosystem has generated amazing dividends for the American people and been an engine for ingenuity and innovation of the private sector. The National Academies of Sciences’ seminal “” study surveyed multinational business leaders and found that 2 of the top factors in deciding where to locate research and development facilities are the quality of research personnel, who are trained through federal funded research and workforce development programs, and university collaborations.

The OMB proposed rule will indeed stymie ingenuity and thwart the ability to attract and retain talent, rather than placing the U.S. on a stronger competitive footing with other countries, which are already taking the lead in research and innovation. The OMB proposed rule essentially undermines the core elements of our scientific ecosystem that have propelled the U.S. into scientific preeminence over the past 80 years. We believe that this is not in the interest of the American people or what the administration wants to be its legacy.

OMB’s stated goals of increasing transparency, oversight and accountability are laudable. Yet, the provisions of this rule will not achieve those goals. Hence, ÃÞ»¨ÌÇÖ±²¥ urges OMB to immediately withdraw the rule in its entirety. The proposal creates onerous new review processes and political control of grants, undermining the existing, globally recognized and adopted peer review process that ensures rigor, accountability and transparency.

The comments that follow focus on provisions that significantly affect federally supported research. ÃÞ»¨ÌÇÖ±²¥ does not address every proposed change, and the absence of comment should not be interpreted as agreement.

Section 200.202—Program Planning and Design

The proposed rule encourages federal agencies to use multiyear awards when possible. Before implementing these or similar policies, ÃÞ»¨ÌÇÖ±²¥ requests that OMB and research funding agencies evaluate the impact of the shift of forward funding of grants to ensure that the strategy does not result in an abrupt decrease in grants. If the shift to forward funding does result in lower success rates, the administration and scientific grantmaking agencies should work with Congress to increase grant funding accordingly.

In principle, we are not opposed to forward-funding, since multi-year funding can increase security and, hence, promote more risk-taking in research. However, multi-year funding cannot come at the expense of the number of grants awarded each year, otherwise we run the risk of losing the next generation of scientists, given the funding crunch. For example, the average National Institutes of Health grant is 4 years. If this average-duration grant receives full funding in year 1, and the budget stays flat, there will be 3 other average-duration grants that will receive no funding. Hence, to maintain steady state, the NIH budget would need to be quadrupled to be able to do forward funding in a logical manner. Is OMB prepared to do that? We would stand behind such a proposal.

Section 200.205—Federal Agency Merit Review of Proposals

The proposed rule requires pre-issuance political appointee review of all federal grants to ensure consistency with the administration's policy agenda. Prioritizing political review of grants will diminish the influence of scientifically-focused peer review on grant decisions and harm scientific integrity. As we have witnessed over the past 18 months, this approach contributes to long delays in program implementation.

When science becomes politicized, federal agencies and recipients focus their efforts and taxpayer resources on burdensome policy requirements that may be unrelated to or misaligned with core purposes of federal grant programs, thereby reducing the effectiveness of federal funding. Most importantly, science is the business of surprises, which can deliver cures, cleaner environments and prosperity. If we let politics control science, the inevitable surprise is that there will be no surprises. 

Technical peer review is a cornerstone of the federal research funding process, ensuring that the most rigorous, reproducible and innovative research is funded. Research funding decisions often require highly specialized knowledge of scientific methods, study design and subject-matter context. Career scientists, physicians and subject-matter experts are best positioned to assess these complex factors. Expanding political involvement in these determinations introduces the risk that considerations beyond scientific merit may influence outcomes, reducing consistency in this process and discouraging investment in areas of science perceived as more subject to shifting policy interpretation. 

ÃÞ»¨ÌÇÖ±²¥ requests that OMB preserve peer review as the primary basis for individual funding decisions, ensuring that award determinations are grounded in scientific merit.

Section 200.206—Federal Agency Review of Risk Posed by Applicants

ÃÞ»¨ÌÇÖ±²¥ requests that OMB define “questionable practices” and that federal agencies clarify that risk reviews conducted under this provision cannot be used to ban funding to researchers or universities based on political affiliations.

Section 200.220—Prohibition of Using Federal Funds for Covered Foreign Collaborations. 

The proposed rule further restricts the use of federal funds to support global collaborations. This ignores the importance of international research collaborations, particularly collaboration to detect outbreaks. Pathogen surveillance, pandemic preparedness and antimicrobial resistance tracking depend on global collaborative networks, as infectious agents do not respect national borders or geopolitical alliances (, ). Relationships and collaborations among scientists across the world need to be developed on a constant basis, not in a moment of crisis.

Through international meetings and collaborations, American and scientists around the globe exchange methods, compare data, build trust, identify emerging problems and accelerate solutions that ultimately benefit public health in the United States. The proposal to limit the use of federal funds to support certain foreign research collaborations would have a direct impact on these collaborations. If finalized, the prohibition on using federal funds for international collaborations will have the indirect effect of chilling international collaborations even when the work is open, non-sensitive, unclassified, important and strongly in the U.S. public interest. This could lead to delayed global and U.S. recognition of new mechanisms of antimicrobial resistance, early signals of infectious disease outbreaks, zoonotic spillover risks or emerging pathogens.

ÃÞ»¨ÌÇÖ±²¥ supports strong research-security safeguards, disclosure of foreign funding sources and risk review. ÃÞ»¨ÌÇÖ±²¥ requests that OMB avoid language that treats ordinary, open scientific collaboration as presumptively suspect.

Section 200.300—Statutory and National Policy Requirements 

The proposed rule would ban federal funding for Diversity, Equity and Inclusion (DEI) programs, including programs with any explicit or implicit racial preferences for participation. ÃÞ»¨ÌÇÖ±²¥ opposes the proposed revisions. In fact, diversity in thoughts, perspectives and experiences is not only desirable, but essential to solve complex problems, which is what science is about.

In order to maximize government investments in science and come to innovative solutions that benefit all people, a diverse scientific workforce that represents all ideas and approaches is necessary. While we embrace the fact that no program should be exclusionary of any individual who is qualified, we are deeply concerned that the proposed ban on DEI programs will harm programs to increase participation in science, harming, not helping, scientific progress and the effectiveness of government funding and of private sector needs. ÃÞ»¨ÌÇÖ±²¥ supports maintaining a strong microbial science workforce, which should include heterogeneity of approaches and thought to ensure innovation and scientific progress.

Section 200.340—Termination and Suspension

The proposed rule allows agencies to terminate an active award at any time if it no longer aligns with agency priorities or the national interest. This will not advance the federal government’s objective to avoid wasted investments and harm to scientific integrity.

Expanded discretionary termination authority threatens scientific integrity and will politicize science. If researchers become reticent to share results that contradict an administration's policy preferences for fear of cancellation, that will undermine objectivity. Mid-cycle termination is particularly fiscally wasteful: when grantees cannot complete experiments already underway with federal funds, the government forfeits the value of its initial investment and the potential of technology transfer. Scientific research is not like an assembly line: you can't stop and start and expect the project to restart efficiently.

Biological experiments, such as clinical trials, are often logistically complex and costly to start, stop and restart; cancelling these studies can have a direct impact on patient outcomes. An estimated 74,000 clinical trial participants were impacted by grant cancellations in 2025 with clinical trials sponsored by the National Institute of Allergy and Infectious Disease most impacted by grant cancellations (). Additionally, many trainees are supported by research grants; sudden grant cancellations disrupt training and force trainees to leave the scientific workforce—or discourage potential scientists from entering the research workforce—losing potential innovations and scientific knowledge ().

Section 200.432—Conferences

As we mention above, scientific collaboration and free exchange of ideas, approaches and possible solutions to complex problems are essential to securing the highest possible impacts from government funding of science. Scientific conferences serve exactly this purpose and are an essential component of the scientific process and training, allowing scientists to share their work in progress, get feedback from a wide range of peers and develop their skills (). Restricting the use of federal funds for conferences not only undermines sound science; it again lowers the efficiency of the use of public funds and lowers the free dissemination of information, slowing the development of innovations to benefit the public.

ÃÞ»¨ÌÇÖ±²¥ requests that OMB continue to allow flexibility for researchers to determine what scientific conferences and memberships would be beneficial for them to attend as they make progress in federally funded projects.

Section 200.461—Publication and Printing Costs

The prohibition on using federal funds to cover publication costs, combined with the federal government’s mandate to make the result of federally funded science publicly accessible, represents a large unfunded mandate on researchers. In response to federal government’s public access mandate, publishers have shifted away from a subscription model and toward an article processing charge model, where researchers cover the costs of publishing papers, usually using federal grant funds. Maintaining both the public access mandate and prohibiting grantees from using federal funds to cover publication fees is unsustainable for non-profit publishers and the larger scientific enterprise. A  study estimated that the public access mandate will cost federal agencies $1 billion a year.

If OMB prohibits the use of federal funds to cover publication costs, the costs of publishing do not disappear. Supporting peer review, editorial and scientific integrity oversight, production and preservation infrastructures all cost money and sustained investment. Prohibiting federal funds from covering publishing fees does not make publishing free. It transfers those costs onto individual researchers, their institutions and publishers, none of whom are positioned to simply absorb them. In doing so, it introduces additional administrative and financial burdens, including the need to establish internal funding processes, track compliance across publications and assume costs currently supported through federal awards, ultimately undermining the effectiveness of the policy and the opportunity for researchers to publish scientific outcomes. This would be yet another opportunity for the U.S. government to cede American leadership in science and technology by giving foreign competitors an advantage over American scientists and will also likely delay the translation of research findings into the benefits for the public.

In fact, without funding, authors face out-of-pocket fees or pressure to publish in venues without rigorous peer review, potentially prioritizing affordability over quality. This policy would further endanger the future of the scientific workforce by forcing researchers to divert limited funding toward publication costs instead of investing in the training, mentorship and hiring of early-career scientists. This dynamic ultimately distorts publication decisions and weakens confidence in the scholarly record, which is exactly the opposite of what public access policy is supposed to accomplish.

Furthermore, ÃÞ»¨ÌÇÖ±²¥ is concerned that the public access mandate and the prohibition on using federal funds for publication fees will force researchers to publish their results in non-peer reviewed venues, like preprint servers or blogs. Peer review is essential to ensure that results are vetted and scientifically sound. Encouraging researchers to publish their work only in non-peer reviewed venues contradicts the administration’s commitment to Gold Standard Science.

ÃÞ»¨ÌÇÖ±²¥ recommends that OMB continue to allow researchers to cover article processing fees and other costs associated with publishing their federally funded research in peer-reviewed journals. This ensures that the results of federally funded research are shared in the scholarly record and appropriately vetted by the scientific community before the research results are used to inform clinical decision-making, product development and policy.

Conclusion

Thank you for the opportunity to respond to this proposed rule. Given the wide range of negative impacts that this rule, as proposed, will have on scientific integrity, Gold Standard Science and progress to develop treatments and cures for infectious diseases and microbial biotechnologies, ÃÞ»¨ÌÇÖ±²¥ requests that OMB withdraw this rule. If you have any questions or would like to further discuss these comments, please contact Nicole Zimmerman, Senior Federal Affairs Officer, at nzimmerman@asmusa.org. 

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Stefano Bertuzzi, Ph.D., MPH
 CEO, ÃÞ»¨ÌÇÖ±²¥