Hello friends,
A few hours ago, the American Diabetes Association enlisted police to eject the editor-in-chief of one of their own journals from their conference. His offense? Quietly distributing copies of his editorial in Diabetes Care¹ that calls for his colleagues to reject complacency, halt the destruction of biomedical research infrastructure, and “continue to believe in ensuring better health for all.” Here’s to Dr. Steven Kahn and everyone who is standing up and speaking out.

There’s a lot going on, including the unforgivable destruction of the Ocean Observatories Initiative, but I’m going to deviate from my usual format today. I suspected it would be bad last week, but the consequences of a newly-proposed revision to federal regulation are dire. This is an emergency: we all need to focus on what it is and how to mitigate it.

This was Year 2, Week 23. Good grief, I’m tired of these machinations.

What’s happening

The Office of Management & Budget (OMB) has proposed revision to the Guidance for Federal Financial Assistance that is all about increasing and centralizing political control. This is the latest move from OMB director Russell Vought, the architect of Project 2025, or as ProPublica calls him, our shadow president. His changes to the rule would transfer complete power over grants, loans, and cooperative agreements into the hands of political appointees and turn the Trump administration’s policy preferences into binding mandates.

What would the revision do?

They say these changes will “improve transparency, accountability, and oversight.” What they actually do is enshrine political preference over peer review, explicitly authorize grant terminations at any time and for any reason, and institute binding government-wide control. Those are big claims, so here are the specific sections (§) and direct quotes from the proposed revision to back them up:

1. Require political review. §200.205—Federal Agency Review of Merit of Proposals doesn’t forbid peer review, but it doesn’t have to. Instead, it requires that every research funding decision undergoes political review by senior appointees², who must ensure that all projects “demonstrably advance the President’s policy priorities” and are explicitly told they must not “ratify or routinely defer to the recommendations of” experts.³
2. Encourage grant terminations. §200.340–Termination and Suspension allows multi-year grants to be cut at any time, expressly for political convenience. The section “contemplates that sometimes Federal agency program goals or priorities may change after an award is initially made, or that the Federal agency may reassess whether a particular recipient remains the best available choice.” It sounds ominous because it is.⁴
3. Consolidate power. §200.303—Internal Controls frees OMB from existing standards issued by the Comptroller General and Government Accountability Office, arguing that since it is a legislative branch agency “its views regarding internal controls are not binding on Executive Branch regulations.” Elsewhere in Section B, the revision would make OMB’s requirements “carry regulatory effect in their own right” and eliminate the inconvenience that currently classifies its regulatory text as ‘‘guidance, not regulation.’’

So what?

If you’re not already shocked, here are a few ways science is directly harmed under this consolidation of power:

1. International collaboration - under new “domestic-first frameworks” (§200.202), your ability to collaborate with colleagues outside the country is greatly curtailed. Grant applications with international components must be reviewed and rejected unless deemed to be, “in the national interest of the United States.” More than that, your collaborations could be forbidden entirely, including any “direct programmatic activities, research, technical assistance, travel, or indirect costs” (§200.220). All it would take is an executive order labeling your counterparts’ country or organization as one of concern.
2. Conference and professional memberships - the annual meetings of your professional society and all your other academic conferences are thrown into question (§200.432). Traveling to them would have to “advance program outcomes” and be expressly approved by your funding agency in your award terms. Likewise, professional memberships (§200.454).
3. Publication and public engagement - Except as required by statute, “publication costs page charges, article processing charges (APCs), or similar fees such as open access fees for professional journal publications and other peer-reviewed publications) are unallowable” (§200.461). Apart from recruiting project participants, grantees would be generally prohibited from any “advertising and public relations costs (including those related to magazines, newspapers, radio and television, direct mail, exhibits, and electronic or computer transmittals)” (§200.421). You’d also probably need to pay attention to whether simply disclosing your own research findings risks being labeled by OMB as lobbying for “engaging in issue advocacy or public messaging that promotes or opposes a particular social, political, or public policy position” (§200.450).

I'm only focused on science and barely scratching the surface. In this week's Unbreaking briefing, we explain how this proposed rule change works hand-in-hand with Schedule P/C reassignments of federal jobs. The manipulation of the system is breath-taking. Crucially, this is much larger than just science and health funding. Transportation projects, rural infrastructure grants, HeadStart programs, you name it–everything covered in the more than $1 trillion⁵ (yes, trillion⁶) of federal financial assistance–are all in the same boat.

Now what?

We need to submit public comment on the proposed rule. I KNOW, I know. We are all exhausted, and it feels like taking on thankless work and maybe a pointless risk just to shout into the void. But this is a rulemaking question—the revision does not require a vote by Congress to go into effect—so the strategy to oppose it must suit the regulatory process.

Cole Donovan offers solid guidance on why public comment is the necessary first step. In short, it creates evidence of overwhelming opposition and, like it or not, sufficient pressure absolutely alters political calculus right now. More importantly though, and especially if OMB rams this through with no attention to public input, substantive comments lay the foundation for a successful legal challenge. Think about it like this: if they were winning their cases in court, they wouldn’t need to play Calvinball in the rulemaking docket.

So here’s my ask:

• Submit a comment as an individual. The best comments are unique, factual, and succinct. You just need to use your own words, pick one specific thing that matters to you, and explain why this proposal keeps you from doing the best science you can. You might prefer to frame your input positively, focusing on the value of peer review or international collaboration. This is also an ideal place to unleash your inner Reviewer #2. You might even submit anonymously and explain why the threat of retribution makes it impossible for you to speak freely. If you’re not a researcher, you might focus on your identity as someone coping with a disease, as someone whose family or community will suffer, or just as a citizen who deeply cares. Here’s the (surprisingly helpful) official guidance, and Inside Higher Ed has more expert help for you. Just remember: no forms, no copy/pasting. Perfect is the enemy of done.
• Push your affiliated organization to submit substantive comments. Expert consensus is legally useful. Ask leadership to commit, repeatedly and publicly if necessary. Cite the evidence that their participation matters. Celebrate and circulate when they do. AAAS put out the strongest statement I’ve seen from them to date, calling it “a brazen power grab by the Director of the Office of Management and Budget to buck the will of Congress and the American people.” Great! Next I want to see their full submission. I know lots of societies are emailing their members and issuing calls to action. I hope your leadership is activated, and if not, that you can spur them to action.
• Reject despair and fight those who would capitulate in advance. This is not a good-faith attempt at necessary reform. It's hostile and must be treated as such. If you’re scared or numb, you’re not alone. By now, I suspect you’re an expert in being scared or numb, and doing the work anyway.

I know you care. This is a critical chance to make that caring count.
Onward,
Liz

PS - A lot of excellent work has gone into rapidly absorbing and interpreting the proposed rule. I want to drop notes of appreciation for Elizabeth Ginexi’s analysis, as well as editorials from Holden Thorpe and FAS, and coverage by Science, STAT, Ars Technica, and Scientific American.

As ever, thanks for reading & thinking with me. Meeting the Moment will always be free, but if you want to contribute, you can ⤵️

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