This Proposed Rule Could Change American Science Forever. We Read It So You Don’t Have To.
On May 29, the Office of Management and Budget (OMB) dropped a 108 page (single-spaced) proposed rule to “revise the Guidance for Federal Financial Assistance to improve government-wide policies and requirements related to the management of grants, cooperative agreements, and other forms of assistance.” If you are not a dyed-in-the-wool wonk, here’s a translation: this proposed rule would change the way the federal government funds scientific research. And state energy programs. And community health grants. And the local governments trying to modernize how they deliver services. Like a lot.
Aside: there is something wrong with the way we fund science in this country — the list of flaws is long and we have to own them. We also have to build something durable, not treat our principles like a suicide pact.
Rule changes like this thrive in tall weeds: the language is arcane, esoteric even, meant to be understood by lawyers and policy experts. Here’s what’s actually in them.
How we got here
There is a crisis of trust in science. Trust in science is still lower than before the COVID-19 pandemic reshaped our reality, with trust in federal science lower still. This trust is also partisan: Democrats are more likely to have confidence in scientists than Republicans are. Many people struggle to trust scientific processes and activities, to have faith in government as an interpreter of scientific findings, to feel public science priorities represent their needs. The federal research funding apparatus feels distant from most people’s lives, and the connection between public investment and public benefit isn’t easily traceable by the people whose taxes make it happen.
The federal execution of science has real problems too. Administrative burden, convoluted workflows, a funding system that concentrates awards among the already-large and already-connected, a merit review process that has calcified in ways that make it slow and risk-averse. As a community we have to own that. The fish psilocybin study wasn’t taxpayer-funded, but some real head-scratchers were (for the record: some of them were worth it).
Backstopping all of this is a weakening of Congress’s role in R&D. While there is bipartisan support for research in Congress (like the many Democratic and Republican lawmakers who have championed investment across AI regulation, wildland fire, and on emerging technologies like biotech and quantum computing), Congress has been relegated to a rump when it comes to their fiduciary duty to scientific research. Money expressly authorized and appropriated by the people’s house is being held up, research agencies are being starved of their necessary funds, and there is hardly anyone left to do the work.
In that context, the Trump administration has been establishing a policy lineage for major change in how the federal government invests in many areas, including R&D. The 2025 Restoring Gold Standard Science executive order directed political appointees to oversee agency scientific decisions and resolve GSS “violations,” inserting politics into processes where existing scientific integrity policies had specifically been designed to keep it out. Agency implementation plans followed across multiple science agencies. This proposed rule is the next step.
Back to these rules
How much have you heard the phrase “gold standard science” in the last year? As a concept, it was reaching for something important: accountability in how research dollars get spent, scrutiny of whether peer review had become a closed loop, a question about whether federally funded science was delivering for the public that funds it. What it became in practice is something different.
Is it, for example, the systemic weakening of career staff at science agencies to replace their blood-sweat-and-tears expertise with political appointees? Is it firing the National Science Board en masse over email on a weekend? Is it gagging the NSF watchdog meant to uncover research misconduct and fraud? This doesn’t begin to cover the politicking that has diminished our national public health apparatus, or the bed bugs in the Animal and Plant Inspection Service building.
What gold standard science became in practice is a mechanism for political appointees to override scientific judgment and frame ideological interference as methodological rigor. This proposed rule puts that mechanism into binding regulation, government-wide: mandatory political review of every discretionary grant before it’s awarded, expanded authority to terminate awards mid-stream, new restrictions on what funded researchers can publish, say, or collaborate on internationally.
Science is not the only thing at stake. The federal grants system funds an enormous range of what government actually does: states building out energy infrastructure, local health departments running maternal care programs, nonprofits delivering workforce services, cities trying to modernize how they serve residents. OMB’s proposed rule governs all of it: billions in federal grants, every dollar now subject to the same appointee review and presidential priority test. A political appointee gets to decide, mid-stream, that the work no longer matters. That’s not a grants system anyone can build anything ambitious in.
Replacing expert peer review with political appointees doesn’t make federal financial assistance of any kind more accountable to the public, it makes it accountable to whichever political team won the last election and their appointees’ desire to micromanage. Every grantee in America is now operating on that assumption.
The proposed change to §200.205 would formalize prior guidance for senior appointees – not career scientists, not program officers, not people who know how to do this thing – to review every discretionary grant before it’s awarded (science and beyond).
For science specifically, it goes further: appointees expressly prohibited from deferring to peer review [read: experts] on the matter. Since WWII nearly every science agency has emphasized independent expert peer review as THE measure of scientific merit. Even your 8th grade science teacher emphasized this. Under the change to §200.205(d), a political appointee can override the scientific community’s judgment just because. Discretionary awards must also “advance the President’s policy priorities” – not national security, or public health, nor foundational science priorities. Presidential ones.
Under current rules, terminating a grant requires a finding of noncompliance or fraud, which is a high bar because multi-year awards require multi-year commitments. You can’t build a cutting edge research program or radically transform a grid on a one-year horizon. The proposed change to §200.340(a)(2) drops that bar entirely. No finding required; termination is available whenever an award no longer aligns with agency priorities or the national interest. Yes that could mean almost anything. There are currently 150,000 active multi-year awards operating under the assumption that finishing what they started is possible. The chilling effect on applications may be as significant as the terminations themselves: why spend months on a competitive grant application, or structure your organization around a multi-year award, if the whole thing can evaporate at will?
Then there’s the elimination of fixed-amount awards. Smaller organizations, the ones without teams of grants managers and compliance lawyers, depend on fixed-amount awards because they’re manageable. Kill them and you’ve told a significant chunk of the grants ecosystem that they’re no longer in the running.
Proposed changes to §200.421, §200.432, and §200.461 restrict the use of federal funds for publications, press communications, and conference attendance. For researchers, this directly conflicts with a longstanding OSTP mandate requiring federally funded research to be published open-access. You can’t comply with one federal requirement without violating another. But the restrictions aren’t limited to science: any federally funded practitioner sharing findings, any state agency presenting at a national conference, any nonprofit documenting what their grant actually accomplished runs into the same wall. In other words: you can’t do public work that the public can see and learn about.
The proposed changes to §200.220 and§200.202(e) would require case-by-case approval for international research collaborations — a domestic-first framework that treats standard scientific practice as a special exception. (We did just bring a Canadian to the moon with us, for the record.) International cooperation is standard practice across many scientific disciplines; fruitful, peaceful scientific collaboration has been the norm with any number of countries (that we are already engaged in multilateral collaboration with)? A domestic-first framework that requires case-by-case approval would be detrimental to international public health efforts, where foreign scientists are leading research into treatments and containment.
Changes to §200.206 look a lot like a loyalty test and not just for science. Any organization applying for a federal grant would be subject to eligibility review based on its affiliations, activities, and perceived alignment with administration priorities. Congress tried this one in 1949 when they tried to sneak in a loyalty test affidavit into the National Science Foundation Bill. We said it in 1949 and we’ll say it again: “Its sole justification for inclusion is concession to current fears and hysteria. Totally ineffective in detecting actual enemies of the U.S., it is significant only in its indication of the state of mind of the country – one of unreasoning insecurity and fear. To fail to oppose the provision is to accept this state of mind and permit it to go on to even more dangerous manifestations.”
The provision that should worry everyone is in §200.202(a)(iii): a requirement that federal programs “align with administration policies and priorities.” Science funding has always been political and anyone telling you otherwise is selling something. Democratic legitimacy matters for public investment, and the federal government should be accountable to the people whose taxes fund it. But there’s a meaningful difference between federal priorities and administration priorities that this rule deliberately erases. The federal government is a massive institution with a general mandate to serve the public across generations. An administration comes and goes every four to eight years, with narrower ideological agendas and a much shorter time horizon. Requiring every grant dollar to align with the current administration’s priorities isn’t accountability, it’s a different thing entirely.
Two things can be true
To be fair, a few things in this rule are worth having. NOFO streamlining and encouragement of multi-year awards are real improvements to a pre-award process that has frustrated applicants for years. The rule also comes down hard on merit review as a source of stagnation, and to an extent that’s not wrong. We’ll take those. (Further FAS insights into merit review are forthcoming, but traditionalists be forewarned: we make a many-pronged call for reform.) As a scientific community we have to own the current flaws. We also have to build something durable, not treat them like a suicide pact.
Step back from the individual provisions and the systemic problem becomes clear: this rule is a demand signal and institutions will respond to it rationally. Universities, nonprofits, state agencies, and local governments will look at these conditions — arbitrary termination authority, political pre-clearance, loyalty reviews — and make reasonable decisions about what’s worth pursuing. You cannot have loyalty tests and a scientific effort the size of the Manhattan Project or in new areas of discovery where the trajectory is unknown. Smaller institutions without the legal and administrative capacity to manage the new compliance burden will exit the market; larger ones will self-censor. The portfolio of federally funded work will get narrower because the risk calculus changed.
There’s an irony here for anyone who believes in competent government: a system that can override expert judgment at will has less use for experts. That’s a demand signal too. There is a world beyond merit review emerging, like the NSF X-Labs initiative, team science models, Tech Labs built on baked-in independence. Exciting constructions, none of them ready for prime time. We can’t throw the baby out with the bathwater. Better results from federal grants are a legitimate goal, and the path there isn’t complicated to describe: grants systems that actually reflect the communities and problems they’re meant to serve, and that are designed to learn from what happens after the money goes out the door. We don’t have that now and this proposed rule doesn’t get there either.
So what’s next
Many of our peers are outraged. AAAS CEO Sudip Parikh calls these proposed changes “a brazen power grab,” while Irene Ngun, Assistant Director of Policy and Advocacy at Stand Up For Science, plainly calls it a “weaponization.” Across the science and technology policy community, there is a feeling that this represents the final bell toll of an apocalyptic-level event for American science. Whether or not that is your read on the situation, this is as significant as a change as can be. Independence is the source of scientific integrity. (And those outside of this community should care too: OMB’s proposal would govern billions in federal grants. Every dollar everywhere will be subject to the same appointee review and need to meet presidential priorities.)
There is no question this is a Big Deal. If you are a university or research lab, or aspire to work in one, or are simply an enthusiast of federally-funded research (the kind that gave us the internet!), what’s next will matter. It is likely these changes will lead to litigation. When that time comes, we will offer dispassionate analysis, giving primacy to facts and figures. But before that, we are exploring every avenue available to us to revert this threat.
- We’re in constant contact with science advocacy groups, industry, scientists and innovators, and policymakers to stay on top of the latest dynamics and opportunities for action.
- We’re reaching out to congress and the executive branch with substantive oversight priorities. We need members from both sides of the aisle to act on these. Raise your hand if this is you. Some of these include:
- Conflicting mandates between this rule and other rules throughout government (like the Office of Science and Technology Policy’s open access publishing guidance),
- Clarification about how this rule affects existing and multi-year awards, and
- A Government Accountability Office study request.
- We’re preparing a public comment and encourage you and your institution to do the same.
There is no question this is a Big Deal. If you are a university or research lab, or aspire to work in one, or are simply an enthusiast of federally-funded research, what’s next will matter.
The emerging federal metascience community is asking fascinating questions that are equally vital for democratic legitimacy: beyond “did this program work” to “how does the federal R&D enterprise itself work, and how could it work better?”
Get it right, and pooled hiring becomes a model for how the federal government decides what to do together and what to do apart. That’s a bigger prize than faster hiring. It’s a more functional government.
No one will be surprised if we end up with a continuing resolution to push our shutdown deadline out past the midterms, so the real question is what else will they get done this summer?