On May 29, the Office of Management and Budget posted OMB-2026-0034, a sweeping set of proposed changes to the ways that federal agencies administer funds granted to individuals and organizations, including the research grants made by the National Science Foundation and National Institutes of Health. The proposed changes are framed as preventing waste, fraud, and abuse, but in detail they create dramatic new restrictions on how federal funds are granted, how those funds may be spent, and what people working on federally funded projects may do. In brief: funding decisions would be made directly by political appointees, not by expert agency staff; use of funding for a variety of important activities like conference attendance, publication of results, or public outreach would be heavily restricted; and funded organizations would be restricted from speaking on a sweeping list of allegedly controversial topics, from climate change to human diversity.
Former NIH Program Officer Elizabeth Ginexi has detailed the many concerning rule changes, and helped lead a general call for people to provide comment on the proposals, from their perspectives as members of the American public, as federally funded scientists, and as representatives of scientific organizations. These comments are supposed to inform OMB’s decision to implement, revise, or scrap the proposed rule changes — and, more likely, provide an evidentiary basis for pushback by Congress and in lawsuits that seem very likely to be necessary.
I’ve signed on to statements by the scholarly societies in which I’m a member, and I’ve consulted a bit on some of the language in those; and the California State University system, my employer, also has a comment in process. Today I also submitted a comment from me, personally. Individual comments are limited to 5,000 characters, and specificity is key, so I focused in on a recurring theme I saw in the changes — restrictions on scientists’ ability to communicate. I’m posting the text of my comment here as an independent record, and in case any readers want some additional motivation or inspiration for their own comments. Comments on the proposal are still open until 11:59pm (Eastern time) on Monday, 13 July, and I’d encourage you to contribute if at all possible — you can do so here.
I am commenting on the proposed Regulation for Federal Financial Assistance in my capacity as Principal Investigator of a research lab supported with current federal funding, and with a career-long history of work on federally funded research. I won Honorable Mention from the National Science Foundation’s Graduate Research Fellowship program, and my doctoral research benefitted from a NSF Doctoral Dissertation Improvement Grant; I went on to postdoctoral research on a NSF-funded collaborative project, and as faculty at California State University Northridge, my lab has received funding from both NSF and the Bureau of Land Management. I am concerned that the proposed Regulation would impede one of the most basic tasks of scientific work: communication.
Communication among scientists, and between scientists and the American public, is essential to scientific discovery, and to unlock its benefits for American society. The proposed Regulation places new restrictions on the use of grant funds for conference attendance (§200.432) and professional society membership (§200.454), severely restricts the use of grant funds for publication costs and open access (OA) fees (§200.461), severely restricts public communication and outreach by grant-funded researchers (§200.421), and prohibits the use of grant funds in connection with sweepingly defined “issue advocacy” (§200.450). These restrictions would hamstring scientific discovery and prevent scientists with federal funding from communicating results of their research to the taxpayers who supported it. That is, they could, ironically, prevent scientists from doing the very things that federal research funding pays us to do.
Conference attendance and professional society memberships let scientists exchange ideas, especially projects in progress, in less formal settings where discussions can be frank and free-flowing. At the Evolution meetings in June, I presented work supported by NSF, and a graduate student in my lab presented her BLM-supported thesis project. Both of us fielded questions and suggestions that will help us improve the work as it continues. This conference was also my first opportunity recruit prospective new graduate students and a postdoctoral scholar whose work would be supported by a NSF award I had just received. Because I was at the meeting, I could talk to prospects in person, get to know them, and make my “pitch” well ahead of the recruitment and hiring process.
Publication costs and open-access fees are also essential for basic research. Articles published in peer-reviewed journals are the primary way scientists learn about each other’s work, so we can build on it, refute it, or simply learn from it. Open access (OA) publication — in which articles are posted online, free of charge to the reader — makes research available to the widest possible community, including the American public. The cost of organizing peer review and publication is, however, not zero, and OA fees paid by authors are a solution (if an imperfect one) to cover these costs. NSF now mandates OA publication of articles reporting research work funded by NSF grants, so rules impeding the use of grant funds for OA fees are at odds with an existing agency mandate as well as the fundamental processes of science.
Finally, communication of research results to the American public is a civic duty for scientists working with the support of government funding. Taxpayers have a right to know what discoveries are produced by the investments federal agencies make on their behalf, through research grants. NSF recognizes this right through the OA publication mandate, and by including public communication and outreach as important research activities. Researchers are often the best qualified people to speak on topics of public interest, when those topics touch on their expertise. As just one example, I have written an Op-Ed and given media interviews advocating in favor of energy development in the Mojave Desert, which impinges on the habitat of species I study as part of my federally funded research — but which can also help to protect those species if planned carefully.
Thus, all of these provisions in the proposed Regulation are concerning to me because they limit activities that improve the effectiveness of federally supported research, and could prevent federally supported scientists from communicating their results to the American public or contributing expertise to important matters of public concern. I would ask that all of them be withdrawn, and that the proposed Regulation be withdrawn in full, or rewritten from the ground up in conversation with the relevant Congressional committees, who can speak to the purpose of legislation that grants all funds administered by OMB.
Thank you for your consideration,
Jeremy B. Yoder
Associate Professor of Biology
California State University Northridge