Take Action to Preserve Merit-Based Science and International Collaborations
The White House Office of Management and Budget (OMB) has proposed a new rule titled “Regulation for Federal Financial Assistance” that will significantly reshape how the U.S. government funds and manages scientific research, including international collaborations, through the National Institutes of Health (NIH) and other agencies. All ISSCR members, regardless of whether you are U.S.-based or not, are eligible to provide comment on the proposed policy.
Though the rule is extensive and applies to all federal grantmaking, there are several areas where input from our community is critical.
These include:
Section 200.205: De-emphasis of merit-based review and the establishment of political review. Political appointees would see expanded power to override expert assessment of scientific merit of grant applications. Under the proposed changes, all grants must “...demonstrably advance the President’s policy priorities.” This politicization of research funding represents a significant departure from the merit-based system that has been in place for decades.
Sections 200.202 and 200.220: Outright restrictions or significant bureaucratic burdens on international collaborations. In addition to applying a “domestic-first” framework for all grants, new restrictions would impact programmatic activities, research, travel, and indirect research costs for international collaborations. The proposed rule would have significant implications for both basic research and clinic trials. International collaboration has been essential for progress in stem cell research; the proposed rule undermines innovation and clinical translation.
Section 200.340: Enables mid-stream grant cancellations without cause, including for political reasons. Under the proposed revisions, research grants would no longer have long-term reliability after they are awarded. Funding for ongoing research projects, clinical trials, and long-term scientific studies could be terminated at the discretion of an agency. These provisions increase risk for grant recipients and hinder the ability of researchers to conduct the long-term planning necessary for high quality research.
Sections 200.432, 200.454, 200.461: New restrictions on scientific exchange and professional activities. Publication and subscription costs would be unallowable for grant recipients, while conference expenses and professional organization memberships are unallowable unless explicitly written into grant terms. These activities serve as the foundation of scientific exchange and help drive rigorous, reproducible science through professional and peer engagement and the open exchange of ideas, methods, and research results.
For a full synopsis of changes in the proposed rule, please see this summary. The Association of Public & Land-Grant Universities (APLU) has also compiled resources on the proposed rule, including a summary of major provisions, found here.
As part of the U.S.’s rulemaking process, there is now a brief public comment period for interested parties to comment on the proposed rule. The ISSCR is preparing a formal response that will highlight the negative impacts of the proposed rule and calling for its withdrawal. You are encouraged to submit a comment in your personal capacity on the proposed rule. (Additional details below.) Comments must be received by 13 July, 2026 at 11:59PM EDT.
What Can You Do?
Submit a Comment to OMB regarding the Proposed Rule
You can submit a comment to OMB in your personal capacity about how these changes will impact you and your research. Comments can be submitted anonymously, and you do not need to live or work in the U.S. to comment. Comments must be received by 13 July 2026 at 11:59PM EDT.
Comments can be submitted on the Regulations.gov website for the proposed rule. Click the blue “Comment” button at the top of the page and follow the instructions on the next page. Files can be attached to your submission, if you prefer to submit comments on a word document or PDF.
Tips for commenting:
Make your comment personal. If possible, share information about your qualifications and your research, and how the proposed changes will impact you specifically.
Structure your comments by listing in brackets the section number of the proposed rule you are commenting on. For example, if you are providing comments on the political review of grants, start that paragraph with [200.205]. Refer to the above summary and linked documents for section numbers.
You do not need to comment on every provision. You can choose to submit comments only on provisions that would impact you the most.
We recognize that continued shifts in the policy landscape are having significant impacts on you, your research, and your colleagues. Please know that ISSCR continues to engage on these issues.