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Faculty Impact
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The proposal places significant emphasis on agency priorities, the administration’s concept of “Gold Standard Science,” and policy considerations in discretionary funding decisions. It deemphasizes merit review and requires politically appointed officials to make grant funding decisions based on the administration's political priorities.
It also introduces undefined review terms such as “anti-American values” and requires scrutiny of an applicant’s history of “questionable practices”, including plagiarism; discredited or non-replicable studies; activities deemed “inconsistent” with federal civil rights or religious liberty laws; and memberships in or affiliations with organizations that “violated Federal laws” or “undermine public safety or national security.”
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These provisions affect how research funding decisions are made, including how research
opportunities are developed and approved by officials before posting, how research
proposals are evaluated, how funding priorities are established, and the extent to
which subjective political, programmatic, and policy considerations affect funding
decisions. |
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Changes in Review Process
This new subsection would require federal agency heads to designate senior political appointees to conduct pre-issuance reviews of all discretionary awards. These senior appointees must apply specific principles, including ensuring that discretionary awards “demonstrably advance the President’s policy priorities," are not used for discriminatory or impermissible purposes, and emphasize compliance with applicable law.
The proposed rule explicitly states that peer review recommendations must “remain advisory” and not be “ministerially ratified [or] routinely deferred to” by senior appointees. The proposed rule states that agencies are not required to issue awards solely as a result of issuing a Notice of Funding Opportunity (NOFO), and may repost a funding opportunity if doing so would avoid funding “low-quality proposals.”
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As previewed by Executive Order 14332 this introduces a new layer of political review into the award process, potentially adding another layer of unpredictability into award timing and outcomes, as senior appointees exercise independent judgment over proposals, separate and apart from scientific peer review. |
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Expanded Suspension and Termination Authorities
The proposal expands agency authority to suspend or terminate awards based on agency priorities, program goals, and/or political determinations of the national interest, regardless of whether the recipient is performing the project per the approved scope of work. Terminations may be made to “a class of award,” not just individual grants.
Termination for the government’s convenience, e.g., for changes to administration priorities, may not be appealed.
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These proposed provisions would increase uncertainty for multi-year projects (such
as clinical trials), research centers, graduate student enrollments, workforce planning,
and other long-term investments that depend on policy stability that enables researchers
and their institutions to achieve the national competitiveness goals of federal research
grants. |
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Changes to Allowable, Unallowable, and Indirect Costs
Changes to the indirect cost rate negotiation system are not proposed. However, the proposal states that, all else being equal, agencies should prefer applicants with lower indirect cost rates in discretionary funding decisions.
The proposal disallows several necessary costs. For example, publication costs, including
article processing charges, or similar open access fees for professional journal publications
and other peerreviewed publications. These are unallowable unless expressly required
by statute or approved in advance by the federal agency. With no exception, subscriptions
to business, professional, academic, and technical periodicals are unallowable. The
proposed rule also permits costs for attending conferences only if participation in
the conference is expressly approved by the agency. Costs of memberships in professional
organizations are allowable only if necessary to fulfill award requirements.
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While OMB states that the proposed revisions do not address the indirect cost rate
negotiation system, and the proposal does not directly cap negotiated F&A rates, it
would reduce indirect cost reimbursement through broad disallowance of some costs.
This has implications for the institutional infrastructure that supports research,
including compliance, cybersecurity, research security, animal care, facilities, grants
administration, and other research support functions. Furthermore, any disallowance
of publication or conference costs would increase the costs to institutions, limit
dissemination of federally funded research findings, and restrict professional development
collaboration important to the training of future STEM experts. |
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