Notice & Comment

Funding Ideologies not Ideas, Factions not Facts

For decades, the United States has maintained global leadership in fundamental and applied science by investing in research to answer questions of greatest concern to our health and well-being and the advancement of society. Federal science funding has powered breakthroughs that shape our daily lives. These advances often begin with long-term research investments that can take decades to deliver real-world impact.

A proposed rule by the Trump Administration’s Office of Management and Budget (OMB) puts American scientific progress and leadership at risk. It would require each agency to establish a centralized process for advance review of all research grants by senior political appointees to ensure that they further the president’s policy priorities. It would empower political appointees to use their “independent judgment” to filter out projects that do not align with the administration’s priorities, regardless of merit-based and peer-reviewed evaluations of their scientific merit. Political officials could even terminate or suspend existing grants midway with a vague, easily abused determination that an award “no longer effectuates program goals, agency priorities, or the national interest.”

The proposed rule is an invitation to substitute the ideological or partisan preferences of political appointees in place of the knowledge and experience of experts in the relevant fields. It would put the choice of what topics to study, what methods of research to use, and which researchers or institutions will be funded in the hands of a thin layer of political appointees across federal agencies.

The proposal should be seen in three contexts. First, it is another effort by the administration to centralize the White House’s political control over currently nonpartisan functions of the government. Second, more specifically, it is a power grab at the expense of Congress that would give political appointees more tools to override or ignore legislative mandates for research and action in areas such as public health, environmental protection, and energy policy. Third, it would add to the current administration’s toolbox for punishing disfavored states, cities, and constituencies.

Over time, the nation’s research agenda would swing with the political valence of future presidents and threaten stable funding for inherently long-term research endeavors. Studies into complex medical, ecological, economic, engineering, and other topics necessarily unfold over years or decades, not four-year political cycles.

The proposal has drawn fierce and widespread opposition. Despite an unusually short comment period, the proposal received more than 496,000 comments. Of the more than 52,000 posted on Regulations.gov by early July, some 95 percent ran against the proposal, according to analysts at the University of North Carolina at Chapel Hill.

Congress is also pushing back. The Senate has just adopted a bipartisan ban on finalizing the rule in a continuing resolution to keep the government funded through early December, which will now go to conference with the House.

It’s easy to see why members of Congress of both parties are riled up. Congress establishes our national research priorities through legislation and appropriations. It sets broad priorities and delegates the task of selecting detailed research agendas to expert science agencies such as the National Institutes of Health (NIH), the National Science Foundation, and other agencies that distribute federal funding. Implementing the congressional priorities, agencies’ grant-making decisions have traditionally been made through merit-based review processes, where independent experts evaluate proposals and recommend the strongest projects for funding.

To be sure, in a merit-based process there can be differences of view on what to fund and why. But the new OMB proposal would inject politically-motivated review into decisions about individual grants, which have traditionally been insulated from that kind of politics.

The perils of politicizing federal research funding are not idle speculation. We’ve already seen dozens of examples in this administration, from the cancellation of hundreds of climate and environmental justice grants by the Environmental Protection Agency (EPA), to the claw-back of billions of dollars in clean energy funding, to the termination of hundreds of NIH research grants for life-saving clinical trials. Just last month Trump officials conceded in a court filing that they halted billions of dollars in energy project funding “based solely” on whether the recipient state voted for the president in 2024.

When the federal science system works as it should, guided by expertise and sustained investment, it delivers tangible benefits that improve people’s lives every day. Decades of federal research funding have led to breakthroughs in medicine, technology, and public systems. The same is true for science that protects our environment. Federal research funding supports efforts that help communities prepare for and respond to climate change: improving hurricane forecasting, strengthening wildfire response, and advancing clean energy solutions. We’ve already seen efforts to cancel satellites and ocean monitors, which are critical to knowing what is happening to a changing climate.

Even programs not directly focused on scientific research – such as those for building infrastructure projects, environmental clean-up, and delivering health care and other goods and services – rely on impartial, merit-based research to guide decisions, measure impact, and improve outcomes. These investments touch communities across the country and underpin solutions to environmental and public health challenges. The proposed rule would give political appointees another way to undermine such programs.

The OMB proposal undoubtedly will face many legal challenges. The proposal raises concerns under the Administrative Procedure Act as well as substantive statutes that require competitive and merit-based grant processes. Among other claims, one could expect challengers to argue that the rule conflicts with governing statutory criteria (e.g., a statutory direction to make grants on a “competitive, merit basis”). Challengers are also likely to argue that the rule violates the Administrative Procedure Act by inserting non-statutory factors into funding determinations. Adding a political appointee review falls outside the factors Congress directed funding agencies to consider. Decisions that are not based on the statutorily relevant factors are arbitrary and capricious under Motor Vehicle Mfrs. Ass’n v. State Farm, 463 U.S. 29, 43 (1983).

Under the APA an agency also must consider reliance interests that it has engendered prior to changing course. FCC v. Fox Television Studios, 556 U.S. 502, 515 (2009). Grant denials and cancellations would upset substantial reliance interests by disrupting contracts with labs, equipment suppliers, faculty, graduate students and postdocs, and their institutions.

The politicized funding system as imagined by the proposal puts scientific progress at risk. When grants can be redirected or canceled based on shifting political priorities, critical research may never begin or may be halted before it delivers results. Over time, this weakens our ability to address major challenges like mitigating climate change, protecting public health, and assuring that our workforce is ready to meet the moment. The results will be a loss of continuity in fundamental and applied scientific work, setting back innovation, weakening U.S. leadership, and delaying science-based solutions that Americans urgently need.

This post co-authored with Glenda Valdez, Legal Fellow, Climate & Energy, Natural Resources Defense Council