The American Association of Immunologists submitted formal comments strongly opposing the White House Office of Management and Budget’s (OMB) proposed overhaul of federal grantmaking guidance, arguing that the changes would do great harm to the U.S. scientific enterprise. The comments echo concerns raised across the scientific community during a public comment period that resulted in nearly 500,000 submissions (according to regulations.gov), with an estimated 95% expressing opposition to the proposed rule. AAI urged immunologists to submit their own individual comments explaining how the proposed rule would harm them in advance of the July 13 deadline and provided resources and guidance to help them generate their responses.
Shifts Authority to Political Appointees
One of AAI’s strongest concerns centers on the proposal’s shift away from long-standing merit-based peer review toward review by unnamed political appointees. The proposed rule would allow political officials greater authority to review funding decisions and determine whether research aligns with presidential priorities, potentially overriding expert scientific judgment.
AAI argues that such changes would weaken the principles that have made federally-funded biomedical research successful for decades: independent peer review, scientific merit, and investigator-driven discovery.
Grants Made More Vulnerable
AAI also expressed concern about provisions that would make grant awards more vulnerable to termination after funding has already been awarded. The proposed rule would expand agency authority to end projects deemed inconsistent with changing agency priorities or the “national interest,” without justification. Awards terminated for these reasons would not be eligible for appeal. Such uncertainty could discourage innovative, long-term research efforts, and undermine the stability needed to pursue complex biomedical questions.
Additional issues highlighted by AAI include restrictions on international scientific collaboration, limitations on conference attendance and publication costs, and giving preference in funding decisions to institutions with lower indirect cost rates. The association warned that these provisions could impede scientific communication, reduce opportunities for collaboration and career development, and ultimately slow biomedical progress.
Process is Unusually Expedited
OMB is required to review and respond to original, substantive comments before finalizing the rule. This would be extremely difficult to accomplish given the unusually expedited timeline established by OMB, which proposes to issue a final rule that goes into effect by October 1, 2026.
Congressional intervention to postpone or block implementation of the rule remains a possibility. On July 2, all Senate Democrats sent a letter to OMB Director Russell Vought urging him to rescind the proposed regulation. Senator Susan Collins (R-ME), Chair of the Senate Appropriations Committee, separately called on Vought to extend the comment period on the proposed rule by 90 days and to “withdraw portions of the rule that would unduly burden scientific and biomedical research and small communities.” There has been some bipartisan opposition on the House side as well, with Congresswoman Laura Gillen (D-NY, 4th) and Congressman Brian Fitzpatrick (R-PA, 8th) co-leading a letter to Vought asking him to reconsider the proposed rule.
AAI continues to work closely with the broader scientific community and coalition partners to monitor developments and coordinate its response to this critically important issue.
