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Comments of the National Academy of Medicine on OMB’s Proposal to Alter the Federal Grantmaking Process

Preserving America’s Capacity to Save and Improve Lives Through Science

The approach the United States has taken to funding biomedical and health research for more than seven decades rests on a straightforward premise: awards are chosen through rigorous, independent, competitive peer review, within priorities that elected leaders set through statute and appropriations. That approach has delivered enormous returns, including steep declines in deaths from cancer, heart disease, and infection; life-saving advances in transplantation, maternal and fetal care, and treatment of genetic and neurological disorders; and the promise of new cures through gene- and immune-based therapies. It has also sustained decades of U.S. leadership in science and innovation and driven nationwide economic growth.

The Office of Management and Budget’s (OMB’s) proposed rule, , threatens to fundamentally alter this proven system and compromise the ability of the American scientific enterprise to deliver ongoing benefits to taxpayers. Alongside the ½ûÂþÌìÌÃ, National Academy of Engineering, and hundreds of other aligned organizations, the National Academy of Medicine (NAM) submitted a formal public comments to OMB detailing concerns with key provisions and urging action to preserve the primacy of independent, merit-based review and sustain the scientific workforce that is vital to national competitiveness and security. A high-level summary of the comments appears below.

Access the NAM’s complete comments here: Comments of the National Academy of Medicine on the Proposed Rule, Regulation for Federal Financial Assistance

Summary

The NAM supports appropriate measures to ensure accountability and legal compliance in the use of federal research funds. However, several elements of the proposed rule would introduce uncertainty and potential bias into a system that depends on predictability and independence.

The rule would insert discretionary, non-technical review by political appointees ahead of funding decisions, potentially overriding objective processes designed to select the most meritorious projects to advance national priorities. It would expand agencies’ authority to terminate active, multi-year awards for non-scientific reasons, disrupting years-long clinical trials, research cohorts, and laboratory work that cannot simply be paused without harming the ability to achieve valid results and honor obligations to people who contribute to biomedical research by participating in clinical trials.

The rule could curtail the ability of scientific and medical organizations to convene independent experts and disseminate research findings free of political influence and could impede essential international scientific collaboration. It could also restrict legitimate scientific research that measures how health outcomes differ across communities, including research that is essential to serving rural, low-income, and chronically ill populations. Finally, the rule risks destabilizing support for fellowships, traineeships, and other mechanisms that sustain the pipeline of early-career scientists.

Such significant disruption could have economic and national security ramifications. U.S. investment in basic and applied research remains larger than that of any other nation, and it has helped drive many of the major scientific advances of the modern era, advances whose benefits have extended far beyond our borders. It allows the United States to help lead global conversations about public health, regulation, and scientific norms. The biomedical enterprise is also a pillar of our national security, supporting America’s biodefense and pandemic response.

The biomedical enterprise employs millions of Americans and anchors regional economies. It produces medicines that change people’s lives and allow them to be more productive. Sustaining this enterprise requires a scientific and engineering workforce commensurate with the size of our economy and the scale of our scientific aspirations. The enterprise took decades to build, and once it erodes, rebuilding it could take a generation.

The OMB’s proposed changes would add significantly to an already sizable burden on the workforce; for example, funding constraints and immigration policies introduced in 2025 and 2026 have already reduced, by the thousands, the number of next-generation scientists available to serve the nation. In this context, the NAM comment calls on OMB to demonstrate how its proposed changes will protect and enhance, rather than erode, the size and quality of the nation’s current and future scientific workforce.

The NAM welcomes the opportunity to work with OMB toward a final rule that advances transparency and accountability without compromising scientific integrity and innovation.

Media inquiries: Molly Galvin ([email protected])

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