I took my name off this Substack URL and profile. But, rest assured, it’s still me. Let me explain.

Back in December 2025 when I started this Substack, I was writing about the NIH after having left my job as a Program Official for 22 years. I was (and am) still grieving and processing the loss of my career and also of the agency as I knew it. I began writing as a form of therapy and truth telling. I never imaged so many people would be interested in what I had to say.

On May 28, 2026 Russell Vought published his draft OMB rule, a rewrite of 2 CFR Part 200, the Uniform Guidance that has governed federal grants management for over a decade. I downloaded it immediately and began reading and highlighting the horrors contained within. The proposal would convert that guidance, which agencies have historically implemented with some flexibility, into binding regulation across every grantmaking agency in the federal government. It touches nearly $1.1 trillion in annual federal spending. The rule would formally hand political appointees’ authority to review and approve discretionary grants before they’re issued (2 CFR 200.205), expand agencies’ power to terminate or suspend grants already underway whenever a project no longer serves “agency priorities” (2 CFR 200.340), and let agencies weigh an applicant’s “institutional practices, affiliations and risk indicators,” in funding decisions (2 CFR 200.206) rather than financial and technical merit.

I was horrified. I knew this would be devastating to scientists who rely on NIH funding for their research. It’s why I wrote a Substack article titled “Summary of Key Changes in OMB’s Proposed Federal Financial Assistance Rule.” I was hoping to inform the people who needed to know. I never expected this essay to go viral and get 156,917 views.

Following publication of that OMB essay, I faced a deluge of emails and DMs across multiple social platforms. I was contacted by over 40 different journalist and by literally hundreds of people who want to talk to me, interview me, invite me on podcasts, and ask me all manner of technical questions about the OMB rule. I participated in about 12 different webinars to educate folks about the proposed rule and how to write an effective comment opposing it. This unwitting “fame” also led to me being invited to testify in a congressional hearing. If you’re new here and don’t know about it, then you can read more about that in this Substack essay. Between the OMB rule craziness and the congressional hearing, the flood gates opened. I began receiving hundreds of messages a day and even phone calls at my home. Some were violent and threatening, others were simply bizarre, and yes, many were positive. But it was all way too much for me. I never started this Substack with the idea of becoming famous. I never expected to have my life threatened.

This is why I have removed my name. It’s too late to put the toothpaste back in the tube, but I can try to minimize my footprint on the internet a bit. I am not making money on this venture. I receive no benefits. I still have been unable to find a full-time job after leaving the NIH over a year ago. My household finances are strained. My mental health is still not 100%. Having my name plastered all over social media created personal risks that I am unwilling to tolerate. I hope you understand.

I may continue to post about the NIH to the extent that it makes sense when I have something informative to offer beyond what you are hearing in the news. But I need to take a step back and take care of myself first. To all of you who have been encouraging and supportive, I thank you from the bottom of my heart.

On May 29, 2026, the Office of Management and Budget proposed a rewrite of 2 CFR Part 200, the Uniform Guidance that has governed federal grants management for over a decade. The proposal would convert that guidance, which agencies have historically implemented with some flexibility, into binding regulation across every grantmaking agency in the federal government. It touches nearly $1.1 trillion in annual federal spending. Comments are due July 13, 2026.

Rules of this size come with paperwork of their own. Executive Order 12866 requires agencies to prepare a Regulatory Impact Analysis for any “economically significant” rule, one likely to affect the economy by $100 million or more. The Regulatory Flexibility Act separately requires an assessment of how a rule will affect small entities: small nonprofits, small local governments, small businesses. Neither document is optional. Both are supposed to show that OMB looked closely at what its own rule would do before finalizing it. Both are available for download on the Federal Register page for this rule.

OMB’s Small Entity Analysis for this rule, filed in the public docket, states plainly: “OMB has not identified any Federal rules that duplicate, overlap, or conflict with the proposed rule.”

That statement is false, and the proof is sitting in NIH’s own guidance.

What the rule does

Buried in the proposed rule’s program design section, § 200.202(e), is a new eligibility restriction for research and development awards. Going forward, federal agencies generally may not issue R&D awards directly to a foreign entity. An exception exists only where a statute expressly authorizes it, or where the agency’s senior appointee determines a “compelling interest” justifies it. Foreign entities can still participate as subrecipients or contractors under an award to a U.S. institution. As a direct recipient of federal research money, they are presumptively out.

What NIH already did

Four months earlier, NIH had gone a different direction. NOT-OD-25-155, effective for applications due on or after January 25, 2026, eliminated the traditional foreign subaward structure. Under the old model, a U.S. institution held the prime award and passed a portion of the funds to its foreign collaborator as a subrecipient, one layer removed from NIH. Under the new model, that foreign collaborator gets pulled out of the application entirely and issued its own separate award, using activity codes RF2 or UL2. NIH’s own guidance describes the result without ambiguity: the award is “awarded directly to the foreign organization.” The foreign institution registers in SAM.gov and eRA Commons in its own name, receives its own Notice of Award, and reports its own finances directly to NIH.

NIH built this structure to solve a stated problem: the old subaward model gave the government limited visibility into how foreign partners used federal research dollars. The fix worked by making the foreign organization more visible, not less. It made them a direct party to the federal award relationship.

That is exactly the category § 200.202(e) restricts by default.

The collision

Put the two documents side by side and the conflict is not a matter of interpretation. NIH already requires that every foreign research collaborator become the direct recipient of a separate federal award. The OMB rule already presumes that direct federal R&D awards to foreign entities are prohibited unless a senior political appointee finds a compelling interest. Since the subaward option no longer exists at NIH, every international collaboration NIH funds now runs into a restriction the rule proposes to impose for the first time. What used to be a program officer’s routine decision would become a case-by-case political determination, for every foreign component of every NIH grant, with no acknowledgment anywhere in OMB’s paperwork that this is what would happen.

The Regulatory Impact Analysis rates the cost of § 200.202(e) as “minimal” and “primarily one-time.” It does not mention NOT-OD-25-155. The Small Entity Analysis says no conflicting rules were identified. It does not mention NOT-OD-25-155 either. Both documents were prepared by the same office responsible for coordinating with NIH in the first place; the interagency coordination that produced this rule was supposed to catch exactly this kind of conflict before publication.

There is a methodological reason the gap may have gone unnoticed, and it does not make the omission better. The RIA’s own data appendix states that the underlying analysis excluded foreign recipients: “Individuals and Foreign Recipients – Removed from analysis.” The population directly affected by the collision between § 200.202(e) and NIH’s new award structure was removed from the dataset before OMB ever looked for conflicts. An analysis built this way was not positioned to find the problem, regardless of how carefully anyone read the resulting numbers.

Why this matters beyond one footnote

Agencies are required to engage in reasoned decision-making, and courts reviewing a challenge to a final rule can examine an agency’s own analysis as evidence of whether that standard was met. An impact analysis that overlooks a demonstrable conflict with another agency’s binding guidance, issued four months earlier, on the exact topic the analysis claims to have checked, is difficult to defend as reasoned. It does not require speculation about intent to make this point. The comparison is available to anyone willing to read both documents.

This matters beyond any one office’s compliance calendar. A scientist with a foreign collaborator, a research administrator trying to plan around this rule, a member of the public who simply wants federal science policy made carefully: none of them can afford to wait for OMB to notice the conflict on its own. The public comment record is the mechanism built for exactly this purpose, to put in front of the agency the facts its own process missed. This one is documented, dated, and drawn entirely from the government’s own words.

Here’s What YOU need to do

Comment against the OMB rule: Deadline: July 13, 2026 at 11:59 PM Eastern

https://www.regulations.gov/commenton/OMB-2026-0034-0001

Call your representatives. Email your representatives.

They can take action against this through a joint resolution that can be added to appropriations bills or stand alone. However; a joint resolution would need to pass both houses.

More resources and tools:

Stand up for Science Action page: https://fight2win.standupforscience.net/

My substack articles:

· How to write a comment on the Federal Register - https://elizabethginexi.substack.com/p/what-we-need-to-do-next-ombs-proposed

· Summary of Key Changes in OMB’s Proposed Federal Financial Assistance Rule -https://elizabethginexi.substack.com/p/summary-of-key-changes-in-ombs-proposed

· A Rule Nobody Voted On Could Cut Federal Funding to Your Community -https://elizabethginexi.substack.com/p/a-rule-nobody-voted-on-could-cut

· This new OMB Rule Is Bigger Than Science. Much Bigger. -https://elizabethginexi.substack.com/p/this-new-omb-rule-is-bigger-than

On June 30, 2026, I sat at a witness table, under oath, in the Rayburn House Office Building in Washington, DC and testified before the House Oversight Committee’s Task Force on the Declassification of Federal Secrets. The hearing was titled “Mind Control and Accountability: Uncovering the Truth of the CIA’s MKULTRA Project.”

How I Got There

MKUltra was a CIA program, and its crimes were real. Between 1953 and 1973, the CIA used hundreds of scientists to conduct at least 149 research subprojects at more than 80 institutions, dosing unwitting subjects with LSD, subjecting people to electroshock and sensory deprivation, and destroying the records when investigators came looking. It was a genuine scandal, exposed in the mid-1970s by the Church Committee, and the people harmed by it deserved a reckoning that never fully came.

What it was not, in June 2026, was urgent. The program ended more than 50 years ago. Its records were largely destroyed. There is no credible new evidence and no pending legislation. One of the experts who testified alongside me said as much from the witness table.

So why was Congress holding a hearing on it now? And why was I a witness?

The answer has less to do with the past than with the present.

The Democratic minority called me to testify under the House minority witness rule. The plan was straightforward: while Republicans staged a sham hearing on ancient CIA history, Democrats would use their witness slot to put an actual crisis in front of the committee — the dismantling of NIH happening right now, on this Congress’s watch, with this administration’s blessing. Rep. Jasmine Crockett of Texas was supposed to be there to anchor that counter-message and ask me questions that would let the case unfold on the record. Unfortunately, that morning when I arrived for the hearing, I learned that Ms. Crockett would not attend on account of illness. The other Democratic members were unavailable. I was on my own.

One more thing worth understanding about the structure of this hearing: it was convened as a “task force,” not a full committee proceeding. This is not a technical distinction without a difference. A House committee hearing is an official proceeding with subpoena authority. A task force is a temporary group that generally cannot compel testimony or documents. Republicans have increasingly shifted to task force hearings because Democratic members were having too much success getting subpoenas approved in full committee proceedings. Make of that what you will.

The Other Two Witnesses

I was not the only witness. The Republican majority brought in two others: Stephen Kinzer, Senior Fellow in International and Public Affairs at Brown University and author of a book on Sidney Gottlieb, the CIA official who directed MKUltra; and Tom O’Neill, an investigative journalist whose book links Charles Manson to CIA operations.

One is a researcher and the other is a journalist; both made careers writing about sensational historical crimes. But watching how their testimony was used in that room made clear that getting to the bottom of MKUltra was not the point.

To be fair, O’Neill’s written testimony made a legitimate historical case that deserved serious attention. He presented documents showing that in 1977, Congress was told MKUltra produced no usable technology — and that the CIA altered records before handing them over to conceal evidence that West had in fact achieved the program’s core objective: implanting false memories in unwitting subjects. That is a genuine, documented deception of Congress. It may warrant a serious hearing. What followed in the hearing room was not a serious hearing.

What unfolded instead was unhinged MAGA conspiracy theater designed to appeal to their base and create fake news clips to sow distrust in our government.

For example, Rep. Tim Burchett of Tennessee asked Kinzer whether mind control technology could have been used to program “loners” to attempt current assassinations — specifically referencing the Butler, Pennsylvania shooting targeting President Trump and the killing of Charlie Kirk. Kinzer said he hated to speculate, then speculated: he said the CIA had “developed means that we’ve never been told about many, many years ago” and imagined they had “evolved to be much more effective now.” Burchett then mused, without any evidence, that “they” could cast a broad algorithmic net knowing it would cause someone to act violently, while maintaining plausible deniability.

Rep. Lauren Boebert invoked Operation Mockingbird — a real Cold War-era CIA media infiltration program — alongside “radio waves” and “directed energy weapons,” weaving them into a single theory of ongoing government mind control. O’Neill obliged her by suggesting Mockingbird-style propaganda “is still going on today.”

Rep. Burleson asked O’Neill at length about Charles Manson as a possible CIA asset. O’Neill walked through his theory that a federal parole officer overseeing Manson was simultaneously running a drug research project and that Manson’s escalating crimes were enabled, perhaps deliberately, by federal supervision. Luna concluded the hearing by asking O’Neill directly: were Manson and Jack Ruby MKUltra victims? O’Neill said he believed Jack Ruby was, and suggested that Jolly West — a CIA-connected psychiatrist — had been placed in Ruby’s orbit to prevent him from telling his story about the Kennedy assassination.

None of this was accompanied by new evidence. Most of it was, by the witnesses’ own admission, pure speculation. But that was not the full problem.

The problem was the architecture. Every exchange followed the same pattern: a real historical crime by a federal agency was presented, a speculative extension into the present day was invited, and the conclusion left hanging in the room was that federal agencies have always been corrupt, have always lied, and cannot be trusted even today. The specific agencies varied — CIA, NIH, NIAID, USAID — but the target was the same: the legitimacy of federal institutions.

The Moment That Said Everything

In the middle of all this, something remarkable happened. O’Neill, in response to Boebert’s question about modern mind control, said this:

“Maybe radio waves and drugs are not necessary to control people’s minds. We have such a great advertising propaganda press. Social media. Collaboration that certain opinions are marginalized and real debate is frustrated because people are not given access to full amounts of information. That’s a way of controlling the minds of populations. It doesn’t even require sophisticated electronic or psychopharmacological means.”

He was right. And he appeared not to notice what he had just described.

The most effective mind control program operating in America today does not use LSD or electroshock. It uses Fox News, NewsMax, the Washington Examiner, Facebook, TikTok, etc. with a team of coordinated conservative media companies to tell people that government is corrupt, that scientists lie, that vaccines kill, and that the only trustworthy authority is the one telling you not to trust any authority. The people running this hearing know how to use it. They use this program of echo chamber mind-control disinformation every day.

What Crane and Mace did to me at that table — accusing me of covering up a pandemic, of defending an agency that killed Americans with vaccines, of being “tone deaf” to what “the public” believes — was not a search for truth. It was a performance for an audience that had already been prepared to receive it. When the room applauded Crane, it was not because he had made a compelling argument. It was because they packed the room with true believers and the preparation had worked.

Kinzer, in a different moment, described how the FBI didn’t pull the trigger on Martin Luther King but created a climate in which someone would. I found myself thinking about that observation for the rest of the day. These hearings do not need to directly dismantle NIH. They only need to build the climate in which dismantling the agency and firing civil servants feels like justice.

What Happened When They Turned to Me

I went in with one intention: say what needed to be said about the current deliberate dismantling of NIH and to not take the bait on anything else. I was not there in good faith on their terms. They were not acting in good faith on mine. I also had no backup. I was on my own. The only thing I could control was what I said and how I said it.

Chairwoman Luna cut off my opening statement before my five minutes were up. The other two witnesses were allowed to run longer.

Rep. Eli Crane of Arizona came directly at me. He reframed my testimony as “your issues with this administration’s attempt to reform and rein in the NIH.” I corrected him: “My opening statement was talking about the destruction of the NIH and cancellation of grants and political control of the NIH.”

He moved immediately to the debunked Wuhan lab leak theory, asking whether I would deny that NIH had been involved in funding it. I told him I had no knowledge of any such funding, and that I was there to talk about what is happening at NIH right now — “how we really should be letting science be driven by scientists and not by politicians. That’s how we fund cures and make health progress.”

He pushed back, telling me that “for years we were told to trust the science, and then in the aftermath, we’ve all found out that most of what we were told during COVID was a complete lie, and it wasn’t scientific at all.”

I redirected:

“The number one thing that I think that we’re doing to destroy trust in American science right now is canceling clinical trials in the middle of those clinical trials. This does incredible harm to the patients who are receiving experimental treatments, and it really destroys the trust that we have in how do we recruit patients for future trials if they are knowing that their trials could just be simply canceled for political reasons.”

He then pivoted to ask whether I thought NIH had a trust problem based on how it handled COVID.

This is their go-to talking point. Keep in mind: declines in trust for NIH have been driven largely by the GOP disinformation campaigns on Fox News about COVID. Confidence in the NIH to provide trustworthy public health information dropped to 62% in a recent Annenberg Public Policy Center survey. This is a decline from 75% in 2024. These lies are purposefully designed to sow distrust so that they can cite the drop in trust as a reason to dismantle the agency. That’s the scheme.

But they have to repeat these lies and hold sham hearings like this one because their efforts are never fully successful. Sixty two percent of Americans trust NIH, and general support for biomedical research remains strong. Recent polls by Research!America show 92% of Americans support basic scientific research. A separate survey by the American Association for Cancer Research found that 77% of voters want their lawmakers to increase funding for the NIH and its branches.

In my reply to his question about a trust problem, I told Crane:

“No, I do not. I think that the NIH is beloved by the American people because we know about the advances in human health and cancer treatments and heart disease and diabetes and all of the health gains that the research has produced.”

The polling data are on my side. But he told me I was wrong, that the public had a “serious mistrust issue” with NIH. And then he asked whether I denied that NIH tried to cover up the origins of COVID, and he also asked about covering up harmful vaccine side effects and about masking and social distancing. His tactic is to rile up the hand-picked hearing room audience with scary disinformation designed to trigger them to applaud thereby creating a magic moment ripe for a TikTok video vilifying a former NIH scientist. He has a well-funded right-wing organization called “Real America’s Voice” who creates the video and makes it go viral with hateful trolls commenting and spreading the message.

This is the playbook. It’s a mind-control media operation. Repeat the disinformation and lies and accuse scientists and government agencies of killing people. Generate suspicion and outrage based on fantastical lies. That way, when Russell Vought cancels the budgets for all of these federal agencies including the NIH, the MAGA supporters will cheer.

I stuck to my story, based in truth and facts. I told Crane that what concerns me most is what is happening right now: “We’re ceding our leadership in biomedical research to China.”

Rep. Nancy Mace of South Carolina followed. She asked whether I had spoken with Anthony Fauci or any NIH colleagues about NIH’s role in funding the Wuhan Institute of Virology or the development of COVID-19. No. Did I believe NIH or Dr. Fauci lied to the American people about COVID? No. Was I familiar with Dr. Fauci’s statements to Congress? No. Did I think COVID shots harm American citizens? No. Did they cause turbo cancers? No. Then: “Why did the Dems send you here?”

I told her: “I am here to testify about what is happening to the NIH right now.” And when she pressed that I was not an MKUltra expert, I pointed out that I am an expert in human subjects protection, a topic that is directly relevant to a hearing nominally about research ethics conducted on human subjects.

I did not go along with any of it. I was not going to.

What the Science Actually Says

The claims Crane and Mace made at that table were not ambiguous. They deserve direct responses.

On mRNA vaccines:

A comprehensive review published this month in The Lancet, drawing on six years of data from laboratory science, clinical trials, and real-world surveillance of billions of doses, concludes that mRNA vaccines are safe and highly effective. One analysis found 87 percent effectiveness against documented COVID infection and 94 percent effectiveness against death. Serious adverse events are exceedingly rare. The technology does not integrate into human DNA. It clears rapidly. There is no evidence that mRNA vaccines cause cancer. There is no evidence they caused excess deaths. These are not contested scientific questions. They are disinformation points that have been examined and rejected by the evidence.

On NIH and COVID origins:

I was asked repeatedly whether NIH funded research that caused a lab leak and whether I had personal knowledge of a cover-up involving Dr. Fauci. The answer to both is no. I had no involvement in that area of NIH’s work, and I have no such knowledge. But more importantly, these accusations represent wholly debunked conspiracy theories full of disinformation. The majority of virologists and epidemiologists who have examined the question conclude that the available evidence favors a natural spillover origin — a virus jumping from animals to humans, as has happened with every major pandemic in recorded history. No credible evidence links NIH-funded research to the emergence of SARS-CoV-2. The claim that NIH or anyone in government covered up anything is pure nonsense. And it is very dangerous. This rhetoric puts the lives and livelihoods of scientists like Dr. Fauci and others who study virology in peril.

These are terrifying lies that Republicans are using to manipulate people’s opinions about NIH.

What Came After

Since the hearing, I received a threatening comment accusing me of lying to Congress, claiming that a social psychologist is not a scientist, and repeating the false accusations about Fauci and Wuhan. I received other strange messages about CIA conspiracy theories, and musings linked to the “Stranger Things” and MKUltra fandom community. Bizarre stuff.

I will not be intimidated. I have truth and integrity on my side. What was deployed against me in that hearing room was not argument. It was the same theater and lies that have been deployed since 2020. It did not work at the witness table. It will not work here.

A staffer told me afterward that anyone serious knows Eli Crane is not a serious legislator, and that Rep. Crockett’s absence left me on an island. They said I did as well as anyone could have. I believe that. Getting the truth into the record, even in a hearing not designed to receive it, was still worth doing.

Why It Matters

The hearing was absurd. But what it represented is not.

Building public distrust in federal science is not incidental to the project of dismantling it. It is the precondition. If people believe NIH caused a pandemic, covered it up, and poisoned them with vaccines, then canceling NIH grants is not cruelty. It is accountability. The MKUltra history, real and genuinely disturbing, is useful for Republicans because it provides a foundation of documented government wrongdoing from which any further accusation can be launched. You don’t have to prove the new claim. You only have to make it feel plausible.

None of what Crane and Mace said about me or about NIH is true. But as O’Neill himself observed, you don’t need sophisticated technology to control what people believe. You just need a media apparatus willing to repeat the lie and an audience that has already been told not to trust anyone who contradicts it.

I went to Congress with no illusions about what I would find. I found exactly what I expected. And I said what I went there to say.

If no one stands up to the lies. The lies will win. So, I stood up for truth and science.

Right now, the Trump administration and Congressional Republicans are purposefully dismantling the NIH and all the other science agencies. Over 80 years, the US built the most productive publicly funded biomedical research enterprise in human history. The health and economic returns are documented, specific, and large. The speed of the current dismantling is breathtaking.

If you care about future cures for cancer, Alzheimer’s, diabetes, and infectious diseases, you need to speak up now before it’s gone.

The day after the hearing, the Washington Post published an op-ed by Scott Atlas, a former Trump COVID adviser and Hoover Institution fellow who was widely criticized by public health experts during that period for advising against mask mandates and supporting herd immunity strategies that would kill millions. His op-ed is titled “Abolish the NIH. It Really Would Benefit Science.” The piece invokes libertarian economist Milton Friedman, accuses NIH of fiscal abuse, ideological capture, and suppression of scientific dissent, and concludes that private philanthropy and venture capital can replace everything NIH does. It is a more polished version of what Crane and Mace were performing at the MKUltra hearing.

Atlas cites checkpoint inhibitors and semaglutide as examples of private-sector success without mentioning that both depended on decades of NIH-funded basic science those companies did not pay for and would not have funded. He argues that every administration has politicized NIH without acknowledging that the Trump administration canceling 5,100 grants worth $4.4 billion in a single year is most certainly not a point on a continuum of “both sides do it.” The MKUltra hearing was the emotional performance. The Atlas op-ed is the intellectual scaffolding. Together they are doing the same hit job. I have addressed the conservative argument against the NIH in an earlier essay which I encourage you to read. The short version: the arguments against NIH funding rest on a fundamental and deliberate misrepresentation of how science infrastructure works and what happens when you destroy it.

Here’s What YOU need to do

Comment against the OMB rule: Deadline: July 13, 2026 at 11:59 PM Eastern

https://www.regulations.gov/commenton/OMB-2026-0034-0001

Call your representatives. Email your representatives.

They can take action against this through a joint resolution that can be added to appropriations bills or stand alone. However; a joint resolution would need to pass both houses.

More resources and tools:

Stand up for Science Action page: https://fight2win.standupforscience.net/

My substack articles:

· How to write a comment on the Federal Register - https://elizabethginexi.substack.com/p/what-we-need-to-do-next-ombs-proposed

· Summary of Key Changes in OMB’s Proposed Federal Financial Assistance Rule -https://elizabethginexi.substack.com/p/summary-of-key-changes-in-ombs-proposed

· A Rule Nobody Voted On Could Cut Federal Funding to Your Community -https://elizabethginexi.substack.com/p/a-rule-nobody-voted-on-could-cut

· This new OMB Rule Is Bigger Than Science. Much Bigger. -https://elizabethginexi.substack.com/p/this-new-omb-rule-is-bigger-than

For the past eighteen months, the Trump administration’s approach to federal grants has followed a familiar pattern: announce a cancellation, face a lawsuit, sometimes lose. The table below, built from a year-plus of news coverage since Trump took office in January 2025, documents the result: thousands of grants frozen or terminated across more than a dozen agencies, courts intervening (and often siding against the administration) in case after case after case.

That pattern is precisely what OMB’s proposed rewrite of 2 CFR Part 200 is designed to end.

The current rule (the “uniform grants guidance” that has governed how federal agencies award and manage grants for over a decade) has been a legal vulnerability the administration kept tripping over. Judges have repeatedly found that abrupt terminations violated the Administrative Procedure Act, exceeded statutory authority, or were retaliatory rather than merit-based. OMB’s new proposal doesn’t abandon that strategy; it tries to make it bulletproof. As Governing’s Jed Herrmann lays out, the rule would formally hand political appointees authority to review and approve discretionary grants before they’re issued (2 CFR 200.205), expand agencies’ power to terminate or suspend grants already underway whenever a project no longer serves “agency priorities” (2 CFR 200.340), and let agencies weigh an applicant’s “institutional practices, affiliations and risk indicators,” in funding decisions (2 CFR 200.206) rather than financial and technical merit.

In plain terms: every cancellation in the table below that currently risks a court loss because it skipped notice-and-comment, ignored statutory authorization, or substituted political judgment for technical review could become the new normal if this proposed rule goes into effect. The rule is written so that the cuts will now be allowed under binding regulation rather than imposed through ad hoc directives that lawyers can challenge.

The scientific community has taken particular notice. As CNN’s Ella Nilsen and Andrew Freedman reported, the proposal would also gut the peer-review system that has underpinned federal research funding since World War II, replacing scientific merit review with political sign-off, and would categorically bar research touching DEI or gender topics. I’m quoted in that piece. I’ve spent the public comment period trying to mobilize scientists and the public to flood OMB’s docket, because by law they have to read and respond to every comment submitted, and it will help us to wake up Congress. As I told CNN, the question this rule ultimately asks is blunt: who should decide whether a cancer clinical trial is scientifically sound — the oncologists and physicians reviewing it, or Russell Vought?

The table that follows isn’t just a record of what’s already happened over the past year. It’s a preview of what will become routine, lawful, and potentially harder to challenge in court if this rule is finalized. The public comment period is open now. Your voice counts. Let’s get the comments up to 1 million opposed. Also, very important: in addition to logging a comment, you must contact your elected officials in Washington, DC and tell them to block this new OBM rule. Congress has the power to stop this. If they don’t block it, the results will be disastrous.

TAKE ACTION:

Submit a Comment to Oppose the rule! https://elizabethginexi.substack.com/p/what-we-need-to-do-next-ombs-proposed

Call your Elected Officials! https://5calls.org/issue/federal-financial-assistance-science-grants/

Email your Elected Officials! https://ujoin.co/campaigns/4287/actions/public?action_id=6970

Trump Administration Grant Cancellations by Federal Agency

Compiled from news reports and policy analyses through June 2026. Dollar amounts and grant counts reflect reported figures; actual totals may be higher. Court actions reflect rulings reported in source materials.

Budget Areas Substantially Increased by the Trump Administration

While the cancellations documented above affect dozens of agencies and programs, the increases below, particularly the military and ICE, are of a magnitude that dwarfs the cuts in aggregate. The proposed defense budget increase alone (~$500B) exceeds the total of all documented grant cancellations combined (estimated at roughly $20–30B across all agencies). ICE’s new $85B budget alone exceeds most of the cut programs by orders of magnitude. In short, the federal government is not getting smaller; it is being radically restructured, with massive transfers from domestic, scientific, environmental, and social programs to defense, immigration enforcement, and ideologically aligned priorities.

References

Department of Education

Fittes, E. K. (2025, May 22). Digital equity grants landed on Trump’s chopping block: Here’s why the K-12 market is watching. EdWeek Market Brief. https://marketbrief.edweek.org/regulation-policy/digital-equity-grants-landed-on-trumps-chopping-block-heres-why-the-k-12-market-is-watching/2025/05

Lieberman, M. (2025, September 8). Trump canceled millions for special education teacher training: What’s next? Education Week. https://www.edweek.org/teaching-learning/trump-canceled-millions-for-special-education-teacher-training-whats-next/2025/09

Education Week. (2025, September). Trump admin cancels dozens more grants, hitting civics, arts and higher ed. Education Week. https://www.edweek.org/policy-politics/trump-admin-cancels-dozens-more-grants-hitting-civics-arts-and-higher-ed/2025/09

Education Week. (2026, January). Trump slashed billions for education in 2025: See our list of affected grants. Education Week. https://www.edweek.org/policy-politics/trump-slashed-billions-for-education-in-2025-see-our-list-of-affected-grants/2026/01

Education Week. (2021, November). The infrastructure bill includes billions for broadband: What it would mean for students. Education Week. https://www.edweek.org/technology/the-infrastructure-bill-includes-billions-for-broadband-what-it-would-mean-for-students/2021/11

Associated Press. (2025, July 31). A look at colleges with federal money targeted by the Trump administration. WHYY. https://whyy.org/articles/trump-administration-universities-federal-money-targeted/

Department of Justice

Solomon, A., & Pearl, B. (2025, May). DOJ funding update: A deeper look at the cuts. Council on Criminal Justice. https://counciloncj.org/doj-funding-update-a-deeper-look-at-the-cuts/

American Progress. (n.d.). The Trump administration’s unprecedented cuts to DOJ grants undermine public safety. Center for American Progress. https://www.americanprogress.org/article/the-trump-administrations-unprecedented-cuts-to-doj-grants-undermine-public-safety/

U.S. Agency for International Development (USAID)

The Guardian. (2025, August 29). Trump bypasses Congress to cancel $4.9bn in foreign aid. The Guardian. https://www.theguardian.com/us-news/2025/aug/29/trump-pocket-rescission-foreign-aid-funding

Department of Energy

Farah, N. H., & Marshall, C. (2026, June 15). Court reinstates DOE grant funding in blue states. E&E News. https://www.eenews.net/articles/court-reinstates-doe-grant-funding-in-blue-states/

Heller, M. (2026, April 1). Trump’s opposition to renewables stalls rural energy grants. E&E News. https://www.eenews.net/articles/trumps-opposition-to-renewables-stalls-rural-energy-grants/

U.S. Department of Agriculture

Horn-Muller, A., & Gilpin, L. (2025, August 6). Following the USDA’s food and farm funding: Here’s what’s been canceled and frozen, and resources for those affected. Grist. https://grist.org/food-and-agriculture/following-the-usda-food-and-farm-funding/

Urban Sustainability Directors Network. (2025, June 5). USDA grantees sue Trump administration to stop illegal grant terminations [Press release]. https://www.usdn.org/projects/news-release-usda-grantees-sue-trump-administration-to-stop-illegal-grant-terminations.html

U.S. Department of Agriculture. (2025, April 14). USDA cancels Biden-era climate slush fund, reprioritizes existing funding for farmers [Press release]. https://www.usda.gov/about-usda/news/press-releases/2025/04/14/usda-cancels-biden-era-climate-slush-fund-reprioritizes-existing-funding-farmers

U.S. Department of Agriculture. (2025, July 15). Secretary Rollins terminates COVID-era program [Press release]. https://www.usda.gov/about-usda/news/press-releases/2025/07/15/secretary-rollins-terminates-covid-era-program

U.S. Department of Agriculture. (2025, September 10). Secretary Rollins announces reinvigorated Farm to School grants supporting American farmers and students [Press release]. https://www.usda.gov/about-usda/news/press-releases/2025/09/10/secretary-rollins-announces-reinvigorated-farm-school-grants-supporting-american-farmers-and

Environmental Protection Agency

Jones, E. (2025, June 2). Trump cuts hundreds of EPA grants, leaving cities on the hook for climate resiliency. Grist. https://grist.org/cities/trump-cuts-hundreds-of-epa-grants-leaving-cities-on-the-hook-for-climate-resiliency/

Joselow, M., & Ajasa, A. (2025, April 29). The EPA is canceling almost 800 environmental justice grants, court filing reveals. The Washington Post. https://www.washingtonpost.com/climate-environment/2025/04/29/epa-environmental-justice-grants-canceled/

Southern Environmental Law Center. (2026, June 12). Victory: Federal court rules Trump admin’s grant terminations were illegal [Press release]. https://www.selc.org/news/victory-federal-court-rules-trump-admins-grant-terminations-were-illegal/

The Washington Post. (2025, February 6). Environmental justice offices face turmoil under Trump. The Washington Post. https://www.washingtonpost.com/climate-environment/2025/02/06/environmental-justice-offices-trump-turmoil/

The Washington Post. (2025, March 25). EPA environment grants face wrongful termination challenges. The Washington Post. https://www.washingtonpost.com/climate-environment/2025/03/25/epa-environment-grants-wrongful-termination/

The Washington Post. (2025, April 22). EPA staff cuts target environmental justice, DEI employees. The Washington Post. https://www.washingtonpost.com/climate-environment/2025/04/22/epa-staff-cuts-environmental-justice-dei/

FEMA / Disaster Preparedness

Hersher, R. (2026, March 30). Trump administration cuts turned rural towns into sitting ducks for disasters. NPR. https://www.npr.org/2026/03/30/nx-s1-5753765/fema-trump-extreme-weather-rural-pennsylvania

NPR. (2025, May 1). Trump disaster funding cuts: FEMA BRIC. NPR. https://www.npr.org/2025/05/01/nx-s1-5359452/trump-disaster-funding-cuts-fema-bric

NPR. (2026, January 16). FEMA cuts jobs under Trump. NPR. https://www.npr.org/2026/01/16/nx-s1-5677605/fema-cuts-jobs-trump

NPR. (2026, February 17). FEMA reform under Trump: Hurricane and earthquake preparedness at risk. NPR. https://www.npr.org/2026/02/17/nx-s1-5698320/fema-reform-trump-hurricane-earthquake

FEMA. (2026, March 25). FEMA announces $1 billion in federal funding to help states mitigate impact of disasters [Press release]. https://www.fema.gov/press-release/20260325/fema-announces-1-billion-federal-funding-help-states-mitigate-impact

Department of Transportation

Frazin, R. (2026, February 5). Trump administration directs rescission of $1.5B from blue states on health, transportation. The Hill. https://thehill.com/policy/energy-environment/5725217-trump-blue-states-funding-minnesota-colorado-evs-hiv/

Associated Press. (2025, August 29). Trump administration cancels $679 million in funding for offshore wind projects. PBS NewsHour. https://www.pbs.org/newshour/politics/trump-administration-cancels-679-million-in-funding-for-offshore-wind-projects

Massachusetts Department of Transportation. (2025, August 22). President Trump cancels $32 million in funding for transportation construction materials for Massachusetts [Press release]. https://www.mass.gov/news/president-trump-cancels-32-million-in-funding-for-transportation-construction-materials-for-massachusetts

Nieves, A. (2025, November 4). Judge rules Trump administration can’t tie transportation funding to immigration. Politico. https://www.politico.com/news/2025/11/04/judge-rules-trump-administration-cant-tie-transportation-funding-to-immigration-00635218

The Hill. (2025). Court orders Trump to reinstate a portion of energy funds. The Hill. https://thehill.com/policy/energy-environment/5685418-federal-court-rules-against-trump/

The Hill. (2026). Federal court orders EV electric vehicle charger funding unfrozen. The Hill. https://thehill.com/policy/energy-environment/5706538-ev-electric-vehicle-charger-funding/

NASA

Hsu, J. (2025, April 1). NASA cut $420 million for climate science, moon modelling and more. New Scientist. https://www.newscientist.com/article/2474255-nasa-cut-420-million-for-climate-science-moon-modelling-and-more/

NIH, NSF, and Federal Science Funding

Kozlov, M., Tollefson, J., & Garisto, D. (2026, January 22). US science after a year of Trump. Nature, 649, 812–815. (Grant-data visualization by K. Albrecht.) https://www.nature.com/immersive/d41586-026-00088-9/index.html

Facher, L. (2026, January 14). Trump administration cuts up to $1.9 billion from mental health and addiction treatment programs. STAT. https://www.statnews.com/2026/01/14/samhsa-grant-cancellations-align-with-agency-priorities/

Tollefson, J., Garisto, D., & Ledford, H. (2025, April 29). Will US science survive Trump 2.0? Nature. https://www.nature.com/articles/d41586-025-01257-6

Science.org. (n.d.). Supreme Court upholds Trump cancellation of NIH grants. Science. https://www.science.org/content/article/supreme-court-upholds-trump-cancellation-nih-grants

Brennan Center for Justice. (2026, May 14). The cost of the Trump administration’s attacks on research funding. https://www.brennancenter.org/our-work/research-reports/cost-trump-administrations-attacks-research-funding

National Education Association. (n.d.). Trump cancels federal research grants: What are the consequences? NEA Today. https://www.nea.org/nea-today/all-news-articles/trump-cancels-federal-research-grants-what-are-consequences

Washington Post. (2026, April 19). Science research funding cuts under Trump. The Washington Post. https://www.washingtonpost.com/science/2026/04/19/science-research-funding-cuts-trump/

FactCheck.org. (2025, May). RFK Jr. denies cuts to scientific research while slashing staff and funding. FactCheck.org. https://www.factcheck.org/2025/05/rfk-jr-denies-cuts-to-scientific-research-while-slashing-staff-funding/

FedInventory. (n.d.). HHS published a list of canceled grants [Substack post]. FedInventory.

National Endowment for the Arts

Veltman, C. (2025, May 3). Sweeping cuts hit NEA after Trump administration calls to eliminate the agency. NPR. https://www.npr.org/2025/05/03/nx-s1-sweeping-cuts-nea

National Endowment for the Humanities

Ables, K., & Kingsberry, J. (2026, May 9). The DOGE-ing of the humanities is being reversed. The Atlantic. https://www.theatlantic.com/culture/archive/2026/05/neh-doge-humanities-court-ruling/

HHS, Child Care, and Social Services Block Grants

Perchick, M. (2026, January 1). Child care payments on pause in all states following alleged fraud in Minnesota, US DHHS says. ABC11/WTVD. https://abc11.com/post/child-care-payments-50-states-paused-alleged-fraud-minnesota-us-department-health-human-services-says/18339437/

Gwyn, N. (2026, January 23). Trump administration’s five-state funding freeze is unlawful, harmful, and a major threat to people in every state. Center on Budget and Policy Priorities. https://www.cbpp.org/research/federal-budget/trump-administrations-five-state-funding-freeze-is-unlawful-harmful-and-a

Primus, W., & Siniakovas, R. (2025, May 8). The Social Services Block Grant provides critical services to low-income families—and has already been cut substantially. Brookings Institution. https://www.brookings.edu/articles/the-social-services-block-grant-provides-critical-services-to-low-income-families-and-has-already-been-cut-substantially/

Tully-McManus, K., & Scholtes, J. (2026, April 16). GOP, Democrats blast Vought for holding back cash: ‘You don’t have the authority to impound.’ Politico. https://www.politico.com/live-updates/2026/04/16/congress/vought-slammed-on-impoundment-00877112

Simmons-Duffin, S. (2026, February 13). A familiar move with a new twist: Trump tries to cut CDC funds he just signed into law. NPR. https://www.npr.org/2026/02/13/nx-s1-cdc-grants-blue-states

Defense Spending and ICE Budget Increases

Freking, K. (2026, April 16). Trump’s budget director defends White House plan for massive boost in military spending. Federal News Network / Associated Press. https://federalnewsnetwork.com/budget/2026/04/trumps-budget-director-defends-white-house-plan-for-massive-boost-in-military-spending/

Chappell, B. (2026, January 21). How ICE grew to be the highest-funded U.S. law enforcement agency. NPR. https://www.npr.org/2026/01/21/nx-s1-5674887/ice-budget-funding-congress-trump

Data Tracking and Aggregator Sources

GrantExec. (n.d.). Federal grant cancellations [Data dashboard]. https://grantexec.com/data/federal-grant-cancellations

Grant Witness. (n.d.). Federal grant tracking [Data dashboard].

https://grant-witness.us/

Center for American Progress. (n.d.). Mapping federal funding cuts to U.S. colleges and universities. https://www.americanprogress.org/article/mapping-federal-funding-cuts-to-us-colleges-and-universities/

You do NOT need to write a comment as detailed as mine. Please write based on your perspective and based on your life experiences. That is what I have done. This comment represents my viewpoints and my extensive scientific research career.

First, here is what I wrote in the Comment text box:

I am submitting this comment in strong opposition to the proposed revisions to 2 CFR Part 200 (Docket OMB-2026-0034). My full comment, with detailed analysis and supporting citations to legal authorities, scientific literature, and policy documents, is attached as a PDF document.

I write as a concerned citizen, a scientist with more than 30 years of research experience, and a former NIH Scientific Program Official who spent 22 years managing a portfolio of federal grants totaling hundreds of millions of dollars across multiple institutes and centers. I left NIH in April 2025 because I witnessed firsthand the replacement of a scientifically driven system with one that is politically directed, in ways I believe violate the Public Health Service Act of 1944. As a former federal employee who took the oath of office required by 5 U.S.C. §3331, I understood that oath to include an obligation to speak when federal actions conflict with the Constitution and the laws under which I served. This comment is submitted in that spirit.

This proposed rule is not a grants management reform. It is the most consequential attack on American science and on the integrity of federal grantmaking in the postwar era. It would place political appointees above scientific peer reviewers in every grant funding decision, allow any active grant to be terminated mid-project for undefined political reasons, prohibit international scientific collaboration, ban journal subscriptions and publication costs that have been allowable for over fifty years, and require that every federal grant program align with the current administration’s political priorities rather than with scientific need or congressional mandate.

Critically, this rule does not govern only science grants. It governs every federal grant from every agency, totaling approximately $1.1 trillion annually. Grant funding at risk includes money for state health services, transportation projects, education programs, Head Start, housing assistance, rural broadband, water infrastructure, and environmental protection programs. Every one of those programs would be subject to the same political control provisions described above.

My attached comment addresses the following specific provisions and requests that each not be finalized:

§200.205 and §200.205(d) — Political appointee pre-issuance review and the elimination of binding peer review

§200.340 — Discretionary termination on undefined “national interest” grounds

§200.300 — Replacement of anti-discrimination protections with anti-DEI prohibitions

§200.220 and §200.303 — Foreign collaboration prohibition and E-Verify mandate

§200.202, §200.202(d), §200.202(e) — Program design requirements mandating political alignment

§200.204 — Exemption of grant competitions from public notice

§200.206 — Denial of grants based on organizational affiliations

§200.432, §200.454, §200.461 — Conference attendance, journal subscriptions, and publication costs §200.421 and §200.450 — Public communications and issue advocacy prohibition

The attached comment also documents serious legal concerns including violations of the Administrative Procedure Act, the Public Health Service Act of 1944, the First Amendment, the Spending Clause, the Major Questions Doctrine, multiple civil rights statutes, and the Evidence-Based Policymaking Act of 2018. It further raises concerns about the adequacy of the interagency consultation process through which this rule was developed.

I urge OMB to withdraw this rule in its entirety.

Respectfully submitted,

Elizabeth Ginexi, PhD Former NIH Scientific Program Official (2003–2025)

Second, here is what I wrote in the pdf document that I attached as an upload:

Public Comment on Proposed Rule: Regulation for Federal Financial Assistance

Docket: OMB-2026-0034

Submitted by: Elizabeth Ginexi, PhD, Former NIH Scientific Program Official (2003–2025)

I am writing to express my strongest opposition to OMB’s proposed revisions to 2 CFR Part 200,¹ “Regulation for Federal Financial Assistance” published in the Federal Register on May 29, 2026. The proposed revisions would replace the peer-review system of federal investment in science with a political approval process. Indeed, this new political litmus test would extend to all grants issued by any federal agency including funding for science, public services, infrastructure, education, and social welfare programs. Using OMB’s grants management authority as a vehicle for political control over science, public services, and free speech has not been authorized by Congress or the Constitution.

I served the National Institutes of Health (NIH) for 22 years as a Scientific Program Official, shaping biomedical and behavioral health research strategy and safeguarding the taxpayers’ investments. Prior to my work at NIH, I served as a Senior Study Director and Scientist in the private sector conducting health research through federal grants. I hold master’s and doctoral degrees in applied social psychology from The George Washington University, and I completed postdoctoral training under two Public Health Service Grant National Research Service Awards at Children’s National Hospital and the Center for Mental Health Policy at Vanderbilt University. I am also a concerned citizen who values the federal investments in scientific advancement following WWII that helped make our country a leader in science and technology.

I left NIH in April 2025 because I witnessed firsthand the systematic replacement of the statutorily created system driven by scientists with one that is politically directed, in ways I believe violate the Public Health Service Act of 1944 (42 U.S.C. § 201 et seq.)²

As a former federal employee who took the oath of office required by 5 U.S.C. §3331,³ I understood that oath to include an obligation to speak when federal actions conflict with the Constitution and the laws under which I served. This comment is submitted in that spirit.

The proposed revisions to 2 CFR Part 200¹ attempt to codify and dramatically expand the violations I witnessed at NIH. The revisions would also violate the statutes that govern every other federal agency with grant-making authority by making funding decisions politically driven, rather than merit driven. At a fundamental level, this proposed rule violates the statutes that Congress passed to create these agencies.

The modern authority of the NIH was codified in law through the Public Health Service Act of 1944 (42 U.S.C. § 201 et seq.),² which established a decentralized, expert-led structure to support health-related scientific inquiry. Under this framework, NIH is composed of semi-autonomous institutes and centers (ICs), each led by directors selected through search committees of external scientific experts to prevent politicization (Schulson, 2026).⁴ The statutory firewall was robust. For decades, only two positions across the entire agency have been presidentially appointed: the NIH Director, appointed by the President with Senate confirmation under 42 U.S.C. §282, and the Director of the National Cancer Institute under 42 U.S.C. §284, a structure established by the National Cancer Act of 1971 and its 1974 Amendments.⁵ Central to this statutory mission is the mandate for peer review, formalized through the Ransdell Act of 1930 (Pub. L. No. 71-251)⁶ and expanded after World War II. By law and regulation, NIH uses a two-tiered grant review system in which panels of external scientists evaluate each application’s technical merit, followed by a final layer of oversight from National Advisory Councils. The legislative intent was clear: the government provides the resources, but the determination of what constitutes high-quality science remains the exclusive domain of those with the specialized training to judge it.

For eight decades, NIH decision-making followed this framework built on expert scientific consensus. While not without flaws, this system successfully transformed public health, fueled economic growth, and established the United States as a global leader in biomedical innovation.⁷ This system guided by science supported 174 Nobel laureates among NIH-funded researchers, along with the sequencing of the human genome, antiretroviral therapy for HIV, vaccines for polio and hepatitis B and HPV and COVID-19, and treatments for cancers that were uniformly fatal within living memory.⁷ None of those advances were predicted at the time the underlying research was funded. That is not a coincidence. It is the point.

The proposed revisions to 2 CFR Part 200¹ attempt to attach sweeping new conditions to NIH awards. The Spending Clause of the Constitution⁸ gives Congress the power to appropriate federal funds and to attach conditions to those appropriations, not OMB. Under South Dakota v. Dole,⁹ conditions on federal grants must be unambiguous, related to the federal interest in the program, and not coercive. Many provisions of this proposed rule fail that test. On these grounds alone I urge OMB not to finalize it.

I. This Rule Rests on Questionable Legal Foundations

The most foundational problem is the proposed conversion of OMB guidance into binding regulation. Since 2014, 2 CFR Part 200¹ has been explicitly characterized as guidance, commonly known as the “Uniform Guidance.” The existing regulatory text included a sentence stating plainly: “Publication of the OMB guidance in the CFR does not change its nature — it is guidance, not regulation.” The proposed revision deletes that sentence entirely and replaces the word “guidance” with “regulations” across 456 sections of the rule all at once. This transforms what has been a flexible administrative guidance document into binding law, and it does so in a way that makes the full scope of the change easy to miss.

This conversion is legally problematic for several reasons. Converting guidance to binding regulation requires independent notice-and-comment rulemaking for each substantive change being made, as required by the Administrative Procedure Act.¹⁰ Doing so across 456 sections in a single action, with a single government-wide effective date of October 1, 2026, denies agencies, grantees, states, and the public the opportunity to comment meaningfully on each specific change. It also eliminates the flexibility individual agencies have historically exercised in implementing OMB guidance in ways appropriate to their specific statutory missions and scientific communities. Under this rule, NIH, NSF, DOE, NASA, and every other federal agency loses the ability to shield their grantee communities from provisions that conflict with their authorizing statutes.

The proposed revisions also raise serious First Amendment concerns¹¹ under the unconstitutional conditions doctrine. The government is allowed to set rules about how its money is spent. What it cannot do (as the Supreme Court made clear in Agency for International Development v. Alliance for Open Society International¹²) is require organizations to agree with a particular political or ideological position just to qualify for federal funding. That crosses a constitutional line, because it uses money as a tool to force people to adopt views that go beyond anything related to the work being funded. Multiple provisions of this proposed rule cross that line.

The “anti-American values” criterion in §200.205, the issue advocacy prohibition in §200.450, and the DEI prohibition in §200.300 all would condition federal funding on ideological conformity rather than programmatic compliance. Researchers whose work directly informs public policy, such as climate scientists, public health researchers, and behavioral and social scientists, would be effectively prohibited from communicating their own federally funded findings publicly without risking their awards.

Additionally, under West Virginia v. EPA,¹³ the Major Questions Doctrine requires that agencies have clear congressional authorization for decisions of vast political and economic significance. Restructuring the entire federal grant enterprise, which represents approximately $1.1 trillion annually across every agency, every program, and every recipient, through a single OMB rulemaking, in ways that conflict with dozens of specific congressional mandates, is precisely the kind of major question that requires explicit congressional authorization. No such authorization exists here.

The proposed rule also contains a new provision at §200.101(d)(2) that deserves specific attention. It establishes that wherever the new OMB rule conflicts with an existing agency regulation, the OMB rule takes precedence, unless the agency’s rule is specifically required by a federal statute. For decades, individual science agencies have been able to adapt OMB guidance to fit their specific missions, protecting their research communities from provisions that would otherwise conflict with how they operate. This new provision closes that door. It also creates a default presumption that will push agency staff toward the most restrictive reading of every OMB rule whenever there is any ambiguity. Agencies that are required by law to base their decisions on scientific evidence (e.g., FDA, CDC, EPA) will find that the OMB rule now governs over their own implementing regulations. This is not a grants management provision. It is a mechanism for asserting OMB control over every federal agency’s regulatory operations.

The proposed §200.101(d)(2) is independently unlawful for reasons beyond the guidance-to-regulation problem. OMB’s authority under 31 U.S.C. §3511¹⁴ is limited to financial management and grants administration. It does not extend to overriding the substantive regulatory frameworks that Congress has established for individual agencies through their authorizing statutes. Asserting that OMB grants management regulations take precedence over FDA drug approval standards, EPA environmental standards, and NIH peer review requirements, all of which are grounded in agency-specific statutory mandates, exceeds OMB’s delegated authority. Under FDA v. Brown and Williamson Tobacco Corp., 529 U.S. 120 (2000),¹⁵ a general grant of administrative authority cannot override a detailed regulatory scheme that Congress established for a specific agency. Section 200.101(d)(2) attempts precisely that. It is not a grants management provision. It is an assertion of OMB supremacy over the entire federal regulatory enterprise, for which no congressional authorization exists.

The preamble to this proposed rule is itself evidence of arbitrary and capricious rulemaking. Every prior revision to 2 CFR Part 200 since the Uniform Guidance was established in 2013 identified its justifications in administrative assessments, stakeholder consultations, and empirical evidence of programmatic need. This preamble abandons that framework entirely. It characterizes the prior administration’s grants management practices as a “woke policy agenda” that “deliberately favored certain identity groups,” cites Heritage Foundation reports and partisan Senate documents as its primary authorities, and describes decades of peer-reviewed research as “neo-Marxist” and “anti-American.” These are not the findings of a neutral administrative process. They are political accusations. Under the APA’s arbitrary-and-capricious standard, an agency must offer a rational connection between the facts in the record and the choices it makes. A preamble that substitutes partisan rhetoric for evidentiary justification does not meet that standard, and courts reviewing this rule will have a clear record showing that OMB did not engage in the reasoned decision-making the law requires.

I urge OMB to withdraw this proposed rule in its entirety on these grounds. I additionally request that the following specific provisions not be approved or finalized, for the reasons set forth below.

II. §200.205 and §200.205(d) — Political Appointee Review and the Dismantling of Peer Review

These provisions are the most consequential in the rule and the most damaging to the American scientific enterprise.

Section 200.205 would require senior political appointees to conduct a mandatory pre-issuance review of every discretionary grant before it is awarded. These appointees would be explicitly forbidden from deferring to peer reviewers or routinely ratifying their recommendations. The criteria they must apply include blocking awards that touch on denial of “the sex binary in humans,” illegal immigration, or anything deemed to promote “anti-American values,” a term that is never defined anywhere in the rule.

Section 200.205(d) states explicitly that peer review recommendations “remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding.” This provision expressly violates the laws that mandate scientific peer review to inform grant-making decisions at NIH: specifically, the Ransdell Act of 1930,⁶ which established NIH as a federal institution, and Section 492 of the Public Health Service Act of 1944,² which mandates technical and scientific peer review for NIH grant awards followed by Advisory Councils and NIH Institute and Center Directors (all scientists) overseeing the final award decisions. These statutory mandates cannot be overridden by an OMB grants management regulation. Only Congress has the authority to make such a change.

I spent 22 years inside the NIH peer review system. I managed hundreds of grants and co-authored 18 funding initiatives that generated more than $778 million in federally funded research. I can say with direct knowledge that the merit review system these provisions dismantle is the reason the United States leads the world in biomedical discovery, behavioral science, and public health research. It is not a bureaucratic formality. It is a carefully constructed, legally and scientifically defensible process through which thousands of the nation’s best scientists evaluate the quality, innovation, and feasibility of proposed research. No political appointee, regardless of their qualifications, can replicate that judgment.

Scientific peer review is also the primary protection against waste, fraud, and abuse in federal science funding. Replacing it with political review does not improve stewardship of federal funds. It eliminates the most rigorous quality control mechanism federal science has.

This provision creates an additional problem by requiring that all grants include benchmarks for compliance with “Gold Standard Science,” a term tied to Executive Order 14303 but never defined anywhere in the rule. Agencies would have to prioritize institutions that have “demonstrated success in implementing Gold Standard Science,” while institutional prestige and historical reputation would be explicitly deprioritized. Because the standard is never defined, political appointees retain unlimited discretion to favor or disfavor any institution based on political alignment. This is a benchmark that cannot be defined, cannot be met, challenged, or reviewed. Under the void-for-vagueness doctrine,¹⁶ a regulatory requirement that fails to give recipients fair notice of what is required is constitutionally unenforceable.

None of the discoveries that defined American scientific leadership over the past eighty years, such as the sequencing of the human genome, antiretroviral therapy for HIV, vaccines for COVID-19, were politically predicted or politically selected. They emerged from a merit-based system that this rule would dismantle.

I request that §200.205 and §200.205(d) not be finalized.

III. §200.340 — Discretionary Termination

Under the current rule, federal grants may be terminated only under limited, defined circumstances: when a recipient fails to comply with the terms of the award, when both parties mutually agree to end it, or when the program loses its legal basis. These protections exist to give researchers, institutions, and communities the certainty they need to make long-term commitments based on awarded grants. The proposed revision to §200.340 would sweep those protections away. Under the new standard, any active federal grant could be terminated because a political appointee determines it no longer serves “the national interest as they exist at the time of the termination.” No finding of noncompliance is required. No finding of fraud or misconduct is required. A brief written rationale suffices.

This standard is so broad as to be effectively unlimited. It means that a grant awarded under one set of administration priorities can be canceled by the next political official who reviews it, regardless of the scientific progress being made, the commitments made to participants, the staff hired, or the students mid-dissertation. It converts every multi-year federal research award into an at-will arrangement, making long-term scientific planning legally and financially impossible. Applying this standard retroactively to grants already awarded raises additional due process concerns, as recipients have relied on established rules in making binding commitments to staff, participants, and institutions.

I have seen what mid-project grant terminations do to research programs, to the scientists who depend on them, and to the communities that participate in them. The harm is not abstract. Data sets become scientifically worthless when longitudinal studies are cut off before completion. Clinical trial participants are left mid-protocol. Graduate students abandon their training. The scientific record is permanently diminished and already spent taxpayer dollars are wasted.

Applying this rule to grants that are already underway would raise serious legal problems. When the government changes long-standing rules, courts have consistently held that it must explain why the change is necessary and consider the harm to people who organized their lives and work around the old rules.¹⁷ OMB does neither here. Scientists who received multi-year grants under the existing framework made real, binding commitments in good faith; they hired researchers, enrolled participants, signed contracts, and built research programs around the reasonable expectation that awarded grants would be honored. The law requires OMB to grapple with that disruption before changing course.¹⁸ It has not. On top of that, giving researchers no advance warning, no chance to respond, and no way to appeal before their grant is canceled raises a fundamental question of basic fairness. The Constitution requires that before the government takes away something it has already granted, people must have a meaningful opportunity to be heard.¹⁹ This provision provides none.

The revisions to provision §200.340 will damage the nation’s health, economy, and security, and relinquish our role as the world’s leader in biomedical research and innovation.

I request that the “national interest” termination standard in §200.340 not be finalized, and that the existing provision limiting termination to noncompliance and mutual agreement be restored.

IV. §200.300 and §200.300(b) — Anti-Discrimination Protections Replaced with Anti-DEI Prohibitions

The existing §200.300 protects individuals from unlawful exclusion or discrimination under federally funded programs. The proposed rule retains that language but immediately follows it with a new paragraph prohibiting use of federal funds to “fund, promote, encourage, subsidize, or facilitate” DEI or DEIA policies, “gender ideology,” or assistance with gender transition for individuals under age 19.

What is currently a section protecting people from discrimination would be converted into a section prohibiting programs designed to serve them. This directly conflicts with the statutory purpose of programs Congress created specifically to address health and social disparities, including IDEA,²⁰ Title I,²¹ Head Start,²² community health centers, and the Ryan White HIV/AIDS Program.²³ The administration cannot use a grants management regulation to override what Congress has legislated in those authorizing statutes.

The proposed §200.300(b) also conflicts directly with obligations Congress has already imposed on federal grantees through Title VI of the Civil Rights Act of 1964 (42 U.S.C. §2000d et seq.),²⁴ Title IX of the Education Amendments of 1972 (20 U.S.C. §1681 et seq.),²⁵ Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. §794),²⁶ the Age Discrimination Act of 1975 (42 U.S.C. §6101 et seq.),²⁷ and Section 1557 of the Affordable Care Act (42 U.S.C. §18116).²⁸ An OMB regulation cannot override a congressional statute. To the extent this provision requires grantees to curtail programming that their civil rights obligations require them to provide, it is unenforceable as a matter of law.

I request that the new §200.300 and §200.300(b) prohibitions not be finalized.

V. §200.220 and 200.303 — Foreign Collaboration Prohibition and E-Verify

Provision (§200.220) is entirely new. It would prohibit the use of any federal funds, including indirect costs, for collaboration with entities in “covered foreign countries.” This is defined broadly enough to encompass virtually every significant research partner outside the United States. The prohibition covers travel, technical assistance, research activities, and indirect costs allocable to such collaborations.

I have seen firsthand how international scientific collaboration advances American research. Infectious disease surveillance, genomics, climate science, and epidemiology all depend on data and partnerships that cross borders. The United States became the world leader in biomedical research in part because our scientists could work with the best minds anywhere in the world. This provision would end that, while our primary scientific competitors, including China, face no such restriction and are investing aggressively in exactly these fields.

It also directly conflicts with the congressional mandate of the Fogarty International Center at NIH,²⁹ which was created specifically to fund international health research. The prohibition may also conflict with bilateral scientific cooperation agreements the United States has entered into with allied nations, which contemplate and facilitate joint research programs. An OMB grants management rule cannot nullify a congressional mandate nor can it override treaty commitments. The United States has built global scientific leadership through exactly these kinds of international commitments. This provision would dismantle them.

A separate provision compounds this harm. The proposed rule adds a new paragraph (f) to §200.303, embedding a mandatory E-Verify requirement inside the existing internal controls section, requiring all grant recipients to enroll in and use the DHS E-Verify system for every employee and contractor working on a federal award.

Most major American research universities employ scientists from other countries on work visas. Under this provision, a failed E-Verify check must be reported to the federal agency and could result in termination of the grant. Combined with the foreign collaboration ban in §200.220, the message to international scientists is unmistakable: you are not welcome here. For generations, the United States attracted the world’s best researchers because American universities offered them opportunity, stability, and freedom to do their best work. These two provisions would destroy that reputation and hand our scientific competitors a recruitment advantage they could not have earned on their own.

I request that §200.220 and the E-Verify requirement added at §200.303(f) not be finalized.

VI. §200.202, §200.202(d), and §200.202(e) — Program Design Requirements

Under the current rule, federal grant programs must be designed around the purposes Congress established when it created them. Program goals must be evidence-based, consistent with authorizing legislation, and aligned with the agency’s own performance standards. That framework keeps grant programs grounded in scientific need and statutory mission rather than political preference. The proposed revisions to §§200.202, 200.202(d), and 200.202(e) replace that framework with something fundamentally different. Going forward, all federal grant programs would be required to align with “administration policies and priorities.” Agencies could restrict who is eligible to apply by limiting competitions to specific nonprofit categories. And any international element in an R&D award would be presumptively disfavored under a new domestic-first framework, requiring affirmative political justification on a case-by-case basis.

Requiring programs to align with administration priorities at the design stage means the political filter operates before anyone applies. Science agencies would be prohibited from soliciting research on topics that conflict with the current administration’s agenda, regardless of scientific need, statutory mandate, or the advice of the scientific community. This is not a grants management reform. It is a mechanism for suppressing entire fields of scientific inquiry, without scientific justification and without a vote of Congress.

Congress passed laws creating each federal agency’s grant programs and spelled out exactly what they are supposed to accomplish. This rule would allow the administration to ignore those congressionally defined purposes and substitute its own political priorities instead without passing a single new law. The Constitution does not allow that. The power to define what federal programs are for belongs to Congress, not to the President or OMB.³⁰

I request that §§200.202, 200.202(d), and 200.202(e) not be finalized as proposed.

VII. §200.204 — Exemption of Grant Competitions from Public Notice

The current rule is straightforward: every federal funding opportunity must be publicly posted on Grants.gov so that any eligible applicant can find it, read it, and compete for it on equal footing. That requirement has been the cornerstone of open, fair federal grant competitions for decades. It ensures that awards go to the best applicants, not the best-connected ones. The proposed revision to §200.204 would allow agency heads to skip that requirement entirely whenever they decide that public posting poses a risk to national security or is not in the national interest. A national security exception makes sense in narrow circumstances, such as classified defense research. But “the national interest” is an undefined standard that this administration has applied expansively, and it could be used to hide entire grant competitions from public view. When grant competitions are invisible, the public cannot know whether awards are being made on merit or on political grounds. Transparency is not just good governance. It is the primary safeguard against corruption and favoritism in federal spending.

This provision conflicts with two laws Congress has already enacted. The Federal Funding Accountability and Transparency Act of 2006 (FFATA)³¹ requires that all federal grants be publicly posted and accessible. When Congress passed that law, it specifically limited the national security exception to classified information only. The proposed rule’s much broader “national interest” exception goes beyond what Congress authorized, and OMB does not have the power to expand a congressional exception on its own. Federal grants management law³² also expressly states that public notice requirements written into the statutes that created individual grant programs cannot be overridden by general grants management rules. The laws that established NIH, NSF, and DOE grant programs contain their own public notice requirements. Section 200.204 cannot erase them.

I request that §200.204 not be finalized as proposed.

VIII. §200.206 — Denial Based on Organizational Affiliations

Under current grants management rules, agencies assess applicant risk based on concrete, verifiable factors: past performance on federal awards, financial health, and compliance history. This proposed revision to §200.206 adds a new category: an applicant’s organizational affiliations. Specifically, it would allow agencies to deny grants to any applicant affiliated with an organization deemed to “advocate for the overthrow of the United States Government” or “undermine public safety or national security.” None of these terms are defined anywhere in the rule. Because the rule’s own preamble characterizes climate research, equity research, and public health advocacy as anti-American activity, this vague new standard could be used to disqualify researchers who belong to environmental groups, civil rights organizations, or public health advocacy associations. In effect, it creates a political blacklist with no defined edges and no meaningful limits on its application.

Section 200.206 violates the First Amendment’s protection of freedom of association, as established in NAACP v. Alabama, 357 U.S. 449 (1958),³³ by conditioning receipt of a federal benefit on an applicant’s organizational affiliations. It further reflects the principle, developed through cases including Keyishian v. Board of Regents, 385 U.S. 589 (1967),³⁴ that the government may not deny benefits based on mere organizational membership without requiring specific intent to further unlawful purposes. The provision’s undefined terms including “undermine public safety,” “undermine national security,” and “anti-American values” render it unconstitutionally vague under the Fifth Amendment’s Due Process Clause.¹⁶ And its disparate impact on researchers affiliated with organizations serving minority communities implicates Title VI of the Civil Rights Act of 1964, 42 U.S.C. §2000d et seq.²⁴

I request that §200.206 not be finalized.

IX. §200.432, §200.454, and §200.461 — Conference Attendance, Journal Subscriptions, and Publication Costs

For decades, scientific conference attendance, journal subscriptions, and publication costs have been standard, routine allowable costs under federal science grants, recognized as essential to conducting research. The proposed rule reverses all three simultaneously. These three provisions (§200.432, §200.454, and §200.461) together would isolate federally funded researchers from their professional communities, deprive them of access to the scientific literature, and make it financially prohibitive to publish their findings.

Section 200.432 would make conference attendance allowable only if expressly pre-approved by the agency and written into the original award terms. Conferences are where scientists present findings, receive peer critique, discover new approaches, and build the collaborations that drive discovery. Requiring political pre-approval for specific conference attendance is completely unreasonable. This provision would essentially give agency officials the power to selectively cut researchers off from their fields.

Section 200.432 also raises serious First Amendment concerns. In Sweezy v. New Hampshire, 354 U.S. 234 (1957),³⁵ the Supreme Court identified academic freedom as a “special concern of the First Amendment” and held that the government should be “extremely reticent to tread” in the areas of academic freedom and political expression. Scientific conferences are the primary forum through which researchers engage in the intellectual exchange that is the essence of academic life. Requiring express political pre-approval for conference attendance, administered by political appointees applying political criteria, constitutes a content-based restriction on speech and association that is presumptively unconstitutional. It will also produce a severe chilling effect, and researchers will avoid conferences on politically sensitive topics rather than risk denial, thus suppressing exactly the kind of free inquiry the First Amendment is designed to protect.

Section 200.454 would reverse a provision that has explicitly permitted journal subscriptions as allowable costs since 1971. The preamble offers no substantive justification for this reversal beyond a generic reference to stewardship. Under the Administrative Procedure Act’s¹⁰ arbitrary-and-capricious standard as articulated in Motor Vehicle Manufacturers Association v. State Farm,³⁶ an agency reversing a longstanding policy must provide a reasoned explanation that accounts for the change. This preamble does not meet that standard.

Section 200.461 would make publication costs categorically unallowable by default and directly contradicts the 2022 OSTP open access mandate,³⁷ which requires that federally funded research be made publicly available. OMB cannot simultaneously require open access publication and prohibit the costs of achieving it. This irreconcilable conflict alone is sufficient grounds to withdraw §200.461.

I request that §§200.432, 200.454, and 200.461 not be finalized.

X. §200.421 and §200.450 — Public Communications and Issue Advocacy

Under current rules, federally funded researchers routinely communicate their findings to the public, the press, and policymakers as a standard and expected part of their work. The proposed rule would end that. Section 200.421 would make all public relations costs unallowable except those explicitly required by statute. Section 200.450 would prohibit any communication that could be characterized as taking a position on a social, political, or public policy issue. Together, these provisions would effectively silence federally funded researchers from communicating their findings on any politically sensitive topic. The public invested in this research. It has a right to the results.

Sections 200.421 and 200.450 also violate the First Amendment’s guarantee of free speech. The Supreme Court has ruled, in Legal Services Corporation v. Velazquez, 531 U.S. 533 (2001),³⁸ that the government cannot use its power over funding to silence certain viewpoints or shut down an established channel of communication that a federal program was created to support. Federal science research grants were designed to produce knowledge and share it with the public. They were never intended as a tool for controlling what scientists are allowed to say. Yet that is exactly what these provisions do. Section 200.421 makes it financially impossible for researchers to communicate their findings to the public at all. Section 200.450 prohibits communications on any topic the government decides is political and does so without ever defining where that line is. Together, they give the administration the power to fund research with one hand and silence its results with the other. Because researchers will not know which communications are safe, they are likely to stop communicating altogether rather than risk their grants. The Supreme Court has recognized this kind of self-censorship as a serious constitutional harm in its own right.

The harm from §200.450(c)(1)(v) extends further still. This provision would prohibit federally funded researchers from communicating findings to state agency officials for purposes of influencing state policymaking, rulemaking, or administrative action, unless that communication was specifically written into the original grant as a performance requirement. In practice, virtually no research grant is written that way. The result is that federally funded scientists could be prohibited from presenting their findings to state health departments, state environmental agencies, or state education agencies — the very institutions responsible for translating scientific evidence into public health and safety policy.

This prohibition also conflicts directly with the evidence-based policymaking requirements embedded in multiple federal statutes. The FDA is required by the Federal Food, Drug, and Cosmetic Act³⁹ to base its regulatory decisions on scientific evidence, much of which is federally funded. The EPA is required by the Clean Air Act and Clean Water Act to set standards based on the best available science. OSHA is required to base workplace safety standards on substantial evidence. If federally funded researchers cannot communicate their findings to the agencies responsible for these statutory mandates, those agencies lose the scientific basis on which their own legal obligations depend. More broadly, the Evidence-Based Policymaking Act of 2018⁴⁰ requires federal agencies to use evidence and data in policymaking across the entire government. OMB cannot use a grants management regulation to sever the pipeline between federally funded science and the evidence-based rulemaking that Congress has required.⁴⁰

The newly added proposed conflict resolution provision at §200.101(d)(2) makes this worse. By establishing that OMB’s grants management rules take precedence over agency-specific regulatory frameworks, it ensures that even agencies with statutory mandates to base their rules on scientific evidence cannot protect the researchers who produce that evidence from the §200.450 prohibitions. Congress required evidence-based policymaking. This rule would make it administratively impermissible to fund it.

I request that §§200.421 and 200.450 not be finalized as proposed.

Conclusion

I spent 22 years at NIH helping to build and sustain one of the greatest scientific enterprises in human history. The system Congress created included scientific peer review, open competition, institutional autonomy, international collaboration, and transparent publication. That system did not happen by accident. It was the product of deliberate, bipartisan policy choices made over eight decades, rooted in the understanding that science serves the public best when it is insulated from political interference.

The proposed revisions to 2 CFR Part 200¹ dismantle that system comprehensively, simultaneously, and without congressional authorization, using OMB’s grants management authority as a vehicle for political control of science and of free speech that Congress and the Constitution never intended and does not allow.

Finally, I want to be clear that this comment, while written from the perspective of a scientist, addresses a rule that extends far beyond science. The regulation being rewritten governs every federal grant from every agency, totaling approximately $1.1 trillion annually. State health services, transportation projects, education programs, Head Start, housing assistance, rural broadband, water infrastructure, and environmental protection programs would all be subject to the same political control provisions documented above. The harm from this rule would reach every community in America.

I urge OMB to withdraw this rule in its entirety. At a minimum, I request that each of the provisions identified above not be finalized. The American scientific enterprise and the public it serves cannot afford otherwise.

Respectfully submitted,

Elizabeth Ginexi, PhD

Former NIH Scientific Program Official and Concerned US Citizen

June 11, 2026

Citations and Legal Authorities

1 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards — the rule being revised)

2 Public Health Service Act of 1944, Pub. L. No. 78-410, 58 Stat. 682, codified at 42 U.S.C. ch. 6A §201 et seq. — specifically Section 492, 42 U.S.C. §289a (mandating NIH peer review)

3 5 U.S.C. §3331 (Oath of Office) — requires every federal employee, prior to entering upon the duties of their office, to swear or affirm that they will support and defend the Constitution of the United States against all enemies foreign and domestic, bear true faith and allegiance to the same, and faithfully discharge the duties of the office; cited here as the personal commitment that informs this comment and the author’s obligation to speak when federal actions conflict with the Constitution and the laws of the United States

4 Schulson, M. (2026, January 29). At NIH, a power struggle over institute directorships deepens. Undark Magazine.

5 National Cancer Act of 1971, Pub. L. No. 92-218, 85 Stat. 778 (establishing NCI Director as a presidential appointee); National Cancer Act Amendments of 1974, Pub. L. No. 93-352, 88 Stat. 424 (establishing Senate confirmation requirement for NIH Director); codified at 42 U.S.C. §282 (NIH Director) and 42 U.S.C. §284 (NCI Director)

6 Ransdell Act of 1930, Pub. L. No. 71-251, 46 Stat. 379 (establishing the National Institutes of Health as a federal institution)

7 Dzau, V. J., & Yamamoto, K. R. (2025, August 18). Government-funded health and biomedical research is irreplaceable. National Academy of Medicine.

8 U.S. Constitution, Article I, Section 8 (Spending Clause)

9 South Dakota v. Dole, 483 U.S. 203 (1987) — Spending Clause four-part test; conditions on federal grants must be unambiguous, related to the federal interest in the funded program, and not coercive

10 Administrative Procedure Act, 5 U.S.C. §§551 et seq., specifically §706 (arbitrary-and-capricious standard)

11 U.S. Constitution, Amendment I (First Amendment)

12 Agency for International Development v. Alliance for Open Society International, Inc., 570 U.S. 205 (2013) — First Amendment unconstitutional conditions doctrine; the government may not condition receipt of federal funds on recipients affirming a belief that by its nature cannot be confined within the scope of the funded program

13 West Virginia v. EPA, 597 U.S. 697 (2022) — Major Questions Doctrine; agencies require clear congressional authorization for decisions of vast political and economic significance

14 Grayned v. City of Rockford, 408 U.S. 104 (1972) — a law is void for vagueness under the Fifth Amendment’s Due Process Clause when it fails to give persons of ordinary intelligence fair notice of what conduct is prohibited; vague laws that allow arbitrary enforcement are unconstitutional

15 FCC v. Fox Television Stations, Inc., 556 U.S. 502 (2009) — establishes the APA standard for agency reversals of longstanding policy; requires a reasoned analysis that displays awareness of the change, provides good reasons for the new policy, and addresses serious reliance interests that the prior policy engendered; an agency that fails to consider reliance interests when reversing course acts arbitrarily and capriciously

16 Department of Homeland Security v. Regents of the University of California, 591 U.S. 1 (2020) — the Supreme Court held that an agency acts arbitrarily and capriciously under the APA when it fails to assess the existence and strength of reliance interests developed under an existing program and weigh them against competing policy concerns before changing course; directly applicable to the proposed retroactive application of §200.340’s termination standard to grants awarded under the prior framework

17 Mathews v. Eldridge, 424 U.S. 319 (1976) — establishes the governing procedural due process balancing test, requiring courts to weigh the private interest affected, the risk of erroneous deprivation under existing procedures, and the government’s interest in administrative efficiency; the proposed §200.340 termination standard, which requires only a brief written rationale with no notice period, no opportunity to respond, and no administrative appeal, fails this test given the substantial property interests at stake in multi-year federal research awards

18 Individuals with Disabilities Education Act (IDEA), 20 U.S.C. §1400 et seq.

19 Elementary and Secondary Education Act, Title I, 20 U.S.C. §6301 et seq.

20 Head Start Act, 42 U.S.C. §9831 et seq.

21 Ryan White HIV/AIDS Program, 42 U.S.C. §300ff et seq.

22 Title VI of the Civil Rights Act of 1964, Pub. L. 88-352, Title VI, §601, July 2, 1964, 78 Stat. 252, codified at 42 U.S.C. §2000d et seq. (prohibiting discrimination on the basis of race, color, and national origin in programs and activities receiving federal financial assistance)

23 Title IX of the Education Amendments of 1972, Pub. L. 92-318, Title IX, §901, June 23, 1972, 86 Stat. 373, codified at 20 U.S.C. §1681 et seq., as broadened by the Civil Rights Restoration Act of 1987, Pub. L. 100-259, 102 Stat. 28 (prohibiting discrimination on the basis of sex in educational programs and activities receiving federal financial assistance)

24 Section 504 of the Rehabilitation Act of 1973, Pub. L. 93-112, §504, September 26, 1973, 87 Stat. 394, codified at 29 U.S.C. §794, as amended by the Civil Rights Restoration Act of 1987, Pub. L. 100-259, 102 Stat. 28 (prohibiting discrimination against qualified individuals on the basis of disability in programs and activities receiving federal financial assistance)

25 Age Discrimination Act of 1975, Pub. L. 94-135, Title III, §301, November 28, 1975, 89 Stat. 728, codified at 42 U.S.C. §6101 et seq. (prohibiting discrimination on the basis of age in programs and activities receiving federal financial assistance)

26 Section 1557 of the Patient Protection and Affordable Care Act, Pub. L. 111-148, §1557, March 23, 2010, 124 Stat. 119, codified at 42 U.S.C. §18116 (prohibiting discrimination on the basis of race, color, national origin, sex, age, and disability in health programs and activities receiving federal financial assistance, incorporating the protections of Title VI, Title IX, the Age Discrimination Act of 1975, and Section 504 of the Rehabilitation Act of 1973)

27 Fogarty International Center Authorization, 42 U.S.C. §287b (John E. Fogarty International Center for Advanced Study in the Health Sciences — general purpose statute establishing international health research mission, added by Pub. L. 99-158, §2, November 20, 1985, 99 Stat. 866)

28 Gundy v. United States, 588 U.S. 128 (2019) — in which four justices signaled a willingness to reinvigorate the nondelegation doctrine, indicating that broad delegations of legislative power to the executive branch without an intelligible principle to guide their exercise are constitutionally suspect; cited here for the proposition that requiring all federal grant programs to align with “administration policies and priorities” — without any limiting definition or congressional authorization — constitutes an impermissible delegation of Congress’s appropriations and program-design authority to the executive branch

29 Federal Funding Accountability and Transparency Act of 2006, Pub. L. 109-282, September 26, 2006, as amended by the Government Funding Transparency Act of 2008, Pub. L. 110-252 — requires that all federal grant awards be publicly accessible on a searchable website; contains an explicit national security carve-out limited to classified information only, which is narrower than the “national interest” exception proposed in §200.204

30 31 U.S.C. Chapter 61 (Program Information) — governs federal grants management information requirements and provides that nothing in federal grants management law shall supersede notice of funding opportunity requirements contained in the authorizing statutes of individual competitive grant programs

31 NAACP v. Alabama ex rel. Patterson, 357 U.S. 449 (1958) — landmark First Amendment freedom of association case; the government may not deny a benefit or compel disclosure based on organizational affiliation where doing so would chill constitutionally protected association; means that sweep unnecessarily broadly into protected freedoms are unconstitutional even in pursuit of a legitimate government purpose

32 Keyishian v. Board of Regents of the University of the State of New York, 385 U.S. 589 (1967) — the government may not deny public benefits based on mere membership in an organization without requiring specific intent to further any unlawful purpose; rejected the doctrine that government may attach whatever conditions it pleases to public employment or benefits; confirmed that guilt by association is constitutionally impermissible

33 Sweezy v. New Hampshire, 354 U.S. 234 (1957) — the Supreme Court identified academic freedom as a “special concern of the First Amendment” and held that government should be “extremely reticent to tread” in the areas of academic freedom and political expression; the right to lecture and to associate with others for academic purposes are constitutionally protected freedoms; government interference in university teaching and scholarship requires compelling justification

34 Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29 (1983) — APA arbitrary-and-capricious standard; an agency reversing a longstanding policy must provide a reasoned explanation that accounts for the change

35 Office of Science and Technology Policy (OSTP) Public Access Memorandum, August 25, 2022 (Nelson Memo) — requires that federally funded research be made publicly available

36 Legal Services Corporation v. Velazquez, 531 U.S. 533 (2001) — the government may not use funding restrictions to impose viewpoint-based discrimination on private speech or to distort an established marketplace of ideas that a federal program was designed to support; a restriction on federally funded private speech that suppresses expression based on viewpoint violates the First Amendment even when the restriction operates through conditional funding rather than direct prohibition

37 Federal Food, Drug, and Cosmetic Act, Pub. L. 75-717, June 25, 1938, codified at 21 U.S.C. §301 et seq. — requires that FDA regulatory decisions including drug approvals, medical device clearances, and food safety standards be grounded in scientific evidence; conflicts with §200.450(c)(1)(iv) to the extent that provision prohibits federally funded researchers from communicating findings to FDA for purposes of informing evidence-based rulemaking

38 Evidence-Based Policymaking Act of 2018, Pub. L. 115-435, January 14, 2019, codified at 5 U.S.C. §311 et seq. — requires federal agencies to use evidence and data in policymaking and to build evaluation capacity across the federal government; directly conflicts with §200.450(c)(1)(iv) and (v) to the extent those provisions prohibit federally funded researchers from communicating scientific findings to federal and state agencies for purposes of informing policy

The White House budget office is a powerful agency called OMB that most Americans have never heard of. On May 29, 2026 OMB proposed a new rule that would give White House appointees complete control to approve or cancel every grant program created by Congress representing over $1.1 trillion a year.

Your elected members of Congress design federal grant programs to serve the American people. Through legislation they decide how much money goes to each program, and the money is distributed to the states by agencies. Once a grant is awarded, independent experts and established rules within the agencies determine who gets the money and protects it from being canceled without cause. This new rule proposed by the White House OMB would change all of that. It would give White House appointees the direct power to veto any grant before it is awarded, or to cancel any active grant at any time, with no appeal and no explanation required, completely overriding Congress.

This veto power would extend to every federal grant, from every agency. It may be a grant that funds your child’s Head Start program. Or it might be the grant that is finally bringing broadband internet to your rural town. Perhaps it will be the federal funding keeping your county’s rural hospital open or the big infrastructure project your state has been waiting years to complete. These programs could all be canceled by the White House on a whim.

Right now, a 45-day public comment period is open and it closes on July 13, 2026. Under federal law, the government is required to read every single comment it receives and respond to the significant ones before this rule can take effect. That means your voice, your specific story about how federal money reaches your community, has genuine legal power. One well-written personal comment from someone whose life would be affected carries more impact than ten thousand identical form letters.

You do not need to be an expert. You only need to describe what is at stake for you.

Here is what is at stake for all of us.

The bridge your county has been waiting years to fix.

Federal transportation grants fund highway repairs, bridge replacements, transit systems, and port improvements across the country. These are often multi-year projects where engineers are hired, contractors are brought in, and communities make plans around the promise that the money will be there. This proposed rule includes a new termination provision that would allow any active federal grant to be canceled mid-project because a White House appointee decides the project no longer serves the national interest. They won’t even need to provide an explanation beyond a brief written note, and there would be no appeal. If the money for a half-built bridge is cut, how will the community finish it?

The rural hospital that is the only one for fifty miles.

Rural hospitals operate on tight budgets. Many of them depend on federal grants just to keep their doors open. When a rural hospital closes, it does not just affect healthcare. It also shuts down the largest employer in many small communities. Under this proposed rule, every grant that keeps a rural hospital running is at risk of termination at any time, for any reason, with no meaningful process for challenging the decision.

The Head Start center where your neighbor drops off her kids every morning.

Six hundred thousand low-income children are enrolled in Head Start programs right now. These programs operate preschools with teachers hired, children enrolled, and parents who depend on that childcare while they work. Head Start is funded by federal grants. With this new proposed rule, a Head Start center could lose its grant mid-year because a White House appointee decides the program no longer aligns with the administration’s priorities. The children would lose their classroom and the parents would lose their childcare.

The broadband project that was finally going to connect your rural community.

Federal grants have been deploying high-speed internet to rural communities that have waited decades for reliable connectivity. These are multi-year infrastructure projects involving contractors laying fiber. Under this new rule, a grant terminated mid-deployment would leave a community with partially built cable lines that serve no one.

The drinking water system that needed an upgrade.

Water and wastewater infrastructure upgrades in small communities that have no other way to finance them rely on federal grants. Cutting off funding for a water treatment plant mid-construction would have immediate and severe public health consequences.

The school that relies on federal funds for low-income students and students with disabilities.

Federal education grants support schools in communities across every state. The teachers hired with that funding, the programs built around it, and the students who depend on it are all now at risk under a rule that will allow funding to be cut at any time, for any reason, with no appeal.

The substance abuse treatment clinic or mental health center serving your neighbors in crisis.

The federal government distributes nearly $800 million every year through grants to community mental health centers and substance abuse treatment programs across all 50 states. These are the clinics providing opioid treatment, mental health counseling, and crisis services to people who have nowhere else to turn. Many of these clinics operate in communities where private insurance and private providers are scarce or nonexistent.

Every one of these behavioral health grants would be governed by this newly proposed rule and could be subject to termination at any time by the White House. A treatment program mid-cycle, serving patients in active recovery, could lose its federal grant because a President’s appointee decides it is no longer a priority for the administration. For people in recovery, disruption to life saving treatment is not an inconvenience. It is a crisis.

The Meals on Wheels program and senior services keeping your elderly neighbors independent.

The federal government distributes more than $2 billion every year through the Older Americans Act to fund services for Americans aged 60 and older in every state and community. These grants fund Meals on Wheels home delivery programs, senior centers, adult day care, transportation for seniors who can no longer drive, in-home assistance with daily tasks, family caregiver support, and legal services for vulnerable elders. Every one of these programs is administered by local Area Agencies on Aging using federal grant dollars.

For many elderly Americans living alone, a Meals on Wheels delivery is not just a meal. It is a daily check-in, a connection to the outside world, and often the reason they can remain in their own home rather than moving to a care facility. A grant canceled by the White House because a political appointee decides the program no longer serves administration priorities will hurt these seniors in our communities.

What is going on?

Congress passed specific laws creating each one of these grant programs. The goal is to provide needed community services in each state, making sure that your tax money is directly helping your community. All of these programs were created through the Congressional budget process, and built on the expectation that the federal commitments would be honored. Communities built their planning around these expected grants. The hospitals, schools, water utilities, behavioral health clinics, and county engineers all made real, binding decisions based on the reasonable belief that these federal funds would be delivered.

This newly proposed White House budget would break that promise from Congress.

OMB is attempting to do all of this through a single regulatory change, buried in 412 pages of technical language, with a 45-day window for the public to respond. They are doing this to get around Congress and cut off money to your community. And they are counting on most Americans not knowing this is happening until it is too late. The 45-day window to stop it closes July 13. Make sure your community’s voice is in the record.

What you can do right now.

Go to this link and submit a comment in opposition to this rule before July 13: https://www.regulations.gov/commenton/OMB-2026-0034-0001

You do not need to be an expert or a lawyer to submit a comment. You just need to describe, in your own words, what is at stake for you and your community if federal grants can be canceled for no stated reason by the White House.

One important note: do not copy anyone else’s comment, including the examples below. The government counts all identical comments as a single comment, no matter how many people submit them. The goal is to get as many comments as possible to show that Americans oppose this rule. A comment written in your own words, about your own life and community, is perfect testimony. Even three sentences in plain language about your specific situation is more valuable than a polished paragraph you copied from somewhere else.

Not sure what to say? Here are some real situations that could make powerful comments. Use them as inspiration, not as scripts.

A teacher in a high-poverty school whose students depend on Title I federal funding might write about what would happen if that funding were subject to cancellation mid-year based on a White House appointee’s decision, and what it would mean for her students.

A county official overseeing a federally funded infrastructure project might describe how far along the project is, what commitments have already been made, and what a mid-project termination would cost the community.

A parent whose child attends Head Start might describe what that program means to their family, why it matters, and what losing it mid-year would mean for their child and their ability to work.

A person in recovery, or a family member of someone who depends on a federally funded mental health program, might describe what that program has meant and what disruption to it would look like for patients.

A parent whose child requires disability educational services relies on federal funding to make that programming viable in their school district. Parents can describe what it would mean for their child if that funding were subject to cancellation based on a White House appointee’s decision.

A rural resident still waiting for broadband might describe how long they have been waiting, what a federally funded high-speed internet connection would mean for their family or business, and what it would mean if that grant were canceled before completion.

A family whose elderly parent lives alone and relies on Meals on Wheels delivery services could speak about the direct harms that would be caused if this type of grant money is canceled.

Whatever your situation, the formula is simple. Say who you are. Describe the program that matters to you. Explain what losing it, or losing the stability of knowing it will be there, would mean for your life. Then finish your comment by saying clearly that you oppose this new rule.

Deadline: July 13, 2026 at 11:59 PM Eastern

Comment here: https://www.regulations.gov/commenton/OMB-2026-0034-0001

👀 Pay Attention. 👀 This article by Andrew Jack of the Financial Times reveals the twisted ideology behind the new OMB rule issued by Russell Vought. OMB is engaged in a disinformation campaign:

An OMB spokesman said: “Federal grants were already politicised to promote a far-left agenda. Funding went to projects like drag shows to promote diversity in Ecuador and transgender experiments on mice. That ends now. With this new rule, the Trump administration will bring transparency to the grantmaking process and ensure taxpayer dollars are spent wisely.”
⚠️ THIS IS FALSE. 👆

OMB is claiming federal grants funded "drag shows in Ecuador" and "transgender experiments on mice." This is disinformation. Full Stop.

There was no drag show grant. That is a deliberate mischaracterization of a routine State Department cultural diplomacy grant, fabricated by Senator Rand Paul's office, laundered through Heritage Foundation policy documents, and now repeated by OMB as though it were fact.

The "transgender mice" claim is an equally dishonest description of standard biomedical research on sex hormones — methodology used for a century to understand why diseases affect men and women differently. Calling it "transgender experiments" is a cynical rebranding designed to trigger outrage, not inform policy.

Both false claims appear in the new proposed OMB rule's own preamble. A regulatory document that relies on fabricated talking points as its primary justification for rewriting $1.1 trillion in federal grant rules should be recognized for what it is: disinformation in service of a political agenda.

Read the actual rule. Then comment on it before July 13th.

Here are links to my Summaries of this new rule:

Summary of Key Changes in OMB’s Proposed Federal Financial Assistance Rule - https://elizabethginexi.substack.com/p/summary-of-key-changes-in-ombs-proposed

What We Need to do NEXT: OMB’s Proposed Federal Financial Assistance Rule (OMB 2026-10817) - https://elizabethginexi.substack.com/p/what-we-need-to-do-next-ombs-proposed

This new OMB Rule is Bigger Than Science. Much Bigger. - https://elizabethginexi.substack.com/p/this-new-omb-rule-is-bigger-than

This image was generated by Google AI (Gemini)

When I published my summary of OMB’s proposed Federal Financial Assistance rule last week, I was writing from my lane. I spent 22 years as an NIH Program Official overseeing federally funded science. I know firsthand how real and severe that damage to science funding would be, and it deserved to be named clearly.

I want to widen the lens now, because the more I have dug into this rule, the more I realize that scientists are not the only ones who should be alarmed. Not even close.

2 CFR Part 200, the regulation being rewritten here, is not the science grants regulation. It is the universal legal framework governing every federal grant to every recipient across every agency in the federal government. When OMB rewrites it, they are rewriting the rules for all of it.

According to the Congressional Research Service, in FY2024 the federal government sent $1.1 trillion in grants to state and local governments. That money is what funds:

• Medicaid — more than $600 billion, with the federal government covering between 50 and 77 cents of every dollar states spend on health care for their most vulnerable residents

• Transportation — $95 billion for highways, bridges, transit systems, airports, and ports

• Education — $65 billion for Title I schools, special education, Head Start, and workforce training

• Food assistance — $51 billion

• and much more

Every single one of those programs operates under 2 CFR Part 200. Every one of them is now subject to the same provisions I described last week.

Consider what that means in practice. Political appointees who can override expert judgment and block science grants that don’t advance the President’s priorities would have that same power over transportation awards, and housing funds, not just NIH applications. Any active grant could be canceled mid-project because it no longer serves ‘the national interest.’ A highway already under construction. A tribal health program mid-delivery. A city still rebuilding from a flood. And every new grant program must align with administration priorities before a single application is even solicited. Entire categories of funding can be quietly discontinued without a public announcement or a vote.

Federal grants are not peripheral to how states and communities function. They represent, on average, 36 cents of every dollar a state spends. This rule puts that entire financial partnership between the federal government and the states under political control, without an act of Congress, effective October 1, 2026.

A scientist reading my last post understood immediately why they should be worried. These professionals should also be concerned:

• The county engineer overseeing a federally funded bridge.

• The housing authority director managing Section 8 vouchers.

• The rural hospital administrator whose Medicaid reimbursements depend on stable federal grant terms.

• The Head Start center manager operating preschools with teachers hired, children enrolled, and parents depending on them for the childcare that lets them go to work.

• The school principal whose Title I funding supports her lowest-income students.

This rule touches all of them.

If you found my original post worth sharing, I hope you will share this one too, especially with people outside the scientific community who may not yet know this is coming. The comment period is open now and closes July 13, 2026.

Submit your comment in opposition here: https://www.regulations.gov/document/OMB-2026-0034-0001

You do not need to be an expert. You need to describe, in your own words, how your community, your program, your state, or your work depends on stable, merit-based federal grants and what it would mean to lose that. Cite the specific section that would hurt your community.

Below I have compiled the specific provisions that should concern people outside the scientific community, organized by who they affect most. Pick one or two that apply to your situation and cite them in your comment.

For State & Local Governments and Communities

§200.340 — Discretionary Termination is the one that should keep every state and local budget director awake at night. This is the provision that allows any active federal grant to be canceled mid-project because a political appointee decides it no longer serves the national interest.

§200.202 — Program Goals Must Align with Administration Priorities is the second most important for states, because it operates upstream of everything else. Before a state can even apply for a grant, the federal program must be designed to align with the President’s policy priorities.

§200.204 — Grant Competitions Can Be Hidden from Public View compounds the §200.202 problem. If agencies can exempt funding opportunities from public posting on Grants.gov under a broad national interest exception, states may not even know a competition exists until it is over.

§200.205 — Political Appointee Pre-Issuance Review is particularly alarming for local governments and community organizations because it inserts a political filter between a competitive application and an award decision. A local housing authority, a tribal nation, or a rural health clinic that wins on the merits can still be denied, with no appeal right and no requirement to explain why.

§200.206 — Denial Based on Organizational Affiliations is one that community-based organizations need to flag urgently. The language is broad enough to disqualify civil rights groups, environmental advocacy organizations, public health nonprofits, and community organizing entities. Given how expansively the rule’s preamble defines “anti-American activity,” this provision threatens the civic infrastructure that delivers many federally funded community services.

For Healthcare and Social Service Providers

§200.300 — DEI and Related Prohibitions is the most urgent provision for healthcare and social service organizations. The prohibition on using federal funds to promote or facilitate “DEI practices,” “gender ideology,” or related activities is embedded as a mandatory grant condition across all agencies and all programs. For Medicaid-funded health systems, community health centers, and social service agencies, this creates an impossible conflict: the populations these organizations serve are, by definition, the ones equity-focused programs are designed to reach. And because the rule never defines what counts as a prohibited DEI practice, providers face open-ended liability for ordinary program activities.

§200.218 — Disparate Impact Research and Programming Banned is a completely new provision, with no current counterpart in the regulations. It prohibits federal grant funds from supporting disparate-impact studies, disparate-impact litigation, and any program design based on “the assumed risk of disparate-impact liability.” Disparate-impact analysis is a foundational tool of civil rights law, public health research, environmental justice, housing policy, and labor economics. Banning its use in federally funded work would gut decades of evidence-based policy research.

§200.340 — Discretionary Termination applies here too, with particular cruelty. A community health center mid-way through a three-year federally funded program serving patients with chronic disease, a behavioral health organization running a longitudinal treatment study, a food bank administering a multi-year USDA nutrition program—all are now exposed to termination with only a brief written rationale required and no meaningful appeal right.

For Education Providers

§200.300 — DEI Prohibitions applied to Title I, IDEA, Head Start, and workforce training grants creates a direct conflict with the statutory purpose of those programs. Title I exists to direct resources to high-poverty schools. IDEA exists to ensure children with disabilities receive appropriate services. Characterizing equity-focused programming as an unallowable DEI activity inverts the entire purpose of the statutes Congress passed to create those programs.

§200.205 — Political Appointee Review applied to education grants means that competitive federal education awards, including those for curriculum development, teacher training, and educational research, pass through a political screen that has nothing to do with educational quality or student outcomes.

§200.450 — Issue Advocacy Prohibition is particularly significant for education providers because it could restrict grantees from communicating findings, advocating for students before state agencies, or engaging in routine community education work.

How to write an effective Comment. Make it completely unique! Do not cut and paste.

1: Say who you are and why you are qualified to comment. You do not need credentials. Being affected is enough, and simply being a concerned citizen is perfectly fine.

2: List the exact provision #s [PICK ONE or TWO FROM LIST ABOVE] that concern you, and explain what they would do. You do not need to quote the rule directly. Just explain what you understand it to mean in plain terms.

3: Explain the concrete harm. What would happen to you, your community, or your state if this provision takes effect?

4: Closing: State clearly what you want OMB to do. This can be as simple as: “I urge OMB to withdraw these specific provisions: §200.340, §200.202, §200.205.” or “I urge OMB not to finalize this rule.”

Submit your comment in opposition here: https://www.regulations.gov/document/OMB-2026-0034-0001 The deadline is July 13, 2026.

https://www.federalregister.gov/public-inspection/2026-10817/regulation-for-federal-financial-assistance

1. Political Appointees Take Control of Grant Awards (§200.205)

This is arguably the most consequential change in the rule. Senior political appointees, rather than career scientists or program officers, would now be required to conduct a “pre-issuance review” of every discretionary grant before it is awarded. These appointees are explicitly forbidden from deferring to peer reviewers or routinely ratifying their recommendations.

The criteria they must apply include blocking awards that touch on denial of “the sex binary in humans,” illegal immigration, or anything deemed to “promote anti-American values.” The rule also requires that discretionary awards must:

“...demonstrably advance the President’s policy priorities.”

In practice, this gives political appointees a veto over any science that conflicts with the current administration’s ideology.

2. Peer Review Is No Longer Binding (§200.205(d))

The rule explicitly states that peer review recommendations “remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding.” This directly dismantles the post-WWII system used by NIH, NSF, DOE, NASA, and nearly every science agency, in which independent expert peer review was the primary measure of scientific merit. Under this rule, a political appointee can simply override the scientific community’s judgment with no finding of cause.

3. “Gold Standard Science” as an Undefined Political Test (§200.205)

The rule repeatedly invokes a concept called “Gold Standard Science,” tied to Executive Order 14303 of May 23, 2025, without defining it in any concrete or measurable way. Under the proposed requirements:

• All grants must include benchmarks for compliance with “Gold Standard Science”

• Agencies must prioritize institutions that have “demonstrated success in implementing Gold Standard Science”

• Institutional prestige and historical reputation are explicitly deprioritized in favor of compliance with this undefined standard

Because the standard is never defined, the administration retains broad, unguided discretion to favor or disfavor institutions based on their political alignment.

4. Active Grants Can Be Terminated at Any Time, for Any Reason (§200.340)

The rule codifies and expands the authority to terminate active grants mid-award simply because they are “inconsistent with program goals or agency priorities.” Agencies need only provide a brief written rationale; no finding of noncompliance or fraud is required. This retroactively threatens ongoing multi-year research that researchers and institutions have built programs around.

OMB frames this as analogous to the “termination for convenience” clause used in federal contracts, but grants are fundamentally different instruments. Researchers take on staff, make commitments to participants, and design years-long projects around the presumption that a funded grant will run its course.

5. DEI, Gender Research, and Related Topics Banned as Grant Conditions (§200.300)

All federal award funds are prohibited from being used to “fund, promote, encourage, subsidize, or facilitate” any of the following:

• DEI or DEIA policies or practices

• “Gender ideology,” defined as any theory that “denies the biological reality of sex or the sex binary”

• Any assistance with gender transition for individuals under 19

These restrictions are embedded as mandatory grant conditions across all agencies and all programs. A university or research institution that conducts such research, even with entirely separate, non-federal funds, could face grant termination if the activity is found to conflict with award conditions.

6. Broad Prohibition on International Scientific Collaboration (§200.220)

A new government-wide rule prohibits the use of any federal funds, including indirect costs, for bilateral or multilateral collaboration with “covered foreign countries” or entities affiliated with them. The rule extends beyond China to all countries designated under broad sanctions lists, and covers travel, research activities, technical assistance, and indirect costs allocable to any such collaboration.

While legitimate national security concerns exist with certain foreign entities, this provision is sweeping enough to severely disrupt international partnerships that have been foundational to U.S. leadership in fields from climate science and astrophysics to genomics and epidemiology.

7. “Domestic-First” Framework for Research Awards (§200.202(e))

A new domestic-first framework requires that any international element in a federally funded R&D grant be affirmatively justified on a case-by-case basis by agency officials. Foreign entities cannot receive R&D awards at all except with written approval from a senior political appointee. International collaboration, currently standard practice across many scientific disciplines, would become presumptively disfavored.

8. Applicants Can Be Denied Based on Organizational “Affiliations” (§200.206)

The risk factors agencies may use to deny a grant application are expanded to include an applicant’s membership in or affiliation with organizations that “advocate for the overthrow of the United States Government” or “undermine public safety or national security.” Given the preamble’s expansive framing of what constitutes anti-American activity, this language could be used to disqualify researchers affiliated with civil rights, environmental, or public health advocacy organizations.

9. E-Verify Mandated for All Grant Recipients (§200.303)

All recipients and subrecipients of federal awards must enroll in and use the DHS E-Verify system for every employee and contractor working on a federal award. Any Final Nonconfirmation must be reported to the federal agency. This adds significant administrative burden to universities and research institutions and could jeopardize grants at institutions employing researchers from abroad.

10. OMB Claims Direct Binding Authority Over All Agencies

The rule restructures 2 CFR to make OMB’s guidance a directly binding regulation on all agencies, effective government-wide on a single date. This removes the previous system under which individual agencies had meaningful flexibility in adopting OMB guidance. It also eliminates the ability of individual science agencies to shield their communities from any of these changes through their own implementing rules.

Conference Attendance and Related Costs

11. Conference Attendance Now Requires Express Agency Pre-Approval (§200.432)

Under current rules, conference attendance related to the scientific work of a grant is a standard, routine allowable cost. The proposed rule eliminates that presumption entirely. The new text states:

“The costs for attending conferences are allowable only if participation in the conference is expressly approved by the Federal agency and included in the terms and conditions of the Federal award.”

This means every conference a researcher wishes to attend using grant funds must be pre-approved by the agency and written into the award at the time it is made. Conferences not anticipated when the award was issued cannot easily be added later, and the agency has full discretion to deny approval or simply decline to include any conferences in the terms at all.

Conferences are where scientists present results, receive peer critique, discover new approaches, and build the collaborations that advance their fields. Giving political appointees gatekeeper authority over conference attendance is a direct tool for isolating researchers from their professional communities.

12. Professional Memberships Require Prior Approval and Must Be “Necessary” (§200.454)

The proposed rule makes three significant changes to allowable membership and subscription costs:

• Professional society memberships are only allowable if they are necessary to fulfill the award requirements and receive prior written agency approval

• Subscriptions to professional, academic, and technical journals are made categorically unallowable

• Memberships in organizations whose primary purpose is lobbying or issue advocacy are unallowable

The journal subscription ban deserves particular attention. Researchers routinely use grant funds to access the scientific literature that is foundational to their work. At institutions with constrained library budgets, this could make it genuinely difficult to conduct research.

13. Publication Costs and Open Access Fees Presumptively Unallowable (§200.461)

The rule proposes that all journal publication costs, including article processing charges, open access fees, and similar fees, are unallowable by default. Exceptions would require either a specific statutory mandate or case-by-case agency pre-approval. The proposed regulatory text reads:

“Publication costs (including page charges, article processing charges (APCs), or similar fees such as open access fees for professional journal publications and other peer-reviewed publications) are unallowable under Federal awards.”

This directly conflicts with longstanding federal open access mandates, including the 2022 OSTP memorandum requiring that federally funded research be made publicly available. Peer-reviewed publication is the mechanism by which science is validated and shared. Making it financially prohibitive for federally funded researchers to publish their findings would effectively suppress the scientific record.

14. Public Communications and Outreach Severely Restricted (§200.421)

All public relations costs are proposed as unallowable except those explicitly required by statute. This would restrict researchers from communicating findings to the public or press. Combined with the issue advocacy prohibition below, it adds another layer of control over how federally funded science reaches the public.

15. New “Issue Advocacy” Prohibition (§200.450)

Federal grant funds could not be used for:

• Any messaging that promotes or opposes a “particular social, political, or public policy position unrelated to the statutory objectives” of the award

• Voter registration activities

• Attempting to influence any state executive branch agency on matters outside the precise scope of the award

Given that the rule’s preamble characterizes climate science, public health research, and equity research as “divisive ideologies,” this prohibition could be deployed to bar researchers from speaking publicly about their own federally funded findings on politically sensitive subjects.

Notices of Funding Opportunities: New Restrictions and Controls

16. Program Goals Must “Align with Administration Policies and Priorities” (§200.202)

Every new federal grant program, including science programs, must now be designed with goals that explicitly align with administration policies and priorities. This requirement is embedded directly in the regulatory text governing program design, meaning science agencies must structure their grant solicitations around the current administration’s political agenda rather than solely around scientific need, statutory mandate, or the advice of the scientific community.

17. Agency Heads Can Exempt Grant Competitions from Public Notice (§200.204)

A new exception allows a federal agency head, or their designee, to approve an exemption from the requirement to publicly post a funding opportunity on Grants.gov when “publicly announcing an opportunity would pose a risk to national security or is in the national interest of the United States.” While narrow national security carve-outs for classified defense research are legitimate, this language is considerably broader. “National interest” is a phrase this administration has used expansively, and it could justify conducting entire grant competitions outside public view.

18. Agencies Can Restrict Eligibility to Specific Nonprofit Categories (§200.202(d))

Agencies can now explicitly restrict grant eligibility to specific IRS nonprofit categories, for example limiting eligibility to 501(c)(3) organizations while excluding 501(c)(4) organizations. This could be used to exclude advocacy-affiliated scientific organizations or civil society groups that conduct or fund research.

19. OMB Gains Direct Oversight of Which Institutions Receive Grants

A new provision allows OMB to require agencies to submit reports identifying the specific recipients of federal awards over any given period. Combined with OMB’s new authority to require political alignment in program design, this gives the White House direct oversight and leverage over which institutions receive federal research funding. That function has historically been insulated from political interference, and with good reason.

Bottom Line

Since World War II, the United States built the world’s preeminent scientific enterprise on a straightforward principle: federal dollars should fund the best science, as determined by independent experts rather than politicians. Peer review, open competition, and institutional autonomy were the pillars of that system. This proposed rule dismantles all three, simultaneously, government-wide, and binding on every federal agency by October 1, 2026.

What OMB is proposing is not a reform of grants management. It is a complete political control apparatus layered over every stage of the federal science funding lifecycle.

• Before a competition opens, every program must be designed to align with the President’s policy priorities, not scientific need, statutory mandate, or expert consensus.

• When opportunities are announced, agencies can restrict who is eligible, and the agency head can exempt solicitations from public posting under a broad national interest exception.

• When applications are reviewed, political appointees must personally evaluate every discretionary grant. Peer review is explicitly reduced to advisory status. Appointees are forbidden from deferring to scientific experts.

• When awards are made, grants can be conditioned on compliance with an undefined “Gold Standard Science” standard, and institutions can be disqualified based on their affiliations or the political character of their prior work.

• During the research itself, scientists cannot attend conferences, join professional societies, subscribe to journals, or publish in peer-reviewed journals without express agency pre-approval. Each of those approvals can simply be withheld.

• At any moment, an active grant, including a multi-year award already mid-project, can be terminated because a political appointee decides it no longer aligns with agency priorities. No finding of misconduct is required.

• When results are ready to share, publication costs are presumptively unallowable, and any public communication that could be labeled issue advocacy on a sensitive topic puts the entire award at risk.

The rule is also notable for what it cites as justification. The preamble relies heavily on Heritage Foundation reports, partisan Senate committee documents, and White House fact sheets, rather than independent scientific or administrative assessments. It characterizes decades of peer-reviewed research on climate, public health, equity, and international collaboration as “woke,” “neo-Marxist,” “anti-American,” or “divisive ideology.” It treats the scientific community’s professional infrastructure, including conferences, journals, international partnerships, and open access publishing, as wasteful overhead to be controlled or eliminated.

Congress has repeatedly appropriated funds for science agencies with the expectation that those funds would be administered through merit-based, expert-driven processes insulated from political interference. This rule attempts to override that expectation administratively, without new legislation, by repurposing OMB’s grants management authority as a vehicle for political control of science.

The public comment period closes approximately July 13, 2026 (45 days from May 29 publication). Comments must be submitted to regulations.gov, Docket OMB-2026-0034.

Scientists, universities, scientific societies, patient advocacy organizations, state governments, and members of the public all have standing to comment. Given the scope of what is proposed, the breadth and volume of opposition in the formal record will matter both legally and politically.

This image was generated by Google AI (Gemini)

About a year ago, President Trump issued his Executive Order “Restoring Gold Standard Science.” Section 3(d) required agency heads to “report to the OSTP Director on the actions taken to implement Gold Standard Science” within 60 days.

So, on August 22, 2025, the National Institutes of Health released a document called “Leading in Gold Standard Science: An NIH Implementation Plan” including a foreword by NIH Director Jay Bhattacharya. The plan committed NIH to the nine tenets of scientific excellence outlined in the EO: reproducibility, transparency, interdisciplinary collaboration, unbiased peer review, and more. Then it catalogued existing NIH programs (which started long before the Trump administration), described a few new initiatives, and projected confidence about the agency’s commitment to rigorous science.

“Gold standard science isn’t just what we strive for, it is embedded in everything we do, from the research we support to the policies and programs we create.” - Jay Bhattacharya, NIH Director

Curiously, near the end of the document, on pages 13 and 14, the plan made a specific and verifiable promise. It said that NIH would evaluate adherence to all nine tenets using “several frameworks.” It promised to develop “composite measure indexes” to augment evaluation metrics. And it indicated that NIH would “post annual updates of evaluation progress and findings online, sharing widely with public audiences.”

Nine months have passed. No evaluation report exists. This should surprise no one. The NIH “Gold Standard Science” document was simply EO compliance dressed up as institutional substance. But why promise an evaluation? Perhaps an attempt to appear credible and scientific?

As a former NIH Program Officer of 22 years, and a scientist who has been involved in many actual scientific evaluation projects, frankly, I laughed out loud at this section of the NIH plan. It was completely ridiculous, just as ridiculous as the EO.

Pages 13-14:

Defining Our Success

Evaluation of our programs, policies, and initiatives is foundational to ensuring NIH continues to deliver results for the public. Current and planned NIH initiatives will be periodically assessed for adherence to the nine tenets via initiative-specific retrospective or prospective evaluation. Evaluation metrics will be augmented with several composite measure indexes that are under development.

Evaluation Strategy

NIH may rely upon several frameworks to guide its evaluation activities: the simplified Consolidation [sic] Framework for Implementation Research (CFIR)² to guide evaluation of the pre-implementation phase; the Reach Effectiveness Adoption Implementation Maintenance (RE-AIM)³ framework to guide evaluation of the implementation and post-implementation phases; and Proctor’s Implementation Outcomes Framework (IOF)⁴, a framework for translating research into practice and planning programs to improve the odds for successful implementation in “real-world” settings. The use of these frameworks will enable NIH to evaluate adoption, implementation fidelity, and acceptability of aspects of gold standard science as well as sustainability and scalability after initial implementation.

Evaluation Transparency

NIH will post annual updates of evaluation progress and findings online, sharing widely with public audiences. Additionally, through channels such as evaluation presentations at local, regional, and national medical and public health professional meetings, NIH plans to disseminate information on its efforts to support the translation, communication, and incorporation of the nine gold standard science tenets while informing the public of its progress in affirming gold standard science.

Evaluation Structure

Below is a sample evaluation planning table for tenet, Reproducible, subject to refinement based on feasibility, scoping, and resources.

________________________

² Damschroder LJ, Reardon CM, Widerquist MAO, Lowery J. The updated Consolidated Framework for Implementation Research based on user feedback. Implement Sci. 2022 Oct 29;17(1):75.

n.b. CFIR is a comprehensive typology of constructs likely to influence the implementation of Evidence-Based Innovations (EBIs): (a) intervention characteristics, (b) outer setting, (c) inner setting, (d) characteristics of individuals, and (e) the implementation process.

³ Glasgow RE, Vogt TM, Boles SM. Evaluating the public health impact of health promotion interventions: the RE-AIM framework. Am J Public Health. 1999 Sep;89(9):1322-7.

⁴ Proctor E, Silmere H, Raghavan R, Hovmand P, Aarons G, Bunger A, Griffey R, Hensley M. “Outcomes for implementation research: conceptual distinctions, measurement challenges, and research agenda.” Adm Policy Ment Health. 2011 Mar;38(2):65-76.

The Promise

To those unfamiliar with legitimate evaluation research, perhaps this appears reasonably constructed. It names three specific scientific frameworks it would use to guide assessment: the Consolidated Framework for Implementation Research (CFIR), as described in Damschroder et al. (2022); the Reach, Effectiveness, Adoption, Implementation, Maintenance (RE-AIM) framework, as described in Glasgow et al. (1999); and Proctor’s Implementation Outcomes Framework (IOF), as described in Proctor et al. (2011). These are all real, peer-reviewed frameworks, published in respected journals, with extensive citation records. Their inclusion in the document creates a strong impression of methodological seriousness.

The plan even organized these frameworks by phase. CFIR would guide evaluation in the “pre-implementation phase.” RE-AIM would guide the “implementation and post-implementation phases.” Proctor’s IOF would help translate research into practice and plan programs for “real-world settings.” Below this description, NIH provided a sample evaluation planning table for the first tenet, Reproducibility, listing objectives, outcomes, measures, metrics, analytic tools, data sources, and mechanisms.

It looks like a plan. It reads like a plan. It is not a plan.

What Implementation Science Actually Does

To understand why, it helps to understand what implementation science actually is.

Implementation science, as defined by Eccles and Mittman in 2006, is the scientific study of methods to promote the systematic uptake of research findings and other evidence-based practices into routine clinical practice, in order to improve the quality and effectiveness of health services. A useful plain-language summary comes from a 2024 commentary by Frances Chu in the Journal of the Medical Library Association. Chu describes it this way: the intervention or practice being studied is “The Thing.” Efficacy and effectiveness research asks whether The Thing works. Implementation research then asks how to get people and organizations to do The Thing (Chu, 2024, citing Curran, 2020).

Crucially, implementation science presupposes that The Thing has already been proven to work. It does not evaluate whether agency aspirations are being met. It studies whether a defined, evidence-based practice is being adopted by identifiable implementers in a specific healthcare delivery setting, and what barriers and facilitators shape that adoption. As Chu notes, “the expectation is that an intervention has been demonstrated to be efficacious and effective” before implementation science enters the picture.

This precondition and purpose are not a technicality. They are the entire foundation on which all three of NIH’s cited frameworks rest.

Implementation Science Frameworks are Completely Irrelevant to the NIH Gold Standard Science Implementation Plan

CFIR is what researchers call a determinant framework. Its purpose, as described by Damschroder et al. (2022), is to identify barriers and facilitators to implementing a defined evidence-based innovation. Before CFIR can be used, users must complete three mandatory steps: define the innovation being implemented, replace broad construct language with project-specific language, and identify the individuals who have power and influence over implementation outcomes.

NIH’s plan identifies no innovation. “Gold standard science” is a set of normative aspirations, not a manualized intervention with developers whose intent could be operationalized. There is no evidence base being translated into practice, no prior efficacy trial of “reproducibility,” no defined setting in which adoption is being measured. Damschroder and colleagues are explicit: “The CFIR must be fully operationalized prior to use in a project.” NIH’s plan skips operationalization entirely because it is structurally impossible to complete given what the plan is actually describing.

RE-AIM was developed by Glasgow et al. (1999) to evaluate the population-level impact of health promotion interventions across five dimensions: Reach, Efficacy, Adoption, Implementation, and Maintenance. Each dimension requires specific, measurable inputs. Reach is defined as an individual-level measure of the percentage of the target population that participated in the intervention. Adoption refers to the proportion of settings that adopt a given policy or program. Maintenance assesses whether innovations become a stable part of an organization’s behavioral repertoire, with a minimum assessment window of two years.

Now apply these requirements to NIH’s commitment to “reproducible” science. Who are the individual participants whose reach is measured? What is the adoption rate across which defined settings? What behavior at the individual level is being maintained? The plan’s own sample evaluation planning table for tenet 1, Reproducible, proposes metrics like “percentage change in the number of NIH-funded studies meeting protocol standards” and “peer review scores on experimental design.” These may or may not be reasonable things to track. But they have absolutely nothing to do with RE-AIM, which was designed to evaluate smoking cessation programs, diabetes interventions, and worksite health promotion, not the normative commitments of a federal science agency.

Proctor’s Implementation Outcomes Framework defines eight conceptually distinct implementation outcomes: acceptability, adoption, appropriateness, feasibility, fidelity, implementation cost, penetration, and sustainability (Proctor et al., 2011). Each of these outcomes requires a specific evidence-based practice as its referent. Fidelity, for example, is defined as the degree to which an intervention was implemented as it was prescribed in the original protocol or as intended by its developers. Penetration is the integration of a practice within a service setting and its subsystems.

The questions that follow are unanswerable given what NIH has written. Fidelity to what protocol? Penetration of what practice into which service setting? There are no developers whose intent can be measured against. There is no protocol. There is no service setting in the implementation science sense. Proctor’s framework is a tool for understanding whether a specific medical or behavioral health treatment is being delivered consistently across clinics. It cannot evaluate whether a government agency sincerely values unbiased peer review.

The Deeper Problem

It would be charitable to read the citation of these frameworks as a well-intentioned error, the result of a dutiful junior staff member who added these framework citations without fully understanding what they do. That charitable reading is available.

But it strains credulity when applied to Bhattacharya, who is a trained health economist with deep familiarity with research methodology, and whose name and opening quotation appear on the document. It strains credulity further when one notices that the frameworks were not cited generically but with specific journal article references, in a section organized by implementation phase, and yet the plan cannot correctly name the first framework it cites, calling it the “Consolidation Framework” rather than the Consolidated Framework for Implementation Research. Someone knew enough to find the citation. Nobody knew enough to read it carefully. The result is that three legitimate scientific frameworks were erroneously conscripted into an evaluation context for which none of them were designed.

The more uncomfortable interpretation is that the citations are doing what decorative citations always do: creating the appearance of rigor without the substance. They tell a reader who does not look closely that serious methodological thought has gone into this evaluation strategy. They tell a reader who does look closely something else entirely.

This is what evaluation theater looks like. Not the absence of evaluation, which can sometimes reflect genuine resource constraints or bureaucratic delay. Evaluation theater is the performance of evaluation: frameworks cited, phases described, metrics listed, an annual report promised, none of it connected to a coherent methodology that could actually produce findings.

Nine Months of Silence

The plan promised that NIH would “post annual updates of evaluation progress and findings online, sharing widely with public audiences.” It promised dissemination at “local, regional, and national medical and public health professional meetings.” Nine months after publication, none of this exists so far.

The silence is consistent with what we would expect from a plan that was never operationally serious. It was a political document. An evaluation cannot be conducted using frameworks that do not apply to the thing being evaluated. The absence of a report is not the primary evidence of failure. It is the predictable consequence of a methodology that could never have worked.

There is also a structural irony worth naming. One of the plan’s nine tenets is transparency. The plan itself claimed that “public input and accountability are embedded throughout NIH processes.” The commitment to post annual evaluation findings publicly was, by the plan’s own logic, a transparency commitment. A document that cannot meet its own stated standards for transparency is a document that deserves scrutiny on all its other claims as well.

What a Real Evaluation Would Require

This is not a counsel of impossibility. Evaluating whether a federal science agency is living up to its commitments is hard, but it is not methodologically mysterious.

Appropriate frameworks would include program logic models and theory of change approaches that clearly specify inputs, activities, outputs, and outcomes. The NIH already operates under the Government Performance and Results Act, which has its own performance measurement infrastructure that could be adapted here. Scientometric and bibliometric methods, which are well-established in research evaluation, could track preregistration rates, data sharing compliance, replication study outcomes, and retraction rates across NIH-funded research over time. These methods are not exotic. They are what research evaluation actually looks like.

The choice to invoke implementation science frameworks instead is therefore conspicuous. It is not the choice of a team that surveyed the methodological landscape and selected the best tools. It reads like the choice of a team that needed the section to appear rigorous and found credentialed-sounding names to paste into the document. Their evaluation strategy was word salad.

Why This Matters

I have been documenting the decline of the NIH on this Substack because I believe the erosion of this institution has consequences that will unfold over years and decades, long after the current political moment passes. The “Gold Standard Science” plan has attracted criticism on the most obvious grounds: it was issued by an administration that has cancelled grants for political reasons, suppressed CDC findings on vaccine effectiveness, and systematically shut down entire programs of science it finds ideologically inconvenient. Those criticisms are valid and important.

But the evaluation section of this plan deserves its own attention, for a different reason. It is a case study in how bureaucratic documents can be constructed to look serious while committing to nothing.

This is not how well-intentioned bureaucracies stumble. Bureaucracies that stumble produce flawed evaluations, belated reports, metrics that miss the mark. What this NIH plan produced is something more insidious: a document structured to look like accountability while making accountability impossible. Authoritarian-style governance has long understood that the appearance of scientific rigor is more politically useful than the rigor itself. You cite the frameworks, you name the phases, you promise the annual report, and you collect the credibility without ever submitting to the scrutiny. Evaluation theater does not produce findings that can embarrass anyone. That is not a bug. It is the design.

These are not people who are serious about science. I implore the public. Stop treating Jay Bhattacharya as if he is a worthy holder of the NIH Director’s title.

References

Chu, F. (2024). Implementation science: Why should we care? Journal of the Medical Library Association, 112(3), 281-285. https://doi.org/10.5195/jmla.2024.1919

Exec. Order No. 14,303, 90 Fed. Reg. 22,601 (May 29, 2025). Restoring gold standard science. https://www.federalregister.gov/documents/2025/05/29/2025-09802/restoring-gold-standard-science

Damschroder, L. J., Reardon, C. M., Opra Widerquist, M. A., & Lowery, J. (2022). The updated Consolidated Framework for Implementation Research based on user feedback. Implementation Science, 17(1), Article 75. https://doi.org/10.1186/s13012-022-01245-0

Glasgow, R. E., Vogt, T. M., & Boles, S. M. (1999). Evaluating the public health impact of health promotion interventions: The RE-AIM framework. American Journal of Public Health, 89(9), 1322-1327. https://doi.org/10.2105/ajph.89.9.1322

National Institutes of Health. (2025, August 22). Leading in gold standard science: An NIH implementation plan. U.S. Department of Health and Human Services. https://www.nih.gov/sites/default/files/2025-08/2025-gss.pdf

Proctor, E., Silmere, H., Raghavan, R., Hovmand, P., Aarons, G., Bunger, A., Griffey, R., & Hensley, M. (2011). Outcomes for implementation research: Conceptual distinctions, measurement challenges, and research agenda. Administration and Policy in Mental Health and Mental Health Services Research, 38(2), 65-76. https://doi.org/10.1007/s10488-010-0319-7

This essay is part of an ongoing series reflecting on what I learned over more than two decades working inside the U.S. biomedical research enterprise. Each piece stands alone, but together they examine how science is shaped not only by ideas and funding, but by the structures that support or constrain them.

On September 26, 2023, the National Institute on Minority Health and Health Disparities published a Notice of Funding Opportunity (NOFO). Its title was straightforward: Health and Health Care Disparities Among Persons Living with Disabilities (R01, Clinical Trials Optional). Its purpose was equally plain: to support research examining why people with disabilities receive worse health care than people without disabilities, and what can be done about it. Fourteen NIH institutes had agreed to participate (NIMHD, NEI, NHGRI, NIA, NIAAA, NIAMS, NIBIB, NICHD, NIDA, NIDCD, NINDS, NINR, NCI, NIDDK). Researchers across the country began planning applications.

On February 22, 2025, this funding opportunity was canceled.

Today, if you go to the original NIH web address for that announcement (grants.nih.gov/grants/guide/pa-files/PAR-23-309.html) you will find nothing. The server returns a 404 error. The page does not redirect. It does not say the announcement was closed or archived. It simply does not exist. The only way I was able to confirm the full content of this funding opportunity was to take that URL to the Wayback Machine, the internet archive, and search for old captures of the page before it was removed. There, frozen in time, is what NIH once planned to fund: research on the health of people with disabilities, at the intersections of race, ethnicity, and socioeconomic status. This is research that the Trump administration has decided should not exist.

If you read that now deleted NOFO you will see this rationale:

The population of persons living with disabilities in the United States is heterogeneous, estimated at 24–26% of adults and 4.3% of children from various backgrounds, life circumstances, and health conditions. Impaired mobility (13.7%), cognition (10.8%), and independent living (6.8%) are the most common disabilities among adults, and impaired cognition (4.4%) is most common among children. Data indicate that, on average, individuals living with disabilities have poorer health-related quality of life and overall health, as well as decreased healthy life expectancy and longevity compared with people without a disability. Adults living with disabilities have a higher prevalence of preventable, chronic, and complicating comorbidities compared with the overall adult population. Examples include obesity (38.2% versus 26.2%), tobacco smoking (28.2% versus 13.4%), diabetes (16.3% versus 7.2%), and heart disease (11.5% versus 3.8%). Among persons of childbearing age, 12% live with at least one disability and are at a higher risk for maternal morbidity and mortality.

PAR-23-309 is one of 110 NIH funding announcements, posted notices or planned forecasts, that I have identified as canceled since January 20, 2025. I assembled this censored science dataset from crowdsourced spreadsheets compiled in early 2025, grants.gov archive records, and, in some cases, Wayback Machine captures of pages that no longer exist on NIH’s own website. In a prior essay, I described 35 forecasts that were archived, but since then, I found 75 more NOFOs to add to the list. Because so many funding announcements were eliminated from the NIH website, it is possible that I still may have missed some, but to the best of my knowledge this is the most complete list assembled to date.

At the same time, I have been closely tracking all of the brand-new funding opportunities that NIH has posted since January 20, 2025. As I have documented in my prior essays, the number of posted NOFOs has declined dramatically under the Trump administration.

In this essay I will present both halves of what the data reveal: the 110 announcements that were deleted, and the 113 that were permitted under the Trump administration. The contrast between these two lists is not random. This is a story about scientific censorship, a deliberate termination of whole categories of science, and a determination of the categories of science that are politically palatable and will be allowed to continue.

In PART ONE of this essay, I lay out the scale of the deleted NOFOs and describe four categories or types of cancellations. The first category is the so called “DEI” deletions. The second category reflects the termination of all research related to HIV vaccine and cure research. The third category of NOFO cancelations are the result of the political choice by the Trump administration to abandon funding for research related to biodefense and global health research. The fourth and final category of deletions is occurring because of a new NIH policy of administrative centralization and control, wherein the individual institutes, centers, and offices are no longer allowed to issue funding announcements unless they receive political approval.

Then in PART TWO of this essay, I will briefly discuss the political policies that are driving this scientific censorship at the NIH. Finally, in PART THREE, I will reveal what kind of science is being permitted now, in essence, what scientific programs were able to avoid the wrecking ball (at least so far).

PART I: What Was Deleted

The 110 canceled announcements break into two categories: 70 posted Notices of Funding Opportunity that were open for applications, publicly announced, and already being used by researchers to plan their work; and 40 forecasted opportunities that were announced to the research community through grants.gov and then formally blocked before they could be published as full NOFOs.

Of the 70 canceled NOFOs, 69 were published before January 20, 2025. This means that the dominant activity documented here was not simply a refusal to issue new science. It was the retroactive cancellation of science gaps already identified, representing existing federal commitments to specific research priorities. The Trump administration reached back into the record and shut them down.

The scale and speed of that deletion is documented in the grants.gov archive. On February 22, 2025 alone, 49 posted NIH funding announcements were canceled. In the month of February 2025 overall, 62 were canceled. There was no scientific review. There was no advisory council deliberation. The announcements were active one day and marked “Closed” the next, with no explanation in the grants.gov system except that single word. While the records still exist as archives in grants.gov, the original NIH guide web pages have been deleted. The URLs for these “closed” records all return a 404 error.

Beyond the 70 canceled posted NOFOs, 40 forecasted opportunities were archived. These reflected planned funding announcements that NIH originally intended to publish but were then blocked. These fall into two distinct categories, distinguished by the language NIH used to close them. The earlier group, archived beginning in April 2025 by DOGE, carries this notation: “Archiving forecast pending further agency review.” The implication is that this was a temporary hold, not a final decision. That review never came. The later group, archived in 2026 by current NIH leadership, uses blunter language: “This NOFO will not be published. The Forecast is being archived.” No ambiguity, no promise of reconsideration. The shift in language between those two periods is itself evidence of a policy that grew more confident in its own authority over time.

The table below summarizes all 110 cancellations by the method used to erase them, from the most formally documented to the most thoroughly hidden.

And then there are the four announcements erased so completely that even grants.gov contains no trace of them. PAR-23-309, the disability health disparities NOFO that opens this essay, is one of them. The others are PAR-24-038, a NIDCR award to study institutional climate and how it affects faculty careers; PAR-24-212, a NINDS career transition award to promote diversity in Alzheimer’s disease research; and PAR-24-224, the NIGMS MOSAIC Organizational Research Education Award to Promote Diversity. For all four, finding out what they said required going to the Wayback Machine to find frozen records of science the Trump administration has decided should not be remembered.

The Content of the Deleted Science: Category One: DEI-Labeled Programs

The administration calls this research “DEI,” and has provided the official definition. In a strategic priorities statement published August 15, 2025, the NIH Director, Jay Bhattacharya, wrote that “research based on ideologies that promote differential treatment of people based on race or ethnicity, rely on poorly defined concepts or on unfalsifiable theories, does not follow the principles of gold-standard science,” and that broad claims attributing worse health outcomes to “poorly measured factors like systemic racism should not be presented as established background facts.” That is the ideological filter. Applied to a funding announcement, it becomes a keyword screen with a political policy rationale.

Of the 110 canceled announcements, 72 contained explicit language related to diversity, equity, health disparities, or underrepresented populations. Thirty-five were specifically workforce training and career development programs targeting the scientific pipeline, the mechanisms by which NIH was building a more diverse biomedical research workforce. These are not marginal programs. They are named programs with long histories and documented outcomes: G-RISE (Graduate Research Training Initiative for Student Enhancement), U-RISE (Undergraduate Research Training Initiative for Student Enhancement), MARC (Maximizing Access to Research Careers), IMSD (Initiative for Maximizing Student Development), Bridges to the Doctorate, and the MOSAIC program in three of its four variants, all canceled on the same day from NIGMS.

Thirteen of the canceled announcements involved HIV and AIDS research at the intersection of health equity or substance use, touching multiple politically flagged categories simultaneously. The NIDA “Reaching Equity at the Intersection of HIV and Substance Use” forecasts named all three in a single title. Sixteen involved substance use and addiction research, including three NIAAA forecasts that carried explicit health disparities and equity framing. Eleven of the canceled announcements specifically addressed racial and ethnic health. Six touched environmental health. Three addressed LGBTQ health.

The career pipeline deserves its own accounting because the numbers are stark. Across the 110 canceled announcements: 9 K99/R00 postdoctoral-to-independence career transition awards, 8 T-award training programs, 6 F-award fellowships, 2 R36 dissertation awards, and additional predoctoral and postdoctoral transition mechanisms. These are the grants that bring early-career researchers from training into independent scientific careers. Their cancellation does not only affect current science. It shapes who will be doing science in America ten years from now. The diagram below maps 47 canceled career and training programs by career stage. Every stage of the scientific career pipeline was cut.

The Policy That Was Erased Along with the Programs

The administration’s characterization of all this as “DEI” erases something important: these programs did not emerge from political ideology. They emerged from science.

In November 2019, NIH published NOT-OD-20-031: Notice of NIH’s Interest in Diversity, the formal scientific policy foundation that authorized and guided the workforce training and health disparities programs now canceled. The notice opened by stating it was “informed by a literature review, the reports and deliberations of several internal NIH committees, as well as input from Institute and Center officials, program staff and external stakeholders.” It was a deliberate, evidence-based, democratic process of the kind federal agencies are designed to conduct.

The notice documented in precise scientific terms who was underrepresented in the biomedical research workforce and why that mattered: racial and ethnic groups shown by National Science Foundation data to be underrepresented in health-related sciences; individuals with disabilities as defined by the Americans with Disabilities Act; individuals from disadvantaged socioeconomic backgrounds meeting defined federal criteria; and women underrepresented at senior faculty levels in biomedical disciplines. These were not political categories invented by activists. They were evidence-based designations grounded in decades of workforce data.

The notice made NIH’s reasoning explicit: “Research shows that diverse teams working together and capitalizing on innovative ideas and distinct perspectives outperform homogenous teams.” The canceled NOFOs, including G-RISE, U-RISE, MARC, MOSAIC, IMSD, Bridges to the Doctorate, and the health disparities R01s, were the implementation of that evidence-based conclusion.

A final point about these programs deserves stating plainly, because the administration’s “discriminatory” framing obscures it. These programs were additive, not exclusionary. G-RISE, U-RISE, MARC, IMSD, MOSAIC, and Bridges to the Doctorate did not remove funding from majority-group researchers. The parent mechanisms, the standard T32s and K99/R00s and F-awards open to any investigator, continued alongside them. A graduate student who was not from an underrepresented background lost nothing when G-RISE existed. That same student loses nothing now that G-RISE is gone. What is lost belongs entirely to the first-generation student from a minority-serving institution, the researcher with a disability, the scientist from a rural or low-income background, for whom the targeted program provided the specific infrastructure that made the parent mechanism accessible. The administration did not restore equal access. It removed the scaffolding that made equal access achievable for people who faced documented structural disadvantages.

NOT-OD-20-031 has been removed from NIH’s website. I found it through the Wayback Machine, which captured the page on December 25, 2024, less than a month before the administration took office. A notice that took years of literature review, committee deliberations, and stakeholder input to produce was quickly deleted along with the programs it authorized. What remains is an archive snapshot and the record of what NIH once believed about its own mission.

Category Two: The Suppression of HIV Vaccine and Cure Science

Trofim Lysenko was a Soviet agronomist and biologist who rose to power under Joseph Stalin by promoting pseudoscience. In 1940 Lysenko became director of the Institute of Genetics of the Soviet Academy of Sciences, where he used his political influence to suppress dissenting opinions and discredit, marginalize, and imprison his critics, elevating his anti-Mendelian theories to state-sanctioned doctrine. He did not simply cut Soviet biology funding. He replaced legitimate genetics with a politically acceptable alternative, enforced by the state, and destroyed the careers of scientists who practiced the disfavored science. The parallel is not rhetorical. It is structural, and it is most precise when applied to the second category of science being suppressed right now by NIH.

Not one of the following six canceled National Institute of Allergy and Infectious Diseases (NIAID) funding announcements contains a single word of DEI language. No “diversity.” No “equity.” No “disparities.” No “underrepresented.” These are not programs that were caught in a keyword sweep. They were targeted and killed on different dates, through different mechanisms, for a different reason. They represent the science of ending the AIDS epidemic, and that science is now politically forbidden.

The five posted NOFOs, all published in December 2024 and all canceled via NIAID administrative notices in February 2026 more than a year after they were posted, covered the full scientific pipeline of HIV cure and vaccine research:

PAR-25-300: Targeting Cell Surface HIV Envelope for Cell Elimination (R01): Support investigation of HIV-1 Envelope (Env) cell surface expression, the structural mechanism of biologic-mediated cell killing, and novel approaches to enhance the recognition and elimination of HIV-infected cells. These studies were expected to “inform the development of immunotherapies and targeted vaccines for HIV-1 prevention and cure.”

PAR-25-330: Role of Defective Proviruses in HIV Persistence (R01): Define the impact of defective HIV proviruses on mechanisms of HIV persistence during antiretroviral treatment and their potential interference with HIV cure strategies. This is fundamental research into why HIV cannot currently be cured despite effective treatment.

PAR-25-315 and PAR-25-316: Immunometabolic Responses to HIV Infection that Increase TB or HBV Risk (R01 and R21): Elucidate how HIV-induced immune dysregulation in patients on antiretroviral therapy increases their risk for tuberculosis and hepatitis B. Understanding how HIV compromises immunity against secondary infections is critical to protecting the 39 million people worldwide living with HIV.

PAR-25-099: Planning for Product Development Strategy (R34): Support development of a comprehensive product development strategy for next-generation HIV treatments and preventive strategies, explicitly aimed at enabling submission of an Investigational New Drug (IND) application to the FDA. This was a pipeline grant, the mechanism for turning research into actual medical products.

The sixth, RFA-AI-27-020, is the most consequential of all. Titled “Consortia for Structure-based Immunogen Design for HIV (CSID-HIV),” it was a major consortium grant to advance the development of broadly neutralizing antibodies (bNAbs), the scientific foundation of next-generation HIV vaccines. Its description is worth reading in full: it sought to “advance the development and selection of HIV immunogens that induce broadly neutralizing antibody responses” to be “advanced into clinical testing,” with “the ultimate goal to achieve proof of concept of therapeutic strategies using bNAbs and vaccine-induction of bNAbs targeting multiple bNAb sites.” The notice added that “the technology being developed through these consortia will be applicable to other fields facing significant hurdles in viral antigen therapeutic targeting and vaccine design.” This is structure-based immunogen design, the same class of technology that underlies mRNA vaccine development and that has been demonized by anti-vaccine activists including RFK Jr.

RFA-AI-27-020 entered the grants.gov forecast system on September 15, 2025, the same productive cohort as the psychedelics NOFO examined earlier in this series. Compare what happened to each. The psychedelics NOFO, after sitting in the approval queue for 316 days, cleared in eleven days once the President signed an executive order directing its release. The HIV vaccine consortium sat for 219 days and was formally killed on April 22, 2026 with the notation: “This NOFO will not be published. The Forecast is being archived.” Both entered the same queue at approximately the same time. One aligned with the ideology of the people controlling the approval process. One did not.

The broader policy context for these cancellations was made explicit by Jay Bhattacharya himself. In an August 12, 2025 Washington Post op-ed titled “Why the NIH is pivoting away from mRNA vaccines,” he defended the administration’s decision to terminate 22 mRNA vaccine projects worth $500 million across NIH and HHS. His central argument was not that the science had failed. It was that the public had rejected it. “No matter how elegant the science,” he wrote, “a platform that lacks credibility among the people it seeks to protect cannot fulfill its public health mission.” As evidence, he cited a Pew Research Center survey showing 60 percent of Americans did not intend to get an updated coronavirus mRNA vaccine. A poll result, in other words, constituted sufficient scientific grounds to terminate a research platform. Bhattacharya also raised scientific objections to mRNA technology, citing uncertainty about dosage, biodistribution, and off-target effects. But these two arguments contradict each other. If the platform is scientifically unsound, public trust is irrelevant; or if public trust is the standard, the science must be sound enough to matter. That both arguments appear in the same document reveals that neither is the actual reason. The decision was ideological, dressed in the language of science.

What Bhattacharya announced as the replacement is equally revealing. NIH would pivot to “whole-virus inactivated vaccines, which offer a broader immune response and have a longer track record of safety and public acceptance.” For HIV specifically, whole-virus inactivated vaccine approaches have been attempted and failed for decades. They are not a path to an HIV vaccine. They are a politically acceptable substitute for the science that might actually work. The structure-based immunogen design and broadly neutralizing antibody research in RFA-AI-27-020, the consortium archived on April 22, 2026, represents precisely the scientific frontier that Bhattacharya’s pivot is designed to close down. He noted that NIH would continue mRNA research for oncology, but HIV vaccine development is not permitted. This is not a general retreat from mRNA science. It is a specific, targeted elimination of the mRNA and bNAb-based research that offers the most credible path to ending the AIDS epidemic, replaced by older technology with a worse scientific track record, chosen because it is more politically palatable. That is Lysenkoism. Not as metaphor. As operational policy.

Bhattacharya’s stated rationale, public distrust of mRNA technology, is a way to avoid naming the actual driver. That driver is the ideology of his boss. Rolling Stone documented in June 2023 that Robert F. Kennedy Jr., now Secretary of Health and Human Services, has publicly claimed that AIDS was not caused by HIV but by “a gay lifestyle” and the use of alkyl nitrites. He repeated the same AIDS denialism in his 2021 book and again on Joe Rogan’s podcast. He has also asserted without evidence that HIV itself was created by vaccine research, adding: “the medical research on these diseases and vaccine research has actually created some of the worst plagues in our history.” At the same event, he stated: “I do not believe that infectious disease is an enormous threat to human health,” and said that as president he would redirect funding grants away from epidemiology.

The scientific consensus that HIV causes AIDS is not a contested finding. It was established by Koch’s postulates, confirmed at the molecular level, and demonstrated daily by the success of antiretroviral therapy in the tens of millions of people living with HIV worldwide. Kennedy’s claims are not a minority scientific view. They are straightforwardly false, rejected by the entire body of evidence accumulated over four decades. The man who holds these beliefs is now the director of the department that controls NIH policy. The man who serves under him is now the NIH director. Together, they have canceled every NIH funding mechanism designed to develop new HIV vaccines and cures. The “public trust” explanation is not the reason. It is the cover story. This is the Lysenko structure in its most precise form: a state official who rejects established science on ideological grounds, placed in a position of authority over the agency that funds that science, using administrative power to eliminate research that contradicts his preferred belief. Lysenko did not believe in genetics. Kennedy does not believe HIV causes AIDS. Both used state authority to suppress the science that proved them wrong.

The contrast with what NIAID is being permitted to fund makes the pattern explicit. NIAID’s 12 allowed Trump-era NOFOs include tuberculosis vaccine development programs, Hepatitis C vaccine rational design, and influenza transmission consortia. Vaccine science for TB: permitted. Vaccine science for Hep C: permitted. Vaccine science for influenza: permitted. Vaccine science for HIV: zero. This is specifically and exclusively a policy against HIV vaccine and cure research. The strategic priorities document Bhattacharya published in August 2025 stated that “ending the HIV epidemic in the United States remains a key priority,” but defined that priority narrowly as “implementation science and other research directions to improve the uptake of and access to existing medical and behavioral interventions.” Uptake of existing tools, not development of new ones. The six canceled NIAID programs documented above were developing new tools. The stated priority and the actual policy cannot both be true.

This week, a Nature report revealed that eight of the top ten scientific career officials at NIAID all have been pushed out since President Donald Trump took office (Kozlov, 2026).

Category Three: The Suppression of Biodefense and Global Health Science

The third category of suppressed science is related to Category Two and is perhaps the most consequential for national security. It involves the systematic dismantling of the scientific infrastructure the United States uses to detect and respond to biological threats.

In early 2026, Bhattacharya co-authored a paper published in Nature Medicine formally announcing the reorganization of NIAID. The paper stated explicitly: for decades NIAID had focused on three areas, HIV, biodefense and pandemic preparedness, and all other immunological and infectious diseases. Their new vision replaces all three with just two strategic aims: infectious diseases and immunology. Biodefense and pandemic preparedness are not named. The paper was co-authored by the NIH director himself, published in a peer-reviewed medical journal, and available to the scientific community from January 2026. It is not a leaked internal memo or an anonymous account. It is Bhattacharya’s own published statement of what NIAID will and will not do. Around the same time, NIAID staff were ordered to delete the words “biodefense” and “pandemic preparedness” from the institute’s website, with four staff members telling Nature they expect NIAID to deprioritize all three of its traditional research pillars (Kozlov, 2025). This may explain the Countermeasures Against Chemical Threats (CounterACT) forecast cancellation (NOT-NS-24-126), a program to develop therapeutics against toxic chemical exposure, archived in April 2025. It was swept not because of its content but because the entire category of biodefense had been deprioritized. Its subject matter had become impermissible. As Nahid Bhadelia of Boston University’s Center on Emerging Infectious Diseases told Nature: “Just because we say we’re going to stop caring about these issues doesn’t make the issues go away. It just makes us less prepared” (Kozlov, 2025).

On May 1, 2025, NIH announced it would stop renewing or issuing foreign subawards, the funds that allow US researchers to collaborate with international partners. Previously NIH had been spending about $500 million per year on these awards, and in 2024 issued approximately 3,700 of them to institutions abroad. The new policy targets all foreign subawards regardless of the country involved, whether an adversary like China or an ally like the United Kingdom, and states that research projects will be terminated if they are no longer viable without the foreign component. Nature reported that former NIH director Francis Collins called the decision “short-sighted and self-defeating,” noting that disease outbreaks can reach American shores within hours and that combined with the shuttering of USAID, more children and adults in low-income countries will lose their lives because the research did not get done. A former senior NIH employee described the policy plainly: if the administration’s goal is to end funding for research abroad but they lack the legal authority to do so directly, making the bureaucracy much more difficult achieves the same result (Kozlov, 2025).

The NIMH funding announcement for mental health integration in low- and middle-income countries (PAR-25-201), canceled February 25, 2025, is one NOFO-level expression of this policy. Research explicitly designed to strengthen health systems abroad was canceled in the same week the foreign subaward termination policy was being prepared. The NIH Extramural Nexus published a “foreign interference” update in May 2026 establishing a compliance architecture of decision matrices, disclosure forms, and security training requirements framed as protecting American science from “undue foreign influence.” The architecture is real and the security concerns behind it are not imaginary. But the operational effect is to discourage the international collaboration that disease surveillance, pandemic preparedness, and global health research depend on. The policy simultaneously eliminates the domestic infrastructure for biodefense and the international collaboration that early warning requires. No bioterrorism threat becomes less dangerous because NIH stopped studying it. No pandemic becomes less likely because American scientists stopped collaborating with researchers in the countries where outbreaks originate. The Soviet Union under Lysenko also isolated its science from international knowledge, treating foreign scientific exchange as ideologically suspect. The result was not strength. It was catastrophic agricultural failure.

Category Four: Administrative Centralization

A fourth category of canceled science requires a different explanation entirely. These programs contain no DEI language, no vaccine or biodefense content, and no ideological signature. They were eliminated because the Jon Lorsch centralization initiative, described in detail in another of my essays in this series and driven by Bhattacharya’s “Unified Strategy,” is systematically eliminating targeted, institute-specific mechanisms in favor of broad parent announcements.

The clearest examples are the four NIAMS forecasts archived on April 17, 2026. They called for resource-based centers for rheumatic diseases research, resource-based centers for bone and musculoskeletal research, core centers for clinical research, and an ancillary studies mechanism. The practical consequence for NIAMS, the institute responsible for arthritis, lupus, osteoporosis, scleroderma, and other inflammatory and musculoskeletal diseases, is that its entire planned center infrastructure for 2025 to 2026 has been dismantled. What NIAMS is being permitted to fund instead are two limited competition renewals of the congressionally mandated Regenerative Medicine Innovation Project and one chemical threats to skin program soliciting basic research on pathological mechanisms of skin injuries caused by toxic Chemicals of Concern (CoC).

The same pattern applies to the NIAAA Comprehensive Alcohol Research Centers (P60), a center infrastructure program with no DEI content. It was killed alongside the others, almost certainly caught in the centralization sweep of P-series and center-based mechanisms rather than by any keyword screen.

Additional Category Four casualties are visible across the dataset: NIDA’s Non-Invasive Brain Stimulation for Substance Use Disorders (FOR-DA-27-005), a purely neuroscientific program archived April 2026; NIDCR’s Small Research Grants for dental data analysis and statistical methods (PAR-26-039), archived March 2026; NIDDK’s High Risk Multi-Center Clinical Study Planning mechanism (PAR-25-090), a specialized U34 program for clinical trial planning; and two NIA training programs, the Transition to Aging Research for Predoctoral Students (FOR-TEMP-28167) and the REDI Entrepreneurship Award (PAR-26-066), both archived in late April and early May 2026. None of these contain political content. All of them are specialized, institute-specific mechanisms of the kind the Lorsch policy is designed to eliminate.

These four categories, DEI-labeled programs, HIV vaccine and cure science, the suppression of biodefense and global health research, and administrative centralization are not mutually exclusive. They are complementary engines running simultaneously. The Lorsch centralization creates the funnel, and the political approval process controls what flows through it. NIAMS center grants were caught in the administrative funnel. NIMHD health disparities programs were caught in the political screen. HIV vaccine science and biodefense was caught in both.

Part II. The Political Policies Driving Censorship at the NIH

These four categories of deletion did not emerge from budget pressures, bureaucratic accidents, or the ordinary churn of changing administrations. They emerged from deliberate policy. On August 15, 2025, eight days after the White House issued the executive order “Improving Oversight of Federal Grantmaking,” NIH Director Jay Bhattacharya issued a policy statement titled “Advancing NIH’s Mission Through a Unified Strategy.” Read against the NOFO data in this essay, it is the blueprint from which the cancellations flow.

The Unified Strategy document lists eight research priorities. Pandemic preparedness does not appear. Biodefense does not appear. The entire dimension of NIAID’s traditional mission, covering roughly a third of its $6.6 billion annual budget, is absent. The NIAID reorganization that erased those words from the institute’s website is the operational consequence of their absence.

The document’s section on health disparities states that NIH will shift from “identifying and documenting worse health outcomes for minority populations” to “solution-oriented approaches.” The document’s section on training programs states they “should be based on merit, follow civil rights law, and not discriminate against anyone.” That language is the official justification for eliminating G-RISE, U-RISE, MARC, MOSAIC, and IMSD, programs framed by the Trump administration as “discrimination.” The document’s section on foreign research instructs institutes to prefer domestic over foreign collaboration “when scientifically justified,” which is the policy rationale for terminating $500 million in annual foreign subawards.

The document’s HIV section is the sharpest example of the gap between stated policy and actual behavior. It says ending the HIV epidemic “remains a key priority.” It says “research on HIV/AIDS prevention, treatment, and cure will continue as needed.” The Nature Medicine paper Bhattacharya co-authored goes further, stating NIAID “will maintain a strong research and development pipeline for additional long-acting antiviral agents and other novel therapeutic and preventative strategies.” But the NOFO data show that five HIV cure and vaccine research programs were canceled in February 2026, six months after the strategic priorities document was published. A sixth program, the HIV vaccine consortium RFA-AI-27-020, was formally archived two months after that. Together, these six canceled programs were exactly the R&D pipeline the paper says will be maintained. What remains is the language of priority without the funding mechanisms that would make it real. That gap, between what the documents say and what the data show, is gaslighting. A scientist reading both is not confused. A scientist reading both knows exactly what happened.

Part III: Permitted Science

Since January 20, 2025, NIH has posted 113 Notices of Funding Opportunity, the entirety of NIH’s targeted scientific agenda under the current administration (as of May 15, 2026). Every one of these NOFOs cleared the new political approval process requiring sign-off from NIH’s Office of the Director, HHS, and OMB.

The thematic portrait of these 113 permitted announcements is as deliberate as the deletions. What the data show is not a proportional reduction of the overall pre-existing NIH portfolio, but rather, a measured political allowance for a smaller set of approved programs that will continue. The canceled science studied specific populations, specific communities, and specific intersections of identity and health risk, asking why those people fared worse and what could be done about it. The permitted science studies pathogens, aging brains, data repositories, and AI tools. Population-focused research has been replaced by disease-focused research. Equity-framed science has been replaced by infrastructure maintenance. HIV vaccine and cure science, biodefense, and global health research have been replaced by nothing. Career development for underrepresented researchers has been replaced by generic mechanisms that name no one.

Infrastructure maintenance dominates. Forty-seven of the 113 Trump-era posted NOFOs are coordinating centers, data repositories, research networks, biospecimen banks, and other large-scale infrastructure programs. These are predominantly renewals of existing programs, with NIH keeping some established platforms operational while blocking new scientific directions.

Infectious disease with no equity framing is thriving, with one explicit exception. NIAID had 7 NOFOs canceled and 12 permitted. Tuberculosis vaccine development, Hepatitis C vaccine rational design, influenza transmission consortia, biocontainment laboratory operations, fungal disease centers: all approved. Every one of NIAID’s allowed NOFOs involves infectious disease with a clear pathogen focus and no population-equity framing. The programs NIAID is not permitted to fund: HIV prevention, treatment, cure, vaccine development, and biodefense.

Alzheimer’s and aging research continues. Five of the 113 Trump-era NOFOs touch aging or Alzheimer’s disease, a politically unambiguous research area with broad bipartisan support and a well-organized patient advocacy community. Alzheimer’s research still matters.

Artificial intelligence and technology are priorities. Seven Trump-era NOFOs involve AI, bioinformatics, digital health technology, or computational biology. This aligns explicitly with administration priorities stated elsewhere. It is science the current government wants done.

One NOFO moved at presidential speed. On April 18, 2026, the President signed an executive order directing federal agencies to accelerate research on psychedelic drugs for mental health treatment, with a focus on veterans. Eleven days later, NIMH published a funding announcement for clinical trials methodology in rapid-acting psychotropic interventional drugs. That announcement’s forecast had sat in the grants.gov system for 316 days. Whatever held it in the approval queue for nearly a year cleared in eleven days once the Oval Office directed NIMH to act. Compare this to the HIV vaccine consortium (RFA-AI-27-020), which entered the same queue at approximately the same time and was formally killed seven months later.

Congressionally mandated programs? Perhaps. On May 8, 2026, I wrote about a long list of congressionally directed research programs held up in forecast mode. On May 12–13, NIH finally released three NOFOs that were on my list for the NIH INCLUDE Project, launched in 2018 in support of a Congressional directive on Down syndrome research. These three overdue forecasts had been sitting in the queue for over 140 days before release. The others remain in the forecast graveyard. I am tracking them closely.

The list of NIH institutes and centers that have zero posted NOFOs so far under the Trump administration is long: NIMHD, NIAAA, NEI, NIBIB, NIEHS, and the Fogarty International Center.

What the NIH Director Said About Permitted Science

In December 2025, NIH Director Jay Bhattacharya and Deputy Director Matthew Memoli published an article in The Spectator titled “How We Cured DEI at the National Institutes of Health.” Their word choice is itself revealing: they framed the elimination of these programs not as a policy change or a budget decision, but as a medical intervention: a cure. The patient was NIH. The disease was diversity.

In their telling, the programs documented in this essay were not scientifically grounded responses to documented workforce gaps and health inequities. They were “political ideology,” “de facto loyalty oaths,” a “DEI apparatus” that had “corrupted” NIH’s mission. They wrote that “chronic disease does not discriminate and DEI is not the solution.” They described the NOFO cancellations as a restoration of “merit and science-based research.”

In April 2026, my colleagues Jennifer Troyer, Jenna Norton, and Alice Popejoy published a detailed scientific rebuttal in the Science and Freedom Alliance Substack. I highly recommend reading it. Their response documents precisely what Bhattacharya and Memoli’s framing gets wrong, and why the NOFO cancellations are consequential not just politically but scientifically.

Troyer, Norton, and Popejoy make three arguments that bear directly on what the NOFO deletions reveal. First, on the “chronic disease does not discriminate” claim: striking disparities in prevalence and outcomes for heart disease, diabetes, and kidney disease exist across racial and ethnic groups. Canceling the funding mechanisms designed to study those disparities does not make the disparities disappear. It makes them harder to measure and address.

Second, on scientific quality: Bhattacharya claims to have elevated replication and reproducibility to an agency-wide priority. But a well-documented cause of failed replication in human studies is lack of diversity in the initial study population. Troyer and colleagues cite the example of hypertrophic cardiomyopathy research. Genetic studies in relatively homogeneous European ancestry cohorts produced a false positive that led to unnecessary invasive clinical interventions in unaffected African American patients. More diverse study populations would have caught the error. The anti-DEI initiative is eliminating the funding mechanisms that promote that diversity. This will make replication problems worse, not better.

Third, on what was actually canceled: Troyer and colleagues document that what the administration labeled “DEI” encompasses three entirely distinct categories of NIH activity. It included research study inclusion policies, health disparities research programs, and workforce diversity initiatives, each implemented separately, each with its own scientific rationale. Lumping them under a single political label and eliminating them en masse is not a scientific act. It is a category error enforced by administrative censorship power.

What the Law Says

On May 8, 2026, U.S. District Judge Colleen McMahon permanently barred the Trump administration from terminating more than $100 million in National Endowment for the Humanities grants, ruling that the cancellations, which used AI-assisted keyword screening to identify and eliminate grants associated with diversity, equity, and inclusion, constituted unconstitutional viewpoint discrimination in violation of the First and Fifth Amendments (Collins, 2026). Judge McMahon wrote that using ChatGPT to flag grants based on their content “neither excuses presumptively unconstitutional conduct nor gives the Government carte blanche to engage in it.” She called the DEI-based cancellations “a textbook example of unconstitutional viewpoint discrimination.”

The NEH grant cancellations and the NIH NOFO cancellations documented here were products of the same executive orders, issued within the same weeks, justified by the same rationale, and carried out by the same actors. Both used content-based screening to identify and eliminate federally funded science and scholarship associated with disfavored viewpoints. The primary difference is that the NEH cancellations terminated grants already awarded to researchers, while the NIH cancellations I am presenting here are terminated funding announcements, the mechanisms through which grants would have been sought and awarded.

I am a scientist, not a lawyer. I will not render a legal opinion. But I will ask the question the data raise. If using keyword screening to cancel federally funded grants based on their content is unconstitutional viewpoint discrimination, how is using keyword screening to cancel federally funded research solicitations based on their content different?

The researchers who had been planning applications to PAR-23-309, the NIMHD funding announcement on health disparities among people with disabilities now erased from NIH’s own website, have no grants to sue over. The research was never funded. It was stopped before applications could even be submitted. That makes it harder to litigate, but it does not make it different in kind.

Conclusion

I spent 22 years at NIH identifying research gaps and writing funding announcements to fill them. I know what these announcements represent. They are the agency’s statement of what it believes matters, what populations deserve attention, what questions need answers, what science the United States government is willing to invest in. When those statements are deleted, when the pages that contained them are removed from the internet, when the researchers who were planning to respond to them are left without explanation, something consequential has happened.

One hundred and ten announcements deleted. One hundred and thirteen permitted. This is deliberate, categorical, and ongoing scientific censorship. Calling it a simplification of the funding landscape does not make it one. Calling it a cure does not make it one either. The NOFO cancellations documented here are one layer of a multi-layer suppression. Funding solicitations were stopped before applications could be submitted, grants were terminated after they were awarded, and international collaborations were dismantled through bureaucratic obstruction. The layers reinforce each other. The country is less prepared at the research level, the institutional level, and at the international coordination level simultaneously.

The Wayback Machine still holds PAR-23-309. It still holds NOT-OD-20-031, NIH’s own evidence-based statement of why research diversity matters, captured on December 25, 2024, less than a month before it was removed. The research these documents would have made possible has not stopped being necessary because the funding announcements were deleted. The people it would have studied have not stopped experiencing the disparities it would have examined. The HIV epidemic has not stopped because the science to cure it has been halted. Biodefense and global health risks will unfold even if our government is no longer prepared. The science has simply been forbidden. All of this is happening in the United States of America, using your tax dollars, and by political people issuing unscientific justifications.

That is what the data show. I will not pretend otherwise.

This essay is part of an ongoing series documenting changes to the NIH extramural funding system. The dataset of 110 canceled NIH NOFOs and forecasts, reconstructed from grants.gov archive records, crowdsourced spreadsheets, and Wayback Machine captures, is available for viewing here: LINK.

Sources

Collins, D. (2026, May 8). Judge finds Trump’s DOGE-led cancellation of humanities grants unconstitutional. AP/PBS NewsHour. https://www.pbs.org/newshour/politics/judge-finds-trumps-doge-led-cancellation-of-humanities-grants-unconstitutional

Bhattacharya, J. & Memoli, M.J. (2025, December 11). How we cured DEI at the National Institutes of Health. The Spectator. https://spectator.com/article/how-we-cured-dei-at-the-national-institutes-of-health/

Bhattacharya, J. (2025, August 15). Advancing NIH’s Mission Through a Unified Strategy. National Institutes of Health. https://www.nih.gov/about-nih/nih-director/statements/advancing-nihs-mission-through-unified-strategy

Bhattacharya, J. (2025, August 12). Why the NIH is pivoting away from mRNA vaccines. The Washington Post. https://www.washingtonpost.com/opinions/2025/08/12/nih-mrna-vaccines-jay-bhattacharya/

Global Biodefense Staff. (2025, August 18). Jay Bhattacharya’s anti-science turn: Undermining mRNA vaccines and U.S. health security. Global Biodefense. https://globalbiodefense.com/2025/08/18/jay-bhattacharya-mrna-vaccine-cuts-health-security/

Kozlov, M. (2025, April 30; updated May 2, 2025). Exclusive: NIH to end billions of dollars in foreign research grants. Nature. https://doi.org/10.1038/d41586-025-01361-z

Kozlov, M. (2026, May 15). Exclusive: NIH ousts infectious-disease leaders as COVID scientists face US charges. Nature. https://www.nature.com/articles/d41586-026-01558-w

McCann Ramírez, N. & Klee, M. (2023, June 27). RFK Jr. claims ‘vaccine research’ likely responsible for HIV and the Spanish flu. Rolling Stone. https://www.rollingstone.com/politics/politics-news/rfk-jr-anti-vaxxers-roundtable-hiv-spanish-flu-1234779000/

National Institutes of Health. NOT-OD-20-031: Notice of NIH’s Interest in Diversity. Originally released November 22, 2019. Archived via Wayback Machine (captured December 25, 2024). https://web.archive.org/web/20241225023511/https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-031.html

National Institutes of Health. PAR-23-309: Health and Health Care Disparities Among Persons Living with Disabilities (R01). Originally published September 26, 2023. Archived via Wayback Machine.

National Institutes of Health. PAR-25-300, PAR-25-330, PAR-25-315, PAR-25-316, PAR-25-099: NIAID HIV vaccine and cure research NOFOs. Originally published December 2024. Canceled via NOT-AI-26-006 through NOT-AI-26-010, February 2026.

National Institutes of Health. RFA-AI-27-020: Consortia for Structure-based Immunogen Design for HIV (CSID-HIV). Forecast entered September 15, 2025. Archived April 22, 2026.

National Institutes of Health. (2026, May 12). An update on how NIH protects NIH-funded research from undue foreign interference. NIH Extramural Nexus. https://grants.nih.gov/news-events/nih-extramural-nexus-news/2026/05/an-update-on-how-nih-protects-nih-funded-research-from-undue-foreign-interference

Lorsch, J. (2026, March 23). NIH’s Path to a Simpler Funding Opportunity Landscape. NIH Extramural Nexus. https://grants.nih.gov/news-events/nih-extramural-nexus-news/2026/03/nihs-path-to-a-simpler-funding-opportunity-landscape

Ginexi, E. (2026, March 25). The NOFO Graveyard: A Response to NIH’s Defense of Its Vanishing Funding Opportunities. https://elizabethginexi.substack.com/p/the-nofo-graveyard

Ginexi, E. (2026, March 31). Inside the NIH Forecast Graveyard: What NIH is Canceling, What it is Burying, and What it Means. https://elizabethginexi.substack.com/p/inside-the-nih-forecast-graveyard)

Ginexi, E. (2026, May 8). Release the Forecasts: These Funding Opportunities Are Ready to Go. NIH is Holding them Back. https://elizabethginexi.substack.com/p/release-the-forecasts

Van Beusekom, M. (2026, February). NIAID staffers ordered to remove biodefense, pandemic preparedness language on website. CIDRAP, University of Minnesota. https://www.cidrap.umn.edu/bioterrorism/niaid-staffers-ordered-remove-biodefense-pandemic-preparedness-language-website

Taubenberger, J.K., Powers, J.H. III, & Bhattacharya, J. (2026). The new vision from the National Institute of Allergy and Infectious Diseases (NIAID). Nature Medicine, 32(3), 791–792. https://doi.org/10.1038/s41591-025-04160-1

Troyer, J., Norton, J., & Popejoy, A. (2026, April 7). The “Cure” for This Administration’s Scientific Priorities: Defend Responsible, Ethical Research and Respect Academic Freedom. Science and Freedom Alliance.

Science And Freedom Alliance

The “Cure” for This Administration’s Scientific Priorities: Defend Responsible, Ethical Research and Respect Academic Freedom

By Jennifer Troyer, Jenna Norton and Alice Popejoy (all opinions our own…

Read more

4 months ago · 16 likes · Science And Freedom Alliance and 27 UNIHTED

The White House. (2026, April 18). Accelerating Medical Treatments for Serious Mental Illness [Executive order]. https://www.whitehouse.gov/presidential-actions/2026/04/accelerating-medical-treatments-for-serious-mental-illness/

NOFO data compiled by the author from NIH Guide for Grants and Contracts historical archives, grants.gov records, crowdsourced spreadsheets from the research community, and Wayback Machine captures of removed NIH web pages. Analysis covers all NIH funding announcements canceled or archived between January 20, 2025 and May 15, 2026, and all NIH NOFOs posted between January 20, 2025 and May 15, 2026.

Update 5/8/2026: I have been alerted about two additional NIH forecasts that are part of a congressional mandate that I missed on my list. They are related to the Best Pharmaceuticals for Children Act (BPCA).

BPCA became law in 2002. It was reauthorized in 2007 under the U.S. Food and Drug Administration (FDA) Amendments Act, in 2012 under the FDA Safety and Innovation Act, and again in 2017 under the FDA Reauthorization Act. The latest renewal of the BPCA legislation occurred in 2022.

BPCA improves pediatric medication safety and efficacy by incentivizing manufacturers to conduct clinical trials on children, resulting in accurate, age-appropriate labeling. It provides 6 months of market exclusivity for studies and authorizes the NIH to research off-patent drugs.

BPCA has led to more than 200 drugs/therapeutics and 50 conditions/indications prioritized for further study. It also has led to more than 45 clinical trials funded to improve the knowledge of medicines used in children.

BPCA activities have produced 23 label changes to improve pediatric labeling (dosage, safety, and/or efficacy information). Access a selection of approved labels on the U.S. Food and Drug Administration (FDA) website.

And yet! NIH is blocking the release of these two BPCA related funding opportunities that would continue this critical pediatric safety research:

1. RFA-HD-26-009 - Maternal and Pediatric Precision in Therapeutics (MPRINT) Knowledge and Research Coordination Center- NICHD - forecast date 9/15/2025

2. RFA-HD-26-010 - Maternal Medications and Human Milk Research Center (M2HMRC) - NICHD - forecast date 9/15/2025

Both forecasts are 235 days overdue as of May 8, 2026 (their promised date was September 15, 2025).

Holding up NIH research will cost lives.

Release the forecasts!

This essay is part of an ongoing series documenting changes to the NIH extramural funding system. Data used in this analysis were compiled from grants.gov public records. Previous essays in this series: I Wrote Research Funding Announcements for NIH for 22 Years; The NOFO Graveyard; Inside the NIH Forecast Graveyard; The NOFO Pipeline Isn’t Broken. It’s Selective; and Release the Forecasts.

This image was generated by Google AI (Gemini)

Every funding opportunity described in the table linked below has been written. The science has been scoped, the eligibility requirements defined, the review criteria set. NIH scientific program and review officers did that work. They are ready to invite applications. Researchers are ready to apply.

These are not hypothetical programs waiting to be designed. They are fully developed Notices of Funding Opportunity (NOFO) forecasts sitting in a grants.gov queue, waiting for one thing: permission to be released.

Every program on this list has been supported or directed by Congress, through appropriations bill language, statutory set-asides, or sustained committee report directives over multiple fiscal years. Some carry mandatory funding floors that are legally non-discretionary. All of them represent research areas Congress has explicitly said matter: opioid use disorder, Type 1 diabetes, pediatric cancer, Down syndrome, environmental health, minority health, autism, and more.

As of May 8, 2026, there are 49 forecasts related to 13 different congressionally directed programs that are all stuck in the queue. Of those, 36 are past the date NIH itself set for their publication. The HEAL Initiative for opioid research has 11 forecasts stuck and has published zero targeted NOFOs since the Trump administration took office. The Gabriella Miller Kids First program, named for a ten-year-old who died of a brain tumor and who inspired bipartisan legislation to fund pediatric cancer research, has three forecasts overdue by 282 days. The Special Diabetes Program, funded through a mandatory appropriation under the Balanced Budget Act of 1997, has six forecasts overdue.

NIH could release these forecasts as a full funding opportunities immediately. The science is ready. The staff work is done. The only thing standing between these forecasts and the researchers who would respond to them is an approval process that has held mandated programs in a political approval queue for the better part of a year.

The full list, with opportunity numbers, the date each forecast was entered into grants.gov, the date NIH originally promised to publish it, and the number of days it is now past that self-imposed deadline, is available for download at the link below.

In the master list (which you can download via the link below), please note that RED rows reflect forecasts that are overdue. YELLOW rows indicate forecasts that are not yet past their promised date, but I am including them in the table for monitoring purposes. For example, one program, the Autism Centers of Excellence, has two forecasts with July 1, 2026 planned posting dates, which will become overdue in approximately eight weeks if action is not taken. We will see if NIH honors these projected release dates.

Release the forecasts!

LINK TO THE FULL LIST

This essay is part of an ongoing series documenting changes to the NIH extramural funding system. Previous essays: The NOFO Pipeline Isn’t Broken. It’s Selective; Inside the NIH Forecast Graveyard; Who Decides What Science Gets Done? Data compiled from grants.gov as of May 8, 2026.

This image was generated by Google AI (Gemini)

On April 29, 2026, Politico published a story about the ongoing collapse in National Institutes of Health (NIH) funding opportunities (Hooper & Gardner, 2026). I was quoted in that story, as were two other voices defending the current policy: Jon Lorsch, NIH’s Deputy Director for Extramural Research, and Emily Hilliard, a spokesperson for the Department of Health and Human Services (HHS). Between them, their statements offer two explanations for why NIH has dramatically reduced the number of Notices of Funding Opportunities (NOFOs) it publishes. One of those explanations is a deliberate policy choice. The other does not hold up against the data. And the data I have been examining, drawn entirely from NIH’s own public records, make the distinction easy to see.

What HHS Said

Asked about the steep decline in NOFOs, HHS spokesperson Emily Hilliard offered this explanation:

“Democrat-led shutdown, the longest in government history, delayed NIH’s ability to issue these NOFOs.”

There were two government shutdowns recently. The first began on October 1, 2025, and lasted 43 days, ending November 12, 2025, the longest shutdown in U.S. history. The second, a 75-day partial shutdown in early 2026, primarily affected the Department of Homeland Security and did not apply to NIH. So, the only shutdown that actually affected NIH was the 43-day fall 2025 shutdown.

But here is what the monthly NOFO data show. Between January 20, 2025 (inauguration day) and September 30, 2025, before the fall shutdown began, NIH posted 58 NOFOs over 254 days. That annualizes to approximately 83 NOFOs per year. The pre-policy baseline was 724 per year. NIH was already 88% below its historical baseline before a single day of shutdown had elapsed.

During the 43-day fall shutdown itself, NIH posted zero NOFOs, which is consistent with a shutdown effect. But after the shutdown ended on November 12, activity did not recover to any meaningful level. NIH posted 14 NOFOs in the remaining 49 days of 2025, and 20 NOFOs in the first four months of 2026. The trajectory before, during, and after the shutdown is nearly identical: a level of activity 85 to 92% below the historical norm, interrupted only by the brief burst at the September fiscal year end. A shutdown that accounts for 43 days of a 15-month collapse cannot credibly be described as the cause of that collapse.

The 2026 situation is an even weaker explanation. That partial shutdown primarily affected the Department of Homeland Security. NIH was not shut down at all. More importantly, Congress passed NIH’s full fiscal year 2026 budget on February 3, 2026. The agency had no obstacles with regard to their ability to publish funding opportunities during that time. Since February 3, NIH has posted 16 NOFOs in 86 days, a pace more than 90% below the historical baseline of 724 per year. NIH had the money. NIH had the authority. The constraint was not the shutdown. The constraint is the approval process.

What NIH Says, and Why It Contradicts HHS

The same Politico story that carried HHS’s shutdown explanation also quoted Jon Lorsch’s blog. His explanation is different from Hilliard’s in a critical respect: it is honest about what is actually happening.

“Although there are fewer funding opportunities, this does not mean fewer funded applications. Instead, it gives investigators greater flexibility to propose their own research topics. We remain committed to supporting meritorious research even as the number of funding opportunities is reduced.”

Lorsch has said, clearly and repeatedly, that the reduction in NOFOs is deliberate policy. NIH is, in his words, “streamlining the landscape of NOFOs” to place greater emphasis on investigator-initiated science. That blog post was written in March, weeks before HHS issued its shutdown explanation. The Politico reporter cited both in the same story, and the juxtaposition is awkward for the administration: one official describes a purposeful policy decision, while another attributes the same outcome to an external event. Both explanations cannot be true. Either the reduction is a deliberate change to the funding system, as Lorsch argues, or it is an unintended consequence of a government shutdown, as Hilliard claims. Lorsch’s own words undercut Hilliard’s excuse, and he wrote them before anyone requested an explanation.

I have addressed Lorsch’s argument about NOFOs at length in my earlier essay responding to his March blog post. The short version: over 80% of annual NIH extramural funding has always gone to investigator-initiated science. Targeted NOFOs were never crowding out investigator-initiated applications. They were filling the gaps that broad mechanisms cannot reach. Eliminating targeted NOFOs does not free scientists to propose more ideas. It removes the signal that tells scientists which problems NIH has identified as priorities and which gaps the research community on its own has not addressed. It also blocks the issuance of targeted funding opportunities for congressionally mandated research programs that must post specific funding calls to meet their mandates.

Lorsch’s assurance that fewer NOFOs would not mean fewer funded applications is contradicted by NIH’s own data. In fiscal year 2025, the number of R01-equivalent awards fell by more than 20% compared to fiscal year 2024, despite a nearly flat NIH budget (Kaiser, 2026; NIH, OER, 2026). And this same pattern of fewer new awards is playing out again right now in 2026. Reporting from The New York Times, The Washington Post, and the Association of American Universities confirms that the rate of competitive awards made by the NIH has slowed down significantly this fiscal year (Agarwal, 2026; Johnson et al., 2026; Mueller & Hwang, 2026).

How the Forecast Pipeline Actually Worked, and When It Stopped

I manually reviewed the version history of all 140 NOFOs posted in calendar years 2025 and 2026 on grants.gov so that I could retrieve the original date when each NOFO started as a forecast. The results are instructive. Of the 48 NOFOs posted in the nineteen Biden administration days of January 2025, none went through a forecast first: the forecast system was not yet in use. Of the 92 NOFOs posted in the Trump era, 85 (92%) did go through a forecast first. The forecast pipeline has been functioning as an actual pipeline for most of the NOFOs that eventually got posted.

But the timing of that pipeline tells a more specific story. Of the 85 successfully converted forecasts, every single one had its forecast first entered into grants.gov between May 5 and September 15, 2025. The median time from forecast entry to posting was 90 days. The mean was 91 days. The fastest conversion took 8 days; the slowest took 350 days.

Since September 15, 2025, no new forecast has converted to a posted NOFO, with one exception. That exception is RFA-MH-27-135, whose forecast was entered June 17, 2025 (within the original window), but which sat for 316 days before being published.

The seven Trump-era NOFOs that were posted without going through a forecast first are also revealing. Five of those seven were posted in January and March 2025, before the forecast system was operationally in use at most institutes. The two December 2025 exceptions, an NCI Cancer Intervention and Surveillance Modeling Network U01 continuation and an NIDDK stem cell grant, appear to have bypassed the forecast requirement without explanation.

What this means is that the forecast system functioned as a genuine pipeline for a defined window: forecasts entered May through September 2025 moved through to posting. Since then, the pipeline has effectively stopped. The 335 forecasts currently sitting as open in grants.gov represent a cohort that has not moved, with an average days overdue time of 137 days. None of those forecasts entered after September 2025 has converted. The system that worked for the first cohort is not working for anything that came after.

An Unexpected Development

On April 18, 2026, President Trump signed an executive order titled “Accelerating Medical Treatments for Serious Mental Illness,” directing federal agencies to accelerate the research, review, and approval of psychedelic drugs for medical use, with a particular focus on treating mental health conditions among veterans (The White House, 2026). Section 3 of the order directed the Department of Health and Human Services to develop a research acceleration plan involving, in the order’s own words, “the National Institute of Mental Health and other relevant components.”

Eleven days later, on April 29, 2026, NIMH published RFA-MH-27-135, “Addressing Methodological Challenges with Clinical Trials of Rapid-Acting Psychotropic Interventional Drugs.” It covers clinical trials methodology for RAPIDs, a category that includes ketamine, psilocybin, and MDMA-assisted therapies. The executive order and the NOFO cover the same subject matter. The gap between them is eleven days.

The forecast for RFA-MH-27-135 was entered June 17, 2025. It sat for 316 days before being published: among the longest conversions for RFA-type targeted funding opportunities in the entire dataset. The median conversion time for all other forecasts that successfully posted was 105 days. Whatever held this particular forecast in place for 211 days longer than the typical conversion, it was cleared within eleven days of the Oval Office directing NIMH to act. I will let readers draw their own conclusions about the relationship between those two facts.

The approval process that has held hundreds of other forecasts past their promised dates apparently moves considerably faster when the instruction comes from a presidential executive order. That is not how a neutral administrative pipeline operates. That is how a politically directed one does.

That contrast becomes sharper when you look at what remains stuck. The National Institute on Minority Health and Health Disparities has posted zero NOFOs since January 20, 2025. Five congressionally mandated research programs, the HEAL Initiative for opioid research, the Gabriella Miller Kids First Pediatric Research Program, the INCLUDE Project for Down syndrome research, the IDeA program for research capacity in underserved states, and the Superfund and HAZMAT Worker Training Program, have each posted zero new targeted NOFOs since the administration took office. Jon Lorsch’s NOFO policy is delaying congressionally mandated research. The political leaders at NIH do not have the authority to overrule Congress as they are clearly doing.

HIV/AIDS content appeared in 23% of NIH funding opportunities published in the nineteen days before the new administration took office. It appears in 3% of funding opportunities published in the fifteen months since. In 2026 specifically, of the 20 NOFOs published through April 30, not one contains equity, disparities, or diversity language. Not one came from NIMHD. The one NOFO that moved at presidential speed follows a very different pattern than the ones that have not moved at all.

The Forecast Graveyard Has Grown

When I published my forecast graveyard analysis in March, I was working with 336 open forecasts, of which 205 were overdue. Since then, the numbers have moved in the wrong direction. Several new forecasts have been entered into the system, and some have dropped off. The total open forecast count stands at 335. The overdue count has grown to 239.

Among the new forecasts added since March, one is the “NIH Specialized Center Grant (Parent P50),” with NIAAA listed as the lead institute. This is an interesting development because a forecast by NIAAA for a Comprehensive Alcohol Research Centers (P60 Clinical trial Optional) NOFO was explicitly archived (canceled) on March 18, 2026. Now with this new forecast it appears that NIAAA is no longer allowed to issue its own center grant program. Instead, because of Jon Lorsch’s policy they must participate in a new “Parent” center grant NOFO. This forecast indicates that the estimated post date is November 09, 2026. The former NIAAA P60 forecast was entered into the system on August 27, 2025. They have been blocked from renewing their specialized alcohol research center grant program for all this time.

The picture that emerges from these numbers is not one of a system disrupted by an external event. The forecast pipeline that worked for the May through September 2025 cohort has not produced a single new conversion since then, except the one that followed a presidential order. The 335 open forecasts represent programs that missed that window and have been waiting ever since.

The researchers waiting for these forecasts are not waiting because of a government shutdown. They are waiting because the system that was designed to move funding opportunities from concept to publication now requires approval from NIH’s Office of the Director and from political appointees at HHS and OMB before a NOFO can be posted. This political approval process, which circumvents the statutory framework governing NIH, is producing historically low numbers of NOFOs because of a series of presidential and HHS directives.

The fall 2025 shutdown was real, but it does not explain a 15-month pattern of NOFO declines. That is a policy choice. And the research community deserves to have it described accurately.

This essay is part of an ongoing series documenting changes to the NIH extramural funding system. Data used in this analysis were compiled from grants.gov public records. Previous essays in this series: I Wrote Research Funding Announcements for NIH for 22 Years; The NOFO Graveyard; Inside the NIH Forecast Graveyard.

Sources

Agarwal, K. (2026, March 20). Data show dramatic slowdown in NIH grantmaking. Association of American Universities. https://www.aau.edu/newsroom/leading-research-universities-report/data-show-dramatic-slowdown-nih-grantmaking

Del Barco, M. (2026, April 18). Trump signs order fast tracking review of psychedelics for mental health disorders. NPR. https://www.npr.org/2026/04/18/nx-s1-5789859/psychedelic-treatments-mental-health

Hooper, K., & Gardner, S. (2026, April 29). The debate over NIH’s research revamp. Politico. https://www.politico.com/newsletters/politico-pulse/2026/04/29/the-debate-over-nihs-research-revamp-00896870

Johnson, C. Y., Sidhom, L., & Svrluga, S. (2026, April 19). Where U.S. science has been hit hardest after Trump’s first year. The Washington Post. https://www.washingtonpost.com/science/2026/04/19/science-research-funding-cuts-trump/

Kaiser, J. (2026, February 20). NIH research grant funding rates plummeted in 2025. Science. https://www.science.org/content/article/nih-research-grant-success-rates-plummeted-2025

Mueller, B., & Hwang, I. (2026, April 22). Pace of N.I.H. funding slows further in Trump’s second year. The New York Times. https://www.nytimes.com/2026/04/22/science/trump-nih-funding-research.html

National Institutes of Health, Office of Extramural Research. (2026, February 10). NIH support for early-stage investigators in FYs 2024 and 2025. NIH Extramural Nexus. https://grants.nih.gov/news-events/nih-extramural-nexus-news/2026/02/nih-support-for-early-stage-investigators-in-fys-2024-and-2025

The White House. (2026, April 18). Accelerating medical treatments for serious mental illness [Executive order]. https://www.whitehouse.gov/presidential-actions/2026/04/accelerating-medical-treatments-for-serious-mental-illness/

This image was generated by Google AI (Gemini)

Congress appropriated $47 billion for NIH research in fiscal year 2026. The President signed it into law on February 3, 2026. Many researchers assumed the worst was over. Funding was secured. NIH could move forward.

But the grants are being awarded at a super, super slow pace right now, leading many to worry whether the NIH will spend all of its money by the end of the current fiscal year (Oza, 2026).

I spent 22 years as a program official at NIH. I know how the system worked and how it has changed. This essay explains why grant funding has slowed to a crawl, and documents the comprehensive vetting system that most researchers don’t know exists.

To understand the complexity of the situation, it is important to look at the policy changes implemented by the current administration. Between January 20, 2025, and the present, a series of executive orders and policy changes have created a comprehensive system for vetting NIH research grants based on ideological criteria. Many researchers submitting applications may have no idea this system exists.

The Executive Orders

Two executive orders issued in 2025 established the framework for political vetting of NIH research grants.

On January 20, 2025, hours after taking office, President Trump signed Executive Order 14168, “Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.” Section 3(g) states: “Federal funds shall not be used to promote gender ideology. Each agency shall assess grant conditions and grantee preferences and ensure grant funds do not promote gender ideology.”

The order defines “gender ideology” as replacing “the biological category of sex with an ever-shifting concept of self-assessed gender identity.” It mandates that all federal agencies use “sex” (defined as “immutable biological classification”) rather than “gender” in policies and documents.

Six months later, on August 7, 2025, the President signed Executive Order “Improving Oversight of Federal Grantmaking.” This order established additional requirements for all federal discretionary grants.

The preamble justifies these restrictions by citing examples of grants the administration considers wasteful: “drag shows in Ecuador, trained doctoral candidates in critical race theory, and developed transgender-sexual-education programs.” It blames NIH for funding “an unsafe lab in Wuhan, China” and claims that “more than one-quarter of new National Science Foundation (NSF) grants went to diversity, equity, and inclusion and other far-left initiatives.”

Section 3 of the August 7 order requires that all agencies designate senior political appointees to review and approve funding opportunity announcements and discretionary grants. These appointees “shall not ministerially ratify or routinely defer to the recommendations of others in reviewing funding opportunity announcements or discretionary awards, but shall instead use their independent judgment.”

Translation: political appointees can override scientific peer review.

Section 4(b) establishes criteria that senior appointees must apply when reviewing grants. Discretionary awards must “demonstrably advance the President’s policy priorities” and “shall not be used to fund, promote, encourage, subsidize, or facilitate” the following:

• Racial preferences or other forms of racial discrimination by the grant recipient

• Denial by the grant recipient of the sex binary in humans or the notion that sex is a chosen or mutable characteristic

• Harm reduction

• Illegal immigration

• Any other initiatives that compromise public safety or promote anti-American values

These categories are broad enough to encompass substantial portions of NIH-funded research. Health disparities research studying interventions targeted at racial or ethnic groups could be characterized as “racial preferences.” LGBTQ health research could be deemed “denial of the sex binary.” Addiction and overdose prevention research could be classified as “harm reduction.” Research on immigrant health could be considered support for “illegal immigration.” And “anti-American values” is undefined, allowing political appointees to apply it to virtually any research they oppose.

Implementation Through Policy Notices

Executive orders establish broad requirements. NIH policy notices translate them into specific grant conditions.

On July 17, 2025, NIH issued Notice NOT-OD-25-131 revising its policy on inclusion of women and minorities in clinical research. The stated purpose: “to align with Executive Order 14168 Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government.”

The revision mandates use of “sex” instead of “sex/gender” in all NIH-funded research. Effective August 16, 2025 (30 days after publication), the policy applies to “all grants, cooperative agreements, contracts, other transactions, and intramural studies.”

Any research on transgender health, gender-affirming care, or LGBTQ health disparities that uses “gender” terminology is now non-compliant with NIH policy.

On November 18, 2025, NIH issued Notice NOT-OD-26-009 implementing the termination provisions required by the August 7 executive order. Effective October 1, 2025, all new NIH awards now include this language:

“Pursuant to 2 CFR 200.340, by accepting an NIH award, the recipient agrees that continued funding for the award is contingent upon the availability of appropriated funds, recipient satisfactory performance, compliance with the Terms and Conditions of the award, and may also otherwise be terminated, to the extent authorized by law, if the agency determines that the award no longer effectuates the program goals or agency priorities.”

This applies to new grants, renewals, supplements, and continuation awards. The phrase “agency priorities” is critical because those priorities are now defined by the executive orders and the Unified Strategy, which I will explain shortly.

The notice also includes a remarkable provision: “Any term or condition in this Notice of Award...that NIH is enjoined by court order from imposing or enforcing, shall not apply or be enforced as to any recipient or subrecipient to which that court order applies and while that court order is in effect.”

Translation: court victories only protect the specific institutions that sued. If one university successfully challenges these terms in court and wins, NIH will stop enforcing them against that university but will continue enforcing them against everyone else who has not obtained their own court order.

The Unified Strategy and the Elimination of Paylines

The executive orders establish what NIH cannot fund. The Unified Strategy establishes what NIH will prioritize. Together with the elimination of payline funding criteria, they create comprehensive control over grant decisions.

On August 15, 2025, eight days after the “Improving Oversight of Federal Grantmaking” executive order, NIH Director Jay Bhattacharya issued a statement titled “Advancing NIH’s Mission Through a Unified Strategy.”

The statement establishes NIH research priorities. It also establishes what research NIH will deprioritize. All current NIH funding opportunity announcements now include this language: “Applicants and recipients are strongly encouraged to refer to the NIH Director’s Statement of Priorities, entitled ‘Advancing NIH’s Mission Through a Unified Strategy.’”

On health disparities research, the Unified Strategy states:

“In contrast to research that considers race or ethnicity when scientifically justified...research based on ideologies that promote differential treatment of people based on race or ethnicity, rely on poorly defined concepts or on unfalsifiable theories, does not follow the principles of gold-standard science. Such studies divert resources away from projects that advance the health and longevity of all Americans, including minority populations.”

It continues: “Broad or subjective claims—such as attributing worse health outcomes in a particular population to poorly measured factors like systemic racism—should not be presented as established background facts without clearly defining measurable variables that are part of the research question.”

Research studying structural determinants of health disparities is now characterized as “ideological,” “poorly defined,” and “off-mission.”

On transgender health research, the Unified Strategy states that research “that aims to identify and treat the harms these therapies and procedures have potentially caused to minors diagnosed with gender dysphoria...is more promising” than research on “the use of puberty suppression, hormone therapy, or surgical intervention.”

Only research examining harms of gender-affirming care will be prioritized. Research supporting such care is implicitly deprioritized.

On foreign collaboration, the Unified Strategy states: “All NIH institutes, centers, and offices should consider whether there is a scientific justification for conducting a research program at a foreign site rather than a domestic one. The NIH should prefer the latter over the former when scientifically justified.”

Presumably, this implements the executive order’s prohibition on funding research that advances “anti-American values” by defining domestic research as inherently preferable.

The Unified Strategy is not just a statement of priorities. It has been operationalized into NIH’s funding decision process through the elimination of paylines.

In November 2025, NIH announced a fundamental change to how grants are funded. The agency eliminated reliance on paylines, which were objective score cutoffs that some ICs used to determine which applications received funding based primarily on peer review scores. This new policy is described as Implementing a Unified NIH Funding Strategy to Guide Consistent and Clearer Award Decisions.

According to NIH’s official guidance: “As part of the wider Unified Funding approach, ICOs will no longer employ these cutoff points in overall impact scores to determine which applications to fund...Moving forward, ICOs will consider peer review information in its entirety when assessing scientific merit.”

In practice, this means funding decisions are no longer based primarily on peer review scores. They are now based on “core tenets” that include:

• Alignment with NIH’s mission (as defined by the Unified Strategy)

• ICO priorities (as defined by the Unified Strategy)

• “Broad distribution and geographic balance of funding”

• “The total amount and type of NIH funding already available to each investigator”

• “Actual needs, opportunity costs, and stewardship of taxpayer investments”

This eliminates the objectivity that paylines provided. Previously, if your application scored above the payline, you had a strong likelihood of funding. The decision was based primarily on scientific merit as assessed by expert peer reviewers.

Now, even if your application receives an excellent peer review score, the funding decision depends on whether it aligns with the Unified Strategy priorities, fits the institute’s interpretation of “geographic balance,” and represents appropriate “stewardship of taxpayer investments” in the judgment of IC directors (and/or presumably in the judgement of the NIH Director who may override the IC directors or convince them to change their decisions).

Institute directors—some of whom are political appointees or who report to political appointees—have “delegated authority to decide what is funded,” with peer review recommendations being advisory rather than determinative. However, since so many NIH IC directors have been fired or left, this leaves the agency with many “acting” IC directors who may not feel they have the power to override political appointees’ demands.

The combination creates a second mechanism for rejecting grants. Even if your research does not explicitly violate an executive order prohibition, it can be rejected for failing to “align with agency priorities” as defined by the Unified Strategy.

What’s Now Required in Every NIH Grant Application

All NIH funding opportunity announcements now include identical language establishing new requirements for applicants.

Compliance certification:

“By applying for or accepting federal funds from HHS, recipients certify compliance with all federal antidiscrimination laws and these requirements and that complying with those laws is a material condition of receiving federal funding streams.”

This references the executive orders’ definitions of sex (binary, immutable, determined at conception) and prohibitions on “racial preferences.” By applying for NIH funding, you certify compliance with these definitions. If your research uses “gender” terminology or studies interventions targeted at racial or ethnic groups, you may be violating the “federal antidiscrimination laws” as redefined by the executive orders.

Unified Strategy alignment:

“Applicants and recipients are strongly encouraged to refer to the NIH Director’s Statement of Priorities, entitled ‘Advancing NIH’s Mission Through a Unified Strategy.’”

The Unified Strategy establishes that health disparities research must not study “poorly measured factors like systemic racism” and that only research on harms of gender-affirming care (not benefits) will be prioritized. This “strong encouragement” functions as a requirement when senior political appointees review grants for “alignment with agency priorities.”

Termination provision:

“By accepting an NIH award, the recipient agrees that continued funding for the award is contingent upon...compliance with the Terms and Conditions of the award, and may also otherwise be terminated, to the extent authorized by law, if the agency determines that the award no longer effectuates the program goals or agency priorities.”

“Agency priorities” are defined by the Unified Strategy. “Program goals” can change based on executive orders. Your existing grant can be terminated if NIH decides it no longer aligns, even if the research was approved under previous priorities.

Together, these three provisions create a comprehensive system. You certify compliance with executive order-redefined “antidiscrimination laws.” You are “strongly encouraged” to align with Unified Strategy priorities. Your grant can be terminated if deemed non-compliant with either.

These requirements are being actively enforced in grant funding decisions. According to current NIH staff who spoke on condition of anonymity, program officers are receiving specific feedback that applications they recommend for funding do not align with agency priorities.

For health disparities research, proposals using terms such as “social determinants of health,” “lived experience,” or “neighborhood stressors” are being flagged as insufficiently specific and not meeting the standards outlined in the Unified Strategy. “Social determinants of health” is an established scientific framework with decades of peer-reviewed literature examining how structural factors like poverty, housing, and environmental exposures affect health outcomes. Characterizing such terminology as “vague and non-specific” effectively prohibits research on these topics.

For international collaborations, applications must articulate both a “clear scientific rationale” for conducting research abroad rather than domestically and demonstrate “direct potential to generate knowledge applicable to understanding, improving, or protecting the health of Americans.” This requirement appears in an August 25, 2025 statement from the NIH Director titled “Maximizing and Safeguarding NIH’s Investment in Foreign Collaborations.” The statement emphasizes that “NIH is not a foreign aid organization” and that international research must “deliver both scientific and taxpayer value.”

These review criteria transform scientific evaluation into political screening. Grants are assessed on whether their terminology, geographic scope, and framing align with administratively defined priorities that emphasize domestic benefit and "measurable variables" while excluding research frameworks the administration characterizes as ideological. These political assessments are overriding the scientific recommendations of NIH Program Officials and peer review.

This standard language appears in every NIH funding opportunity announcement now, regardless of research area. It applies to all grant types, all institutes, all mechanisms. Every NIH applicant now operates under these requirements.

Why Non-Competing Continuation Awards Are Being Scrutinized

The termination clause in NOT-OD-26-009 applies not only to new grants but also to “renewal, supplement, or continuation awards issued on or after October 1, 2025.”

This explains why non-competing continuation awards—grants that were already funded and are simply receiving their next year of support—are being scrutinized under the new criteria.

According to current NIH staff who spoke on condition of anonymity due to concerns about professional retaliation, continuation awards are being reviewed for alignment with the executive orders and Unified Strategy priorities. Grants that were approved years ago under different criteria are now being re-evaluated against current political requirements.

“Agency priorities” can change at will. Your multi-year grant could be terminated mid-stream because priorities have shifted, even though your research has not changed and continues to receive strong peer review.

When Courts Strike Down One Mechanism, Others Remain

In February 2025, NIH announced a 15% cap on indirect costs. Universities sued immediately. Courts struck it down as illegal. The Trump administration appealed. Lost again. The deadline to petition the Supreme Court passed in April 2026 without the administration filing (Molteni, 2026). The indirect cost cap is dead.

But look at the August 2025 executive order, Section 4(b)(iii): “All else being equal, preference for discretionary awards should be given to institutions with lower indirect cost rates.”

And Section 5(b): The OMB Director “shall...revise the Uniform Guidance and other relevant guidance to appropriately limit the use of discretionary grant funds for costs related to facilities and administration.”

When the direct approach (the 15% cap) failed in court, the administration shifted to indirect approaches. Senior political appointees now “prefer” institutions with lower indirect costs when reviewing grants. OMB is revising grant guidance to “limit” indirect costs through policy rather than regulation.

Same goal. Different mechanism. Harder to challenge in court because it is buried in grant review criteria and administrative guidance rather than announced as explicit policy.

This is the pattern. When legislative proposals fail (Congress rejected NIH restructuring), implement administratively. When regulations fail in court (15% indirect cap struck down), implement through executive orders and grant vetting.

The executive order contains multiple mechanisms for restricting grants. Strike down one, and the others remain operational.

Why Grants Are Being Delayed Despite Congressional Funding

I keep hearing from researchers and university leaders, such as Vice President for Research (VPR) / Vice Provost for Research types: “Congress funded NIH, so everything is fine now.”

The administration has its own version of this reassurance. In April 2026, an HHS spokesman told The Washington Post that the ‘Democrat-led shutdown’ late last year was responsible for delays and that NIH was ‘catching up.’ The spokesman added that the shift to multi-year budgeting ‘will help sustain long-term research’ by giving researchers ‘more funding stability’ (Johnson et al., 2026).

But this explanation does not account for what the executive orders and policy changes have put in place. The delays are not simply about catching up from a shutdown or adjusting to new budgeting practices. They are the result of a comprehensive vetting system that did not exist before January 2025. Screening tens of thousands of grant applications for ideological compliance for funding approval takes time.

Congress did fund NIH. That is true. The President signed the appropriation. The money exists.

But the grants are not necessarily moving.

The collapse of NIH funding announcements I documented in a previous series of three Substack essays (from 756 NOFOs in 2024 to 17 in 2026 as of mid-March: NOFO essay 1, NOFO essay 2, NOFO essay 3) is explained by Section 3(c) of the August 7 executive order: “agencies shall not issue any new funding opportunity announcements without prior approval from the senior appointee.”

The grants stuck in the funding queue are explained by Section 3(a)(vii): “pre-issuance review of discretionary awards to ensure that the awards are consistent with applicable law, agency priorities, and the national interest.”

The restrictions now appearing in funding opportunities are explained by Section 4(b): the prohibited content list.

This is not accidental. This is the administration policy working exactly as designed.

Most researchers submitting applications right now do not know their grants are being screened for ideological compliance after scientific merit has already been established by peer review and by NIH Program Officials. They do not know their existing grants can be terminated if a political appointee decides they no longer align with “the President’s policy priorities.” They do not know that peer review scores, while still generated, are now advisory rather than determinative.

They do not know because the people who could tell them, such as NIH program staff, dare not say so. Civil servants operate under strict rules governing public statements. Many are aware that whistleblowers in the current political environment have faced retaliation despite formal protections.

How the Vetting System Works

The money Congress appropriated exists. But between appropriation and award, a comprehensive system of political vetting has been inserted.

Two executive orders establish prohibited content and require political appointee approval of all grants. Two NIH policy notices implement these requirements through specific grant terms. The Unified Strategy defines positive priorities and what research is “off-mission.” The elimination of paylines removes objective decision criteria. Standard language in all funding announcements requires compliance with all of the above.

The result is a multi-layered vetting system where grants can be rejected or terminated based on:

• Use of “gender” terminology (Executive Order 14168)

• Research on harm reduction, racial health disparities, or immigrant health (Executive Order “Improving Oversight of Federal Grantmaking”)

• Studying “poorly measured factors like systemic racism” (Unified Strategy)

• Failure to “demonstrably advance the President’s policy priorities” (standard NOFO language)

• Determination by IC directors that the research no longer represents good “stewardship of taxpayer investments” (funding decisions guidance)

Most researchers submitting applications do not know this system exists. They think peer review determines funding. They think Congress funding NIH means grants are being awarded normally. They are operating based on how the system worked before January 2025.

The system has changed. The people who understand most clearly what has changed are the least able to say so.

That silence is what I am trying to break.

This essay is part of an ongoing series reflecting on what I learned over more than two decades working inside the U.S. biomedical research enterprise. Each piece stands alone, but together they examine how science is shaped not only by ideas and funding, but by the structures that support or constrain them.

Sources

Collard, H. (2026, March 20). Facing the new reality of NIH funding. The Scientist. https://www.the-scientist.com/facing-the-new-reality-of-nih-funding-74237

Johnson, C. Y., Sidhom, L., & Svrluga, S. (2026, April 19). Where U.S. science has been hit hardest after Trump’s first year. The Washington Post. https://www.washingtonpost.com/science/2026/04/19/science-research-funding-cuts-trump/

Molteni, M. (2026, April 8). Trump administration drops court fight to cap NIH payments for research overhead costs. STAT. https://www.statnews.com/2026/04/08/trump-administration-drops-nih-indirect-cost-court-battle/

National Institutes of Health. (2025a, July 17). Revision: NIH policy and guidelines on the inclusion of women and minorities as subjects in clinical research (Notice No. NOT-OD-25-131). U.S. Department of Health and Human Services. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-131.html

National Institutes of Health. (2025b, August 15). Advancing NIH’s mission through a unified strategy [Statement]. U.S. Department of Health and Human Services. https://www.nih.gov/about-nih/nih-director/statements/advancing-nihs-mission-through-unified-strategy

National Institutes of Health. (2025c, November 18). Updated terms and conditions of award – Termination and compliance with court orders (Notice No. NOT-OD-26-009). U.S. Department of Health and Human Services. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-26-009.html

National Institutes of Health. (2025d, November 21). Funding decisions. U.S. Department of Health and Human Services. https://grants.nih.gov/grants-process/award/funding-decisions

National Institutes of Health. (2025e, August 25). Maximizing and safeguarding NIH’s investment in foreign collaborations [Statement]. U.S. Department of Health and Human Services. https://www.nih.gov/about-nih/nih-director/statements/maximizing-safeguarding-nihs-investment-foreign-collaborations

National Institutes of Health. (2025, November 21). Implementing a unified NIH funding strategy to guide consistent and clearer award decisions. NIH Extramural Nexus. https://grants.nih.gov/news-events/nih-extramural-nexus-news/2025/11/implementing-a-unified-nih-funding-strategy-to-guide-consistent-and-clearer-award-decisions

Oza, A. (2026, March 17). NIH grant awards are again lagging far behind historical averages, analysis shows: Short on staff, the agency has focused on funding renewals rather than new grants. STAT. https://www.statnews.com/2026/03/17/nih-grant-funding-slowdown-new-awards-training-grants/

Trump, D. J. (2025a, January 20). Defending women from gender ideology extremism and restoring biological truth to the federal government (Executive Order No. 14168). The White House. https://www.whitehouse.gov/presidential-actions/2025/01/defending-women-from-gender-ideology-extremism-and-restoring-biological-truth-to-the-federal-government/

Trump, D. J. (2025b, August 7). Improving oversight of federal grantmaking (Executive Order). The White House. https://www.whitehouse.gov/presidential-actions/2025/08/improving-oversight-of-federal-grantmaking/

One year ago, I left a job as a Program Official at the National Institutes of Health (NIH) that I had held for 22 years. When you work somewhere for that long, it becomes a part of your identity. It’s not an exaggeration to say that my life and sense of self was centered around being an NIH scientist. To leave all of a sudden, unexpectedly and without sufficient time to plan was extraordinarily disorienting. My exit led to a profound sense of grief and loss that I did not fully appreciate in advance. A year later I find myself still processing it all as I continue to chart a path forward.

I don’t regret leaving, but I feel deep sadness that so many of us felt we had to. As I reflect back on the events of a year ago, I’d want to share a sampling of what it was like to work in a completely nonsensical and chaotic agency environment, purposefully designed to spread dread, trauma, hate, and fear.

On January 21, 2025 a memo from HHS informed us of a freeze on all external communications. All meetings, all correspondence, everything cancelled until further notice.

On January 22, 2025 NIH staff learned that Dr. Matthew Memoli had been appointed acting director of NIH instead of the usual process of having the current Deputy serve as the acting director. According to reporting in The Atlantic, Memoli had no prior experience overseeing awards of external grants or running a large agency. But, in 2021, he had called COVID vaccine mandates “extraordinarily problematic” in an email to Anthony Fauci (then director of the NIH’s National Institute of Allergy and Infectious Diseases) and reportedly refused the shot himself which caused Jay Bhattacharya, Donald Trump’s nominee to lead the NIH, to praise Memoli on social media as “a brave man who stood up when it was hard.” Also, Memoli had previously been deemed noncompliant with an internal review, two officials said, after he submitted a DEI statement calling the term “offensive and demeaning.” This appears to be the basis for his appointment.

Also, on January 22, 2025 we were told to report staff who worked on issues related to “DEI.”

A memo dated January 27, 2025 from OMB announced the pause of all grants, loans, and other financial assistance programs in the service of “ending wokeness.”

On January 28, 2025 we all received the infamous “Fork in the Road” email urging us to resign from the civil service.

By February 4, 2025 several news outlets reported that HHS employees, including some of my friends/colleagues at the NIH, were being terrorized after a dark money right-wing “DEI Watchlist” website published a list of “targets” it claimed were “involved with DEI initiatives.” A majority of these civil servants were Black. Some of my NIH friends were doxxed at their homes. According to NBC news, Dr. Georges Benjamin, the executive director of the American Public Health Association, learned about the site when a federal health worker sent it to him and he said: “This is a scare tactic to try to intimidate people who are trying to do their work and do it admirably.” “It’s clear racism.” NIH staff who were victimized were terrified, and they were offered no help from NIH leadership.

On February 7, 2025 an email from HHS informed us that a Presidential Memorandum dated January 20, 2025 ordered the elimination of all remote and telework arrangements. All HHS employees would be required to work at a physical HHS facility unless otherwise excepted by applicable law. I eventually received the orders to personally return to the physical office space full time beginning on March 17.

Excerpt from email:

February 9, 2025 marked the release of NOT-OD-25-068 which immediately capped indirect costs at 15% for all awards. (This action was challenged in court and eventually was determined to be illegal.)

On February 12, 2025 NIH’s Principal Deputy Director, Larry Tabak, departed, and then the next day on February 13, 2025 NIH’s Deputy Director for Extramural Research, Mike Lauer, also left, and the anti-vaccine conspiracy theory proponent RFK Jr. was confirmed by the Senate to become the next HHS Secretary.

On February 14, 2025 approximately 1000 NIH probationary employees were fired without any advance notice. Even their supervisors didn’t know about the firings in advance. In my office at NCCIH, we lost several of our amazing program analyst colleagues that day. It was senseless, cruel, and tragic.

By February 20, 2025 I learned that all of our new grant awards were “on hold” although we were not given any reasons for this hold.

On February 22, 2025 a cryptic email from OPM ordered us to “reply to this email with approx. 5 bullets of what you accomplished last week and cc your manager.”

On February 28, 2025 a list was circulated internally at NIH documenting 76 Notice of Funding Opportunities (NOFOs) that were immediately canceled by the Trump administration. I have uploaded this list of Terminated NOFOs so that you can read them and see what was lost.

On March 3, 2025, HHS/NIH ordered all staff to comply with the OPM 5 bullets email requirement, so we all did. It was ridiculous.

In a March 5, 2025 email NIH staff learned that HHS received authorization from the Office of Personnel Management (OPM) to offer Voluntary Early Retirement Authority (VERA) to eligible employees effective for 10 business days (from March 3 to March 14, 2025). This gave us just 9 days to decide whether to take it or not. Initially we were told that if we chose to take VERA, we could continue working until October 1, 2025, and that we would be able to cancel our VERA request at any time if we changed our minds. However, that promise was quickly changed, and we were informed that in order to take the VERA and the VSIP together would have to exit the federal government no later than April 18, 2025.

Previously federal retirement planning would be something that occurs over the course of a year or more, but we had only days to decide, plan, and file the correct forms. This was incredibly anxiety inducing in and of itself, let alone in the context of all the other ongoing chaos. As you might imagine, the NIH HR office was completely overwhelmed during this time, so we were not able to receive any of the usual personalized retirement guidance that these HR professionals used to provide. Instead, they issued FAQ lists and hosted a few sold out informational sessions on MS Teams. I was only able to join one of these webinar sessions because the rest were at maximum capacity. So, the choice to take VERA meant early retirement by self-design and by doing your own research. Good luck!

On March 6, 2025 the news media reported that the NIH had begun mass terminations of research grants that fund scientific projects because they “no longer meet agency priorities.” NIH Program Officials, like me, were not consulted. We learned about the grant cancellations at the same time as the investigators.

On March 17, 2025 I was officially ordered to report to in person work at the office, and several DOGE staffers were working on the 10^th floor of my building. I saw them walking around for several weeks. They were silent and wouldn’t speak to me.

On March 21, 2025 NIH staff were informed that we were no longer allowed to use any “nicknames” in our staff directory. Only our legal names would be allowed. Because, of course, if someone refers to me as “Liz” instead of “Elizabeth” that might promote gender ideology and extremism?

On March 27, 2025 HHS announced its “Transformation to Make America Healthy Again” agenda by Restructuring HHS with plans to cut the staff from 82,000 to 62,000. NIH would decrease by 1200.

April 1, 2025 will go down as “one of the darkest days” for biomedical science and public health as NIH purged agency leadership and instituted mass layoffs. Approximately 1,200 to 1,300 staff members at NIH were laid off, as part of a broader, sweeping reduction-in-force across federal health agencies. These cuts targeted administrative, communications, and support roles, along with the removal of four main scientists and several institute directors, marking an intense restructuring of the agency. My office lost about 40% of our staff that day. Also, on this same day Jay Bhattacharya was sworn in as the new NIH Director.

On April 2, 2025, the newly appointed NIH Director, Jay Bhattacharya, issued his first official action: a most ridiculous (non-scientific) order for staff to standardize their email signatures. Imagine being the leader of the world’s largest and most famous biomedical research enterprise in the world and choosing this as your first imperative on the job! What a joke!

On April 10, 2025 the NIH told us “never mind,” you can stop sending your 5 bullet accomplishment lists to Elon Musk now.

On April 11, 2025 we learned from the news media (not from NIH leadership) that DOGE had complete control over NIH payment systems and grants.gov.

By mid-April, I knew I had made the right choice. The chaos wasn’t ending. The cruelty wasn’t stopping. Staying would have meant watching more colleagues fired, more research canceled, more expertise dismissed as ‘woke.’ I couldn’t be complicit by staying silent, and I couldn’t speak while still employed. So, I left.

April 18, 2025 was my last day reporting to work at NIH/NCCIH. I handed my laptop, iPhone, and NIH employee badge to my supervisor at the end of the day and that was the end of it. After 22 years there was no retirement celebration, no fanfare, just a few tears, and then I said goodbye to my friends/colleagues and left. A year later I am still processing the loss.

Sources

Bensen, J. (2025, February 14). ‘Taking away years of experience’: NIH probationary employees fired Friday: Trump administration ordered federal agencies to let probationary employees go. NBC Washington. https://www.nbcwashington.com/news/president-trump-politics/taking-away-years-of-experience-nih-probationary-employees-fired-friday/3845749/

Diamond, D., Natanson, H., & Johnson, C. Y. (2025, April 11). A DOGE engineer removed users’ access to grants.gov, threatening to further slow the process of awarding thousands of federal grants per year. The Washington Post. https://wapo.st/42jUYnr

Editorial Board. (2026, April 13). A deserved defeat on NIH funding cuts: DOGE tried to slash research grants by targeting “indirect costs.” A court ruled that to be illegal. The Washington Post. https://wapo.st/4vAtCHh

Kozlov, M. (2025, April 1). ‘One of the darkest days’: NIH purges agency leadership amid mass lay-offs. Nature. https://www.nature.com/articles/d41586-025-01016-z

Kozlov, M., & Mallapaty, S. (2025, March 6). Exclusive: NIH to terminate hundreds of active research grants. Nature. https://www.nature.com/articles/d41586-025-00703-1

Lovelace, B., Jr., & Edwards, E. (2025, February 4). Federal health workers terrified after ‘DEI’ website publishes list of ‘targets’: The site calls out workers who have been involved with DEI initiatives. A majority are Black. NBC News. https://www.nbcnews.com/health/health-news/federal-health-workers-terrified-dei-website-publishes-list-targets-rcna190711

Masson, G. (2025, February 18). 2 NIH leaders depart as White House cuts thousands of jobs across federal health agencies. Fierce Biotech. https://www.fiercebiotech.com/biotech/2-nih-leaders-depart-white-house-cuts-thousands-jobs-across-federal-health-agencies

Wu, K. J. (2025, February 27). Inside the collapse at the NIH: Administration officials pressured the NIH to avoid clear advice from the agency’s own lawyers to restart grant funding now. The Atlantic. https://www.theatlantic.com/health/archive/2025/02/nih-grant-freeze-biomedical-research/681853/

U.S. Department of Health and Human Services. (2025, March 27). HHS announces transformation to make America healthy again. https://www.hhs.gov/press-room/hhs-restructuring-doge.html

This essay is part of an ongoing series reflecting on what I learned over more than two decades working inside the U.S. biomedical research enterprise. Each piece stands alone, but together they examine how science is shaped not only by ideas and funding, but by the structures that support or constrain them.

NIH Building 1, Bethesda, Maryland, 1951, Provided by U.S. National Library of Medicine: https://collections.nlm.nih.gov/catalog/nlm:nlmuid-101394961-img

In 1945, two appointed staff members of the newly created NIH Division of Research Grants wrote a letter to the dean of every medical school in the United States to solicit the first grant applications under the new system authorized by the Public Health Service Act of 1944. Within a year, 264 grants totaling $3.9 million had been awarded to researchers at 77 universities across 26 states (Van Slyke, 1946). The first grant, for $92,000, supported a study of the inheritance of muscular dystrophy at the University of Utah (Tabor, 2022). Those two NIH staff members and their two secretaries had just built the administrative foundation for what would become the most productive publicly funded biomedical scientific enterprise in human history.

Eight decades later, the system that grew from those letters, including the two-tiered scientific peer review process, the independent Advisory Councils, the public announcement of funding priorities, and the principle that scientists decide what science gets funded, is being fundamentally restructured. To understand what is being lost and why it matters, it helps to understand how that system was built, why it was designed the way it was, and what it has produced.

I spent 22 years as a Program Officer at NIH, developing funding opportunities, shepherding them through scientific review, and building programs that trained the next generation of researchers. I watched the system evolve over two decades. I never imagined watching it be dismantled. This essay draws on both the historical record and my own direct experience to explain what that system actually was, and what we stand to lose.

Before the Government Got Involved

Before World War II, the United States government did not fund much medical research outside its own laboratories (Tabor, 2022). Most medical and public health research was supported by pharmaceutical companies and private foundations. By 1934, the Rockefeller Foundation alone provided two-thirds of medical research funding in the country (Tabor, 2022). NIH existed, having been established in 1930 by renaming the Hygienic Laboratory of the U.S. Public Health Service, but it was conceived as a government laboratory, not a national funder of outside science (Tabor, 2022).

This arrangement had a structural limitation that was rarely articulated clearly, because the alternative was not yet imaginable. As Dzau and Yamamoto (2025) observe in their National Academy of Medicine analysis, government support for biomedical research has been unique in its emphasis on basic knowledge discovery, its support for investigations that lack immediate promise of profitable product development, and its underwriting of large-scale, long-term research endeavors. Private foundations fund research that interests them. Pharmaceutical companies invest in research with commercial applications. Philanthropies gravitate toward causes with high public visibility. None of these mechanisms reliably fill the space that basic science requires: long-horizon studies with uncertain payoffs, research on diseases too rare or too unglamorous to attract industry investment, and fundamental investigations into how biology works that may not produce a clinical application for twenty years. That gap is the space that government funding was eventually built to fill.

War Builds the Machine

The catalyst for federal investment in science was World War II. As Tabor (2022) recounts, James Conant, president of Harvard University, brought the idea of a government scientific research committee to Vannevar Bush, head of the Carnegie Institution, who brought it to President Roosevelt. In 1940, Roosevelt created the National Defense Research Committee under Bush to channel government resources into war-related research at civilian universities. In 1941, a Committee on Medical Research was created under the same umbrella to address military medical needs. The returns were rapid: advances in penicillin production, blood banking, and infectious disease, among others (Dzau & Yamamoto, 2025).

Roosevelt wanted to sustain that investment after the war, so he commissioned Bush to evaluate the case for ongoing national support of science. The resulting 1945 report, Science, the Endless Frontier, concluded that sustained investment in basic research and scientific training would be essential to postwar prosperity and national security (Dzau & Yamamoto, 2025). It became the intellectual blueprint for the expansion of NIH. By 1962, the NIH budget was 1,000 times what it had been in 1938 (Dzau & Yamamoto, 2025).

The wartime Committee on Medical Research (CMR) funded science through contracts, not grants. Tabor (2022) draws an important distinction: contracts gave the government control over the direction and goals of the work, whereas grants trust scientists to identify the right problems and pursue them with rigor. The CMR used contracts because it needed specific military problems solved on a defined timeline, but even within that constrained model it employed outside scientific experts to evaluate proposed contracts, because the government recognized it was not qualified to judge scientific merit on its own (Tabor, 2022). That practice of outside reviewers became the template for what followed.

NIH converted the CMR contracts into grants at the end of 1945, and the Committee on Medical Research was disbanded on December 31, 1946 (Tabor, 2022). NIH created an Office of Research Grants in 1945 and appointed Dr. Cassius J. Van Slyke as its director on January 1, 1946 (Tabor, 2022). Working with a staff of four, Van Slyke created the administrative structure and grants procedures that would remain largely in use for the next three-quarters of a century (Tabor, 2022). He predicted the program “may have early and profound effects upon the course of medical history and the national health” (Van Slyke, 1946). It was a considerable understatement.

Building the Firewall: Peer Review and the Two-Tiered System

The decision to have all grant applications reviewed by scientists from outside the government was not accidental. According to Tabor (2022), there was a clear institutional philosophy that outside review was essential to prevent political interference in scientific decisions and to avoid conflicts of interest within an agency that was both funding and conducting its own research. The Public Health Service Act of 1944 specified that outside scientific experts should review NIH grants, and that Advisory Councils would make recommendations to the U.S. Public Health Service regarding the research investments (Van Slyke, 1946; Tabor, 2022).

To find reviewers for the first applications, Van Slyke and his colleague Ernest Allen used the directory American Men of Science to identify specialists in each subject area (Tabor, 2022). As Allen later recalled, “we would write to three or four of these people and get their opinions on the merit of the proposal. We then took [their assessments of] the proposals to the National Advisory Health Council” (as cited in Tabor, 2022). Later, the grants office began establishing Study Sections, composed of civilian scientists to review applications for grants in specialized fields (Swain, 1962).

A process formalized into a standard two-tiered peer review system was fully established by 1955 (Tabor, 2022). The first tier, study sections, brought together panels of external scientists to evaluate applications on scientific merit alone: the significance of the research question, the rigor of the proposed approach, and the qualifications of the investigators (Tabor, 2022). By 1950, study sections assigned numerical scores rather than simple approve-or-disapprove decisions, allowing funding to be prioritized in order of appraised merit (Tabor, 2022).

The second tier, Advisory Councils at each institute, evaluated whether meritorious science fit the institute’s mission and priorities. By 1955, each of the eight NIH institutes then in existence had its own Advisory Council of outside experts conducting this second-level review (Tabor, 2022). Institute directors made the final funding decisions, but within a system designed so that scientific merit was evaluated first by external scientists.

Van Slyke articulated the animating principle: the NIH grants program should be “a medical research program of scientists and by scientists” that maintains “the integrity and independence of the research worker and his freedom from control, direction, regimentation, and outside interference” (Van Slyke, 1946).

The extramural research program expanded rapidly as Congress established additional institutes: the National Mental Hygiene Institute (1946), the National Heart Institute (1948), and the National Dental Research Institute (1948), among others (Reynolds & Price, 1949). As specified in law, each new institute was required to have its own Advisory Council. By 1948, the growth of the program had led to the pluralized designation “National Institutes of Health.” Today there are 27 NIH Institutes, Centers, and Offices, all operating within that same statutory framework.

Over time, the system this principle produced 174 Nobel laureates among NIH-funded researchers, along with the sequencing of the human genome, antiretroviral therapy for HIV, vaccines for polio and hepatitis B and HPV and COVID-19, and treatments for cancers that were uniformly fatal within living memory (Dzau & Yamamoto, 2025). None of those advances were predicted at the time the underlying research was funded. That is not a coincidence. It is the point.

The Councils that provide that second tier of accountability are now themselves under threat. The majority of the 25 NIH Advisory Councils are now operating with less than half their full complement of members, according to STAT’s analysis of annual reports of council activity submitted at the end of December (Molteni, 2026). It is unknown why the Trump administration hasn’t moved to fill these vacancies. The upshot is that many of these Advisory Councils are in danger of running afoul of federal laws governing council makeup and operations, the same laws that have governed them since the Public Health Service Act of 1944 mandated their creation.

Going Public: The NIH Guide and the Promise of Transparency

For the first two decades of the NIH extramural grants program, funding opportunities were communicated informally: direct outreach to institutional contacts, institute-specific announcements, and word of mouth. A researcher not connected to the right people at the right institution might simply not learn about an opportunity directly relevant to their work.

On April 30, 1970, NIH launched the NIH Guide for Grants and Contracts. Early issues of the Guide (NIH, 1971) show a centralized weekly bulletin covering new funding opportunities, policy changes, and scientific priorities across all NIH institutes. For the first time, every researcher in the country had access to the same information, through the same channel, at the same time. A scientist at a small rural university could learn about a new funding opportunity at the same moment as a researcher at a well-connected major research institution. The Guide democratized access in a way that institutional networks and direct outreach could not.

The Guide also created accountability that had not previously existed in any systematic form. When NIH decided to make a particular area of research a priority, it had to say so publicly, in writing, in a permanent archived record that any researcher, institution, member of Congress, or member of the public could read. Funding priorities became matters of documented public record rather than internal decisions communicated through informal channels. I relied on the Guide throughout my 22-year career, as did every Program Officer and grant administrator in the country.

In August 2025, NIH announced it would stop posting funding opportunities in the NIH Guide beginning in fiscal year 2026, consolidating all postings exclusively in grants.gov (NIH, 2025). The stated rationale was to reduce duplication across federal systems. In practice, this change has contributed to a significant reduction in transparency, by adding a new forecast layer that, as I have documented in my prior analyses (Ginexi, 2025; 2026a; 2026b), buries the large majority of anticipated funding opportunities before they are ever published as real announcements.

How a Funding Opportunity Actually Gets Made

My earlier essays have described what is happening to NIH funding opportunities now. This section describes what happened before, drawing on my 22 years of direct experience in the process.

The process began with program staff and Institute, Center, and Office leadership. Program Officers spend their careers monitoring the scientific landscape in their assigned areas: reading literature, attending conferences, talking with investigators, and analyzing the institute’s existing grant portfolio to identify gaps. The driving questions were: What diseases were under-researched? What scientific problems went unaddressed because no investigator had proposed to tackle them through a standard unsolicited grant? What gaps in the scientific workforce needed targeted intervention? Ideas for new funding opportunities came from many directions, including portfolio gap analysis, requests for information from the scientific community, scientific workshops with external subject matter experts, strategic plan priorities, Advisory Council input, and recognition by program staff that a clinical population or a scientific problem was being systematically neglected.

Once an idea survived internal vetting, progressing through branches, divisions, and institute or center directors, it was developed into a formal Concept document. That Concept went before the Advisory Councils. With a mandate dating all the way back to the original 1944 Public Health Service Act, NIH Advisory Councils are federally chartered committees of external scientific experts and public representatives who advise on NIH research priorities and policies. They meet three times a year. A program officer presenting a Concept prepared a formal presentation, described the scientific rationale and proposed grant mechanism, and answered questions from council members in an open public meeting. Council members voted on whether the idea was sound and ready to proceed. A negative vote sent the program officer back to work. Sometimes an idea came before the council twice before being approved, and sometimes it did not survive the second presentation.

Writing the NOFO itself was a substantial undertaking. The document had to specify what NIH was looking for and why, what scientific approaches were appropriate, which grant mechanism was being used and why, what the budget parameters were, and what review criteria would be applied. The choice of mechanism was not administrative box-checking; it carried real scientific meaning. An R03 funds exploratory work. An R01 supports an individual investigator’s program. A P50 funds a multifaceted research program on a specific disease with multiple interconnected scientific components. A U01 is a cooperative agreement involving closer NIH participation in the conduct of the research. A T32 supports institutional training programs. A K01 supports scientists needing further training in a specific area.

When a targeted NOFO was published as a Request for Applications (RFA) with a monetary set-aside or as a Program announcement with special receipt, referral, and/or review (PAR), the applications generated could be reviewed by a specially convened expert panel, scored against each other rather than against the full universe of NIH applications. This meant that a proposal for rare disease research was evaluated by reviewers with relevant expertise, competing against other rare disease proposals, rather than being forced into a general study section alongside cancer immunotherapy and cardiovascular genomics proposals. The result was a realistic pathway to funding the best ideas within a specialized targeted area.

The requirement that all NOFOs receive Advisory Council concept clearance before publication became universal policy around 2014, following the NIH Reform Act of 2006 and subsequent internal policy updates. When I started as a Program Officer in 2003, not all NOFOs required that level of review. By the time I left, it was standard practice for all of them. The effect was that every targeted funding opportunity NIH published had been vetted by external scientific experts in a public meeting, with a recorded vote, before any researcher was invited to apply. That public accountability was not bureaucratic formality. It was the mechanism by which the scientific community, and the public it represents, had a documented role in setting research priorities.

What Changed in 2025-2026, and Why It Is Different in Kind

The changes the Trump administration has made to this system since 2025 are not a simplification or a streamlining and show no sign of stopping. They are a transfer of authority at every stage of the process, moving decision-making power away from scientists and toward political appointees.

The sequence of policy changes was rapid. In April 2025, NIH staff were informed that HHS was requiring a redesign of the NOFO format and that within one year all institutes would be expected to reduce the number of NOFOs by 50%. Staff were told that Advisory Council concept clearance would now require HHS pre-approval first. That HHS approval process, I have learned from colleagues still at NIH, can take six months or longer. The political approval gate now precedes the scientific review gate.

On August 14, 2025, when NIH announced the discontinuation of the NIH Guide for Grants and Contracts as a source for funding opportunities beginning in fiscal year 2026 (NIH, 2025), it also introduced the new forecasting requirement. Every institute, center, or office must now post a brief high-level forecast of an anticipated funding opportunity before being permitted to develop the actual NOFO. As of May 2025, each institute was limited to submitting just five targeted NOFOs for approval consideration, a cap with no scientific rationale.

By September 2025, an NIH NOFO Reform Group had been established to oversee compliance with the reduction mandate and to move the agency towards using mostly “Parent Announcements,” (or Parent NOFOs), which are broad Notice of Funding Opportunities that allow investigators to submit unsolicited, investigator-initiated research grant applications to the NIH. Unlike specific RFAs, they cover general, wide-ranging research areas, often for popular mechanisms like R01, R21, or R03, allowing researchers to submit applications for any project within an institute’s mission rather than a specific topic. NIH wants to expand the number mechanisms that use Parent Announcements, and significantly reduce the use of targeted NOFOs.

The written policy governing these changes is the Unified Funding Strategy, which requires that all awards align with administration priorities as determined by NIH/OD and HHS. Internally, NOFO reform efforts cite the Executive Order on Improving Oversight of Federal Grantmaking (The White House, 2025) as a rationale. Colleagues still at NIH have told me that OMB review is now required after HHS approval, adding a third political approval layer to a process that previously had none. A dizzying array of Updates to Finding NIH Funding Opportunities and Information are underway (NIH, 2026), with more likely coming. As of this writing, new implementation guidance continues to appear, each round further constraining what ICOs can propose and how, all purporting to “simplify the process” and consolidate 27 ICOs to conform to one NIH central authority.

The practical result is what I have documented in my prior analyses (Ginexi, 2025; 2026a; 2026b): 83% fewer posted NOFOs in 2025 compared to recent baselines, a forecast graveyard of 205 open forecasts already past their promised publication dates, with 28 forecasts permanently canceled, and a replacement “Highlighted Topics“ portal that lists general research areas without the scientific specificity, mechanism selection, set-aside funding, or dedicated peer review panels that targeted NOFOs previously provided. These figures reflect data through early 2026. The trajectory shows no indication of reversal.

The Highlighted Topics portal illustrates what the transfer of authority looks like in practice. Under the previous system, Advisory Councils of external scientists would have evaluated, in public meetings with recorded votes, whether these were the highest-priority areas for NIH investment and delineated specific grant mechanisms as the best match for the science at hand. Under the current system, the list is vetted and approved by political appointees.

The irony of instituting “Highlighted Topics” under the guise of a “Unified Funding Strategy” is rich. Applications submitted for these topics will be harder to track (compared to a targeted NOFO) as they may not be reviewed together in the same study sections; they may use wildly different grant mechanisms and budgets; they may target very different institute and center missions; and they may not even arrive in the same council rounds. This means that disparate program staff across the NIH will have a difficult time ranking the best “Highlighted Topics” applications for funding consideration to achieve a so-called “Unified Funding Strategy.” This new approach introduces more undue administrative complexity than existed before.

These changes are not complete. New guidance continues to arrive, existing forecasts continue to age past their promised dates, and the research community has no reliable way to know which anticipated funding opportunities will ever materialize. What began as a series of specific policy decisions has become the operating reality of NIH.

Why Expert Control Is Not Just Tradition

The case for peer review and expert-driven priority setting is sometimes presented as though it were primarily a matter of institutional habit. The historical record does not support that interpretation. Congress deliberately intended for the NIH to rely on scientists to vet its grants (Van Slyke, 1946; Tabor, 2022). If political priorities rather than scientific judgment determine what gets funded, NIH will lose the structural characteristic that makes it irreplaceable.

The catalogue of advances that Dzau and Yamamoto (2025) document, including a 56% decline in heart disease deaths between 1950 and 1996, a 54% reduction in the global AIDS death rate since 2010, vaccines for six major infectious diseases, and cancer therapies that have converted previously fatal diagnoses into manageable conditions, were not predicted at the time the underlying research was funded. That is the point of the system Van Slyke built: it trusted scientists to identify the right questions before the answers were visible. Political appointees cannot reliably do that, not because they lack intelligence, but because political utility is a different criterion than scientific promise, and optimizing for one reliably undermines the other.

From my own experience across 22 years at NIH, the structures built around funding opportunity development, Advisory Councils, concept clearance, two-tiered peer review, the NIH Guide, and the NOFO itself, were not bureaucratic excess or undue administrative complexity. Each structure was built through legislation and because experience showed it was necessary. The Guide was built because informal networks excluded researchers who were not well-connected. Advisory Councils were built because NIH was mandated by Congress to implement external scientific accountability that government staff alone could not provide. Targeted NOFOs were instituted because “we will fund good research in this general area” is not always a sufficient signal to the research community, while specific, publicly documented announcements of scope, mechanism, budget, and review criteria allow researchers to address particular gap areas.

Unlike what the current NIH leadership would have you believe, targeted calls for research have never been solicited at the expense of investigator-initiated research. There is no limit for investigators to propose novel or unexpected ideas. In fact, over 80% of NIH extramural funding each year goes to investigator-initiated science solicited by general funding announcements such as the Parent R01 (NIH, n.d.-a; NIH, n.d.-b). The system, while not perfect, was working.

Van Slyke stated the founding principle in 1945 and it has not become less true since: the NIH grants program should be “a medical research program of scientists and by scientists” that preserves “the integrity and independence of the research worker and his freedom from control, direction, regimentation, and outside interference” (Van Slyke, 1946).

The Future of Biomedical Research in the United States

In 1945, Van Slyke predicted that the NIH grant program “may have early and profound effects upon the course of medical history” (Van Slyke, 1946). In fiscal year 2024, NIH invested over $37 billion in extramural research, distributed across more than 2,500 universities, medical schools, and research institutions (NIH, 2024).

What made that growth possible was a principle embedded in the system from the very beginning: when scientists propose the science, other scientists evaluate the proposals, and the results of that evaluation are published for anyone to scrutinize, the country gets the science it could not have predicted it needed. That is what Van Slyke’s letter to the medical school deans was about. It was not about administrative efficiency or reducing fragmentation. It was about asking scientists what science is needed, trusting the answer, and building a transparent, accountable public system to fund the best ideas.

What is being built in its place is a system where research priorities are set by whoever holds political power in Washington. It is a system where the political approval gate precedes the scientific review gate, where funding opportunities are replaced by highlighted topic lists approved without public scientific input, and where the research community waits in a forecast graveyard for targeted announcements that may never come.

The question before us is whether we understand what we are trading away, and whether we think it is worth it.

The system Van Slyke built trusted scientists to ask the right questions. The system replacing it trusts politicians to know the answers. Eighty years of evidence tells us which of those bets paid off.

Sources

Dzau, V. J., & Yamamoto, K. R. (2025, August 18). Government-funded health and biomedical research is irreplaceable. National Academy of Medicine. https://nam.edu/perspectives/government-funded-health-and-biomedical-research-is-irreplaceable/

Ginexi, E. (2026, March 17). Why is the NIH abandoning science? This is not a temporary slowdown. The Chronicle of Higher Education. https://www.chronicle.com/article/why-is-the-nih-abandoning-science

Ginexi, E. (2025). I wrote research funding announcements for NIH for 22 years. This year they’ve published 14. Substack. https://substack.com/@elizabethginexi/p-191085985

Ginexi, E. (2026a). The NOFO graveyard. Substack. https://elizabethginexi.substack.com/p/the-nofo-graveyard

Ginexi, E. (2026b). Inside the NIH forecast graveyard: What NIH is canceling, what it is burying, and what it means. Substack. https://substack.com/@elizabethginexi/p-192737949

Molteni, M. (2026, January 22). Unfilled vacancies have depleted NIH advisory councils, key players in grant approvals: Panels are operating without full range of expertise needed to make informed decisions. STAT. https://www.statnews.com/2026/01/22/nih-advisory-council-vacancies-raise-questions-funding-politicization/

National Institutes of Health. (2026). Updates to finding NIH funding opportunities and information. Retrieved April 8, 2026, from https://grants.nih.gov/policy-and-compliance/implementation-of-new-initiatives-and-policies/updates-to-finding-nih-funding-opportunities-and-information

National Institutes of Health. (2025, August 14). NIH will stop posting notices of funding opportunities in the NIH guide for grants and contracts in FY2026 [Notice NOT-OD-25-143]. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-143.html

National Institutes of Health. (2024). Total NIH Budget Authority: FY 2024 Final. U.S. Department of Health and Human Services. https://report.nih.gov/nihdatabook/report/4

National Institutes of Health. (n.d.-a). Research project grants (RPGs): Number of awards and total funding, by type [Report 34]. NIH Data Book. https://report.nih.gov/nihdatabook/report/34

National Institutes of Health. (n.d.-b). Research project grants (RPGs): Number of awards and total funding, by mechanism [Report 35]. NIH Data Book. https://report.nih.gov/nihdatabook/report/35

National Institutes of Health. (1971, July 29). NIH Guide for Grants and Contracts, 1(9). https://grants.nih.gov/grants/guide/historical/1971_07_29_Vol_01_No_09.pdf

Reynolds, F. W., & Price, D. E. (1949). Federal support of medical research through the Public Health Service. American Scientist, 37(4), 578–586. https://pubmed.ncbi.nlm.nih.gov/18148854/

Swain, D. C. (1962). The rise of a research empire: NIH, 1930 to 1950. Science, 138(3546), 1233–1237. https://www.science.org/doi/10.1126/science.138.3546.1233

Tabor, E. (2022). The origins of NIH medical research grants. Hektoen International: A Journal of Medical Humanities. https://hekint.org/2022/10/18/the-origins-of-nih-medical-research-grants/

The White House. (2025, August 7). Improving oversight of federal grantmaking [Executive Order]. https://www.whitehouse.gov/presidential-actions/2025/08/improving-oversight-of-federal-grantmaking/

Van Slyke, C. J. (1946). New horizons in medical research. Science, 104(2711), 559–567. https://www.science.org/doi/10.1126/science.104.2711.559

This essay is part of an ongoing series reflecting on what I learned over more than two decades working inside the U.S. biomedical research enterprise. Each piece stands alone, but together they examine how science is shaped not only by ideas and funding, but by the structures that support or constrain them.

This image was generated by Google AI (Gemini)

In my last essay I introduced the concept of the forecast graveyard, a growing pile of NIH Notices of Funding Opportunities (NOFOs) that are announced to the research community through grants.gov and then quietly never published. I have now done a deeper analysis of both the forecasts that were formally archived and the forecasts that remain listed as open as of this writing. Of the 35 forecasts that have been archived, 28 remain permanently canceled with no path forward. The picture that emerges is not haphazard. It is a story about two different strategies for eliminating research the current administration does not want to fund, and about a legal obligation to Congress that is being quietly abandoned.

Two Strategies, One Outcome

When people think about NIH cancellations, they typically think about explicit terminations of active, ongoing research grants killed overnight with a form letter. That is one kind of cancellation, and it generated the lawsuits and the headlines.

There is a quieter kind, and it operates through the NOFO forecast system. A NOFO forecast is supposed to announce a forthcoming funding opportunity. In it, NIH tells the research community that a funding opportunity is coming, gives investigators time to prepare, and then provides a projected date when NIH will publish the full NOFO. Instead, NIH forecasts are increasingly functioning as a way to give the appearance of activity while delivering none.

I have compiled and analyzed two lists: 35 forecasts that were formally archived, and 336 that remain open as of today. Of the 35 archived, 28 remain permanently canceled with no path forward, while 7 were eventually reissued in some form. Of those 336 open forecasts, 205 are already past their promised posting date. That is 61% of all open forecasts sitting overdue, with no full NOFO published and no explanation given to the research community waiting for them. The oldest two have been sitting since August 2024, now 581 days in the system. Both are NINDS forecasts for the BRAIN Initiative. One is overdue by nearly ten months; the other by six.

What Got Formally Canceled

The 35 archived forecasts were not all canceled at once, or by the same actors. They arrived in three distinct waves, each reflecting a different phase of the political pressure on NIH.

The first and largest wave came in April 2025, when DOGE swept out 24 forecasts in a matter of days. All carry the following notation in the grants.gov system:

“Archiving forecast pending further agency review.”

When you look at what those 24 have in common, the pattern is not subtle. Eight contained explicit equity, diversity, or health disparities language: funding opportunities for health equity research, diversity in aging, vision health equity, and cancer disparities in people with HIV. Seven involved substance use or alcohol research. Four involved HIV or AIDS. Six were workforce training forecasts. Several hit multiple flagged categories at once. The NIDA “Reaching Equity at the Intersection of HIV and Substance Use” forecasts combined HIV research with equity language and substance use, touching three screened categories simultaneously. These cancellations read like the output of a keyword search, because they almost certainly were.

To be fair, not every April 2025 archived forecast stayed buried. Seven of those 24 were eventually reissued in some form. Three of them, two NIA Alzheimer’s clinical trials and the NHLBI VINYL pediatric lung disease consortium, cleared the approval process and made it all the way to published NOFOs. Four others were reissued as new forecasts and remain in the system, still waiting. The Paul Calabresi Career Development Award in Clinical Oncology from NCI has now been in the forecast system for 19 months across two separate forecast postings, with its expected publication date already 119 days overdue. The NICHD Infrastructure for Population Dynamics Research Program has been in the system for 15 months and is 248 days past its expected posting date. It is worth noting what the three success stories (i.e., the NIA and NHLBI reissues) have in common: they are disease-focused, politically unambiguous, and carry no equity or DEI framing. The forecasts that cleared the process were the ones least likely to attract political scrutiny. That pattern holds even within the small population that got a second chance.

The second wave came in the late summer and fall of 2025, after DOGE had formally departed from NIH. Four more forecasts were archived between August and October 2025 by NIH leadership. These four include the NIH Director’s Early Independence Award, a NICHD grant on bacterial STIs in HIV-affected adolescents, and two NIDCR training programs. Like the DOGE cancellations, these carry HIV and training content, suggesting the political screening criteria were already embedded in agency decision-making before DOGE left.

The third wave is ongoing. Seven forecasts have been archived since February 2026 by current NIH leadership, HHS, and/or OMB. This is where the story becomes more troubling, and the language shift in the grants.gov system is itself revealing. The earlier cancellations said “pending further agency review,” implying a temporary hold and leaving researchers with some hope of eventual publication. The 2026 cancellations carry a blunter notation:

“This NOFO will not be published. The Forecast is being archived.”

No ambiguity, no promise of reconsideration. These include a NIMH forecast for research on crisis response services for suicide prevention, an NIA T32 training program for aging research, an NIA short course for Alzheimer’s disease clinical trial workforce development, an NHLBI forecast for research on clonal hematopoiesis and chronic inflammation, the NIAAA Comprehensive Alcohol Research Centers P60 mechanism, and an NIDCR forecast for dental and craniofacial data analysis.

Only two of these seven contain equity or disparities language. The others were canceled for reasons that are not visible in their content. When forecasts for suicide prevention research and dental research methods are eliminated by the same process, the gate is no longer about flagged terminology. It is about control over what funding opportunities will be allowed.

What Is Being Left to Die Quietly

The more revealing story may be the forecasted opportunities that have not been formally canceled but have not been published either. Many of these appear to be expiring by neglect rather than by explicit decision, and the data support that interpretation.

Consider NIMHD, the National Institute on Minority Health and Health Disparities. All seven of its open forecasts are overdue, by between 122 and 318 days. None have been formally canceled. The NIMHD forecasts involve health disparities research centers, minority institution programs, and the EmbraceHealth Clinical Research Network. These are precisely the kinds of funding opportunities that would attract attention and criticism if explicitly terminated. Letting them sit generates the same practical outcome, opportunities never posted, without creating the paper trail that a formal cancellation would.

NINR, the National Institute of Nursing Research, shows the same pattern. All six of its open forecasts are overdue. All six were posted in May 2025 and cover community-partnered nursing research, health disparities in rural populations, violence against women, and school health environments. They have been sitting for nearly ten months past their expected posting dates.

NIAAA, which posted zero NOFOs in all of 2025, is managing both strategies at once. Four of its forecasts were permanently archived while nine others remain listed as open, seven of them overdue by six to eight months. Researchers in the alcohol science field are sitting with a list of anticipated funding opportunities and no indication of whether any will materialize. The formal cancellations cleared out the most explicitly flagged content. The rest are just sitting.

The distinction between explicit cancellation and passive expiration matters for accountability. A canceled forecast leaves a record. A forecast that simply ages past its promised date never appears in a cancellation tally. For anyone tracking this policy, including Congress, the official record understates the damage by a substantial margin. That understated damage is especially concentrated in one category of funding opportunity that has received almost no public attention.

The Infrastructure Problem

More than half of all open forecasts (192 of 336, or 57%) are for coordinating centers, research networks, multi-site consortia, data hubs, and other large-scale infrastructure programs. These are the programs that build and sustain the platforms on which individual investigators do their work: clinical trial networks, data coordinating centers, SPORE cancer centers, genomic resource centers, and disease-specific research consortia.

Of those 192 center and infrastructure forecasts, 112 are already overdue, with a median overdue time of 166 days. That is notably longer than the 119-day median for other overdue forecasts, suggesting that large programs face a heavier approval burden. The reasons are not hard to understand. A coordinating center involves larger dollar amounts, longer project periods, and more complex programmatic coordination including a special emphasis panel review. Each of those factors adds friction in an approval process that was already slow and is now operating under a political bottleneck.

The consequences for ongoing research are serious. Large centers do not just support investigators applying for new funding. They sustain infrastructure that active researchers depend on right now: specimen banks, data repositories, clinical trial coordination, and training cores. When a data coordinating center’s renewal sits in forecast limbo for 150 days past its promised posting date, the uncertainty ripples outward to every project the center supports. NCI alone has 14 overdue center forecasts, with an average overdue time of 183 days. NINDS has 12. NIA has 10. NHGRI has 10.

Some of these programs have been waiting since mid-2025. The Experimental Therapeutics Clinical Trials Network (ETCTN) Lead Academic Organizations forecast was due in July 2025 and is now 242 days overdue. The Alzheimer’s Clinical Trials Consortium, one of NIA’s flagship clinical research programs, was due in August 2025 and is 241 days overdue. The HeartShare 2.0 heart failure research network from NHLBI was due in October 2025 and is 166 days overdue.

These are not small investigator-initiated grants that can be resubmitted quickly if timing slips. These are programs that require years of development, involve dozens of institutions, and provide the scientific infrastructure that individual investigators rely on for their own work. When they stall, the damage is not contained to the coordinating center. It spreads.

Congressionally Mandated Programs Are Not Exempt

The most legally significant finding in this analysis is the number of congressionally mandated research programs whose forecasts are now overdue with no movement. Congress established these programs through legislation and appropriated funds for them specifically. NIH does not fund them at its own discretion.

The BRAIN Initiative has eight open forecasts that are overdue, ranging from 54 to 301 days past their promised posting dates. The HEAL Initiative, Congress’s response to the opioid crisis, has five overdue forecasts ranging from 63 to 166 days. The Gabriella Miller Kids First Pediatric Research Program has three forecasts overdue by 243 days. This program was named for a child who died of a brain tumor and was established by Congress specifically to fund pediatric cancer and structural birth defect research. The INCLUDE Project for Down syndrome research has three forecasts overdue by 101 days. NIEHS Superfund and HAZMAT worker training programs have four forecasts overdue by 165 to 210 days, including worker health and safety training at DOE nuclear weapons sites.

When NIH fails to publish NOFOs for programs Congress has mandated and funded, it is not simply making a policy choice. Appropriated funds for specific programs that go unspent because the agency will not issue funding opportunities represent a potential violation of the Congressional Budget Act. This is not a hypothetical. It is the structural consequence of a system in which every targeted NOFO now requires approval from NIH/OD, HHS, and OMB before it can be published, and that approval is not arriving.

The Two Populations

The canceled and sitting forecasts reveal two populations of research being curtailed, though the methods used against each have grown more varied over time.

The first population is research with explicit political markers: DEI language, equity framing, HIV research, racial health disparities, and gender-related topics. Most of these were swept out in the first DOGE wave in April 2025, identified by keyword. The pattern was unmistakable and the grants.gov notation left little ambiguity about the intent.

The second population is everything else: basic biomedical science, workforce training, clinical infrastructure, center renewals, and congressionally mandated programs. What is striking is that this population is being curtailed through two different mechanisms simultaneously. Some have been explicitly canceled in the second and third waves, including forecasts for suicide prevention research, Alzheimer’s workforce development, and dental research methods, none of which carry any obvious political marker. The rest are being strangled by process, sitting overdue in the forecast system with no explanation and no path forward. Whether a forecast gets an explicit cancellation notice or simply ages past its promised date, the outcome is the same: research that was announced to the scientific community never materializes.

Every targeted NOFO now requires several rounds of approval both before and during the forecast process from NIH/OD, HHS, and OMB. Two hundred and five forecasts have passed their promised posting dates without a single public explanation from NIH. The forecast graveyard works because it offers no closure, no record of failure, and no accountability.

Researchers monitoring a BRAIN Initiative forecast cannot tell whether their anticipated funding opportunity is stuck in an approval queue, has been silently deprioritized, or is simply never going to arrive. Investigators keep waiting for the official NOFOs to post on grants.gov. Institutions keep planning. And nothing comes.

Of the 336 forecasts currently listed as open, 205 have already missed the date they were promised to the research community. Twenty-four of them are focused on topics that Congress specifically mandated and funded. One hundred and twelve are large centers and infrastructure programs that active research depends on right now. And not one of them has received a formal explanation, defense, or withdrawal.

That is not a funding pipeline. That is a waiting room with no appointments.

This essay is part of an ongoing series reflecting on what I learned over more than two decades working inside the U.S. biomedical research enterprise. Each piece stands alone, but together they examine how science is shaped not only by ideas and funding, but by the structures that support or constrain them.

In the service of open science, I have made the data underlying this analysis available for download here: NIH Forecasted NOFOs. This list of NIH forecasts was compiled from grants.gov as of March 30, 2026. Anyone working from the same source of publicly available data should be able to reproduce these findings.

Image credit: @nihvigils.bsky.social

On March 23, 2026, Dr. Jon Lorsch, NIH’s Deputy Director for Extramural Research, published a blog post titled “NIH’s Path to a Simpler Funding Opportunity Landscape.” The post attempts to explain and justify why NIH is issuing dramatically fewer Notices of Funding Opportunities (NOFOs) than at any point in recent history. It is a carefully written document, fluent in the language of scientific stewardship and administrative efficiency. But it is built on assertions without evidence, and it sidesteps the most important facts about what is actually happening to NIH-funded science.

I spent 22 years as a Program Officer at the NIH. I know how NOFOs are created, what they accomplish, and what their absence means for the research community. I have been writing about this policy change on Substack and in The Chronicle of Higher Education, and I have the data to respond.

The Numbers Tell a Different Story Than the Blog

Dr. Lorsch acknowledges that NIH historically issued between 600 and 850 NOFOs annually. He frames the current reduction as a modest, principled streamlining. The data tell a very different story.

Using NIH’s own posting records, which I have compiled across 14 years (2012–2026) from the NIH Guide for Grants and Contracts and grants.gov, here is what the NIH-wide NOFO count actually looks like:

• 2012–2024 annual range: 511 to 1,081 posted NOFOs per year

• Average 2019–2024: approximately 710 per year

• Average 2023–2024: 724 per year (the immediate pre-policy baseline)

• 2025 posted NOFOs: 120, which is an 83% decline from the recent baseline

• 2026 posted NOFOs so far: 17, which is a pace far below even the already-collapsed 2025 level

NIH NOFOs Published Over Time (as of March 24, 2026)

To put 2025 in full context: in 2020, when COVID-19 shuttered laboratories and disrupted normal NIH operations worldwide, NIH still managed to post over 650 NOFOs. The 120 posted in 2025 is the lowest annual total in the entire 14-year record. This is not streamlining. This is a near-total halt.

And the picture worsens when you account for the new “forecasting” system. Under NIH’s new policy, ICOs must first post a forecast (a simple notice of an anticipated future NOFO), before being permitted to publish the actual funding opportunity. Across all ICOs in 2025, 271 opportunities were forecasted but only 120 were ever posted. Nearly seven out of ten forecasted opportunities never made it to the posting phase.

These are not opportunities being carefully considered. I have come to call this the “forecast graveyard.” It is a pipeline that generates false hope for researchers and then quietly buries it. This system introduces a whole new burden on investigators who read forecasted NOFOs that will never come forward. When seven out of ten forecasts never become actual funding opportunities, generating them is largely an exercise in false advertising.

Claim #1: “This Does Not Mean Fewer Funded Applications”

“Although there are fewer funding opportunities, this does not mean fewer funded applications.” — Dr. Jon Lorsch

This is the most consequential claim in the blog, and it is directly contradicted by NIH’s own published data. According to NIH’s own reporting, in FY 2024 NIH awarded 7,720 R01-equivalent awards. In FY 2025, that number fell to 5,885, a decline of more than 20%, despite a nearly flat NIH budget. The link to this data is on NIH’s own website.

Furthermore, according to a recent Association of American Universities report, NIH issued 66% fewer grant awards in FY26 through the end of February compared to the average for the same period in FY21–24. These are not small measurement artifacts. These are catastrophic drops in the actual funding of science, and the opposite of what Dr. Lorsch promises.

It is important to note that the drop in numbers of grant awards did not result from the drop in NOFOs. Rather, as a recent article in Science notes, the switch to a multi-year funding strategy was likely the primary cause. The cause matters less than the consequence. Dr. Lorsch assures the research community that fewer NOFOs would not mean fewer funded applications. The data show that funded applications fell sharply, whatever the reason. NIH is actually funding far fewer awards now, and it appears likely that this trend will continue. Telling the research community that fewer NOFOs will not mean fewer funded applications, while the agency’s own numbers show a 20% drop in R01 awards within a single year, is not a defensible position. It is gaslighting.

Claim #2: Targeted NOFOs Limit Investigator Flexibility

“Their narrow scope can sometimes limit flexibility for investigators to propose novel or unexpected ideas.” — Dr. Jon Lorsch

This is the foundational premise of Dr. Lorsch’s entire argument, and it collapses under the weight of NIH’s own historical data. NIH has tracked, for decades, the proportion of funded research that comes from investigator-initiated versus targeted NOFOs. The NIH Data Book charts show clearly and consistently that broad parent mechanisms — the very investigator-initiated grants Dr. Lorsch says he wants to protect — have always dominated the NIH funding portfolio. Targeted NOFOs have never crowded out investigator-initiated science. This is not a problem that exists.

Dr. Lorsch acknowledges as much, writing that “broad funding opportunities like parent announcements have supported a large share of NIH-funded research for many decades.” If investigator-initiated research has always been the dominant mode, what exactly is the problem being solved?

Here are some representative charts from the NIH Data Book:

In 22 years at the NIH, I do not recall a single instance in which the extramural research community complained that too many NOFOs were forcing them to constrain their scientific ideas. Scientists were always welcomed and encouraged to submit their best ideas through parent mechanisms. Most did. The data confirm it. Dr. Lorsch provides no survey, no listening session summary, no Request for Information, and no documented complaint from the research community to back up his claim that NOFO proliferation was limiting scientific innovation. The assertion is simply stated as fact, repeatedly, but repetition is not the same thing as evidence.

Innovation and discovery are not impeded by the existence of targeted NOFOs. Indeed, the vast majority of Nobel-winning NIH-funded research has been funded through unsolicited, investigator-initiated grant applications during times when more targeted NOFOs were issued at the same time. To date, the NIH has funded 174 Nobel laureates who collectively received or shared 104 Nobel Prizes for their groundbreaking work. All of that occurred during the same decades when NIH was issuing hundreds of targeted NOFOs each year.

Claim #3: Fewer NOFOs Reduce Administrative Burden on NIH Staff

“Streamlining the number of funding opportunities also reduces administrative complexity across NIH, allowing NIH program staff to focus more on scientific stewardship.” — Dr. Jon Lorsch

As someone who spent more than two decades as a NIH Program Officer, I can speak to this directly: the number of NOFOs is not what burdens program staff. Scientific stewardship — talking with investigators about their ideas, nurturing portfolios, identifying scientific gaps — is the job. It is what program officers were hired to do, and it is what they want to do. Having a robust portfolio of targeted NOFOs does not prevent that work. It enables it.

What does create genuine administrative burden and prevent scientific stewardship is something Dr. Lorsch does not mention at all: the ongoing requirement that program staff screen grant portfolios and applications for terms that may potentially be associated with misalignment with the agency’s new priorities’ such as DEI, mRNA research, vaccine hesitancy, and climate research. Program colleagues who remain at NIH describe spending countless hours defending grants in their portfolios, coaching applicants about which words to avoid, and navigating an ever-changing list of politically sensitive topics. This is what diminishes innovation. This is what limits investigator flexibility. This is what keeps program staff from focusing on scientific stewardship.

In 2025, NIH terminated thousands of grants worth billions of dollars. HHS grant terminations impacted more than 74,000 clinical trial participants in the name of eliminating DEI. Even after a federal judge determined that DEI screening of NIH grants was illegal, the practice continues. If Dr. Lorsch genuinely wants to free his program staff to focus on science, he should address that problem.

Claim #4: This Is About “Reducing Fragmentation”

“Moving toward the use of broader funding opportunities rather than highly specialized announcements reduces fragmentation in the funding landscape.” — Dr. Jon Lorsch

Dr. Lorsch never defines “fragmentation,” and this vagueness is telling. NIH has 27 Institutes, Centers, and Offices (ICOs), each with a distinct and congressionally mandated mission. The National Cancer Institute exists to fund cancer research. The National Institute on Alcohol Abuse and Alcoholism exists to fund alcohol research. The Fogarty International Center exists to fund global health research. When these ICOs issue targeted NOFOs that reflect their specific missions, that is not fragmentation. That is the system working as Congress intended.

What the new system actually does is centralize control. Under the previous policy, targeted NOFOs were approved by ICO directors and their affiliated advisory councils composed of scientific experts with deep domain knowledge making peer-reviewed judgments about scientific priorities. Under the new policy, every targeted NOFO must be approved by the NIH Office of the Director, HHS, and OMB — political appointees whose expertise is political, not scientific.

Funneling the research community toward fewer, broader parent mechanisms also makes the grant portfolio far easier to monitor and filter for political purposes. When every application arrives through the same parent announcement, screening for ideologically disfavored topics becomes straightforward. This may not be what Dr. Lorsch intends, but it is the structural consequence of the system he is describing.

The practical result of these new NOFO policies is visible in the data, and it is not evenly distributed.

Which ICOs Have Been Hit Hardest?

The data I compiled reveal that the collapse in NOFO activity is not evenly distributed. Using the average of 2012 – 2024 as the pre-policy baseline, here is what some of the hardest-hit ICOs experienced in 2025:

• NICHD (child and maternal health): posted just one NOFO in all of 2025. Its 14-year average was 41.7 per year, making the decline approximately 98%. Thirteen forecasted NOFOs sit in the graveyard.

• NINDS (neurological disorders): posted 3 NOFOs in 2025 against a 14-year average of 49. That is a 94% decline. What makes the NINDS story particularly striking is the trajectory: the institute had been accelerating its activity for years, reaching what turned out to be its all-time peak of 80 NOFOs in 2024 and then collapsed 94% the very next year. Sixteen forecasted NOFOs remain unposted.

• NCI (cancer): NIH’s highest-volume institute by any measure. Over the full 14-year record it averaged 86 NOFOs per year, and in the five years immediately before the policy it averaged more than 90. In 2025 it posted 4, a 95% decline. Twenty-four NCI forecasts are sitting in the graveyard, representing cancer research programs that were anticipated, announced to the community, and then quietly shelved.

• NIMH (mental health): averaged nearly 60 NOFOs per year over 14 years. It posted 4 in 2025, a 93% decline. Mental health research, an area of enormous and well-documented unmet need, has been reduced to a trickle.

• NIAAA (alcohol research): issued zero NOFOs in 2025 despite having 9 in the forecast system. Its 14-year average was 21 per year, with annual totals ranging from 10 to 44. NIAAA has never had a zero-posting year in the entire 14-year record. Nine forecasted opportunities were announced to the alcohol research community and then never materialized.

• NIEHS (environmental health): posted zero NOFOs in 2025, despite 6 forecasted. Its 14-year average was 14 per year, and like NIAAA it has never previously had a zero-posting year. Calls for targeted research on environmental contributions to disease, including cancer, reproductive harm, and neurological conditions, simply stopped.

The mandate, as I understood it from NIH leadership before I left, was a 50% reduction in the number of NOFOs issued each year. What the 14-year data show is an 83% reduction system-wide, with most individual ICOs experiencing declines of 90% or more.

What Targeted NOFOs Actually Do — And Why Losing Them Matters

Dr. Lorsch’s blog does not spend any time describing what targeted NOFOs actually accomplish. It should. As I explained in my last essay, a NOFO is how NIH tells researchers what the agency needs. It specifies a research problem or a training need, explains why it matters, describes the approach NIH is looking for, and sets aside dedicated funding to solve it. Critically, NOFOs typically focus on problems that are not being addressed by unsolicited investigator-initiated applications. Targeted NOFOs exist precisely to address the gaps that broad parent mechanisms do not fill. When you eliminate targeted NOFOs, you eliminate the funding signal for exactly those areas of science that would otherwise be overlooked.

Moreover, some of the most consequential scientific programs in NIH’s history were built on targeted NOFOs: the Human Genome Project, the BRAIN Initiative, the All of Us Research Program, the Cancer Moonshot, the IDeA program that builds research capacity in historically underfunded states. None of these emerged from investigators independently deciding to pursue them through parent mechanisms. They emerged because NIH identified a strategic priority and issued a targeted funding opportunity to pursue it. To suggest that targeted NOFOs limit innovation is to misunderstand how some of the most innovative federally funded science of the past three decades actually got done.

Many of these programs are also mandated by Congress. The IDeA program, for example, exists because Congress determined that states with historically low NIH funding deserved targeted investment to build research infrastructure. When NIH stops issuing NOFOs for congressionally mandated programs, it is not just making a policy choice. It may be failing to fulfill a legal obligation.

A Personal Example: What a Targeted NOFO Can Accomplish

By 2016, I had recognized that behavioral and social science doctoral training was falling dangerously behind the rapid growth of big data and computational methods. University programs across the country were not preparing graduate students to handle the health data of the future. No investigator was going to solve this problem by submitting a parent mechanism training grant application. It required a strategic, coordinated response from NIH.

I spent years developing a concept, pitching it across institutes, gathering feedback, drafting budget scenarios, and building the case for action. I persuaded OBSSR leadership to commit $2 million per year over five years. I recruited 11 NIH institutes as co-signers. And in 2019, we issued a targeted NOFO (RFA-OD-19-011) to launch the first national data science training program for behavioral and social science graduate students in the country.

The first eight programs were funded in 2020. The RFA was reissued in 2024. Over 100 scholars have now been trained, significantly expanding U.S. behavioral data science capacity in ways that will pay scientific dividends for decades.

That program did not happen because an investigator independently decided to propose it. It happened because a program officer identified a gap, built a coalition, and issued a targeted NOFO. Under the new system Dr. Lorsch is describing, that process would require approval from NIH/OD, HHS, and OMB before a single word of the funding opportunity could be published. Given what we know about how many forecasted NOFOs actually make it to posting (fewer than one in three in 2025), there is a reasonable chance that program would never have existed.

Conclusion

Dr. Lorsch’s blog is well-written, but it is not well-supported. The central claims are each contradicted by available data: that targeted NOFOs limit investigator flexibility, that fewer NOFOs will not mean fewer funded awards, that this is about reducing administrative complexity. The NIH’s own published numbers show a collapse in NOFO activity that dwarfs the mandated 50% reduction, a parallel collapse in R01 awards, and a forecast system in which the majority of anticipated opportunities are never published.

The blog presents none of this data. It makes no reference to the administrative burden created by DEI screening of grants, which is the actual burden consuming program staff time. It offers no analysis to support the claim that investigators felt constrained by targeted NOFOs, because no such analysis exists. It makes no distinction between the policy as stated (50% reduction) and the policy as implemented (83% reduction).

The research community deserves an honest accounting of what is happening. This is not a simplification of the funding landscape. It is a contraction of it, and one that is falling most heavily on the ICOs and research areas that serve the most vulnerable populations, including children’s health, mental health, alcohol and substance use, cancer, environmental health, and neurological disease.

Fewer NOFOs means fewer signals to the research community about what NIH needs. It means fewer protections for understudied areas that cannot compete through open parent mechanisms. It means a transfer of authority away from scientific experts and toward political appointees. And, as the data now confirm, it means fewer funded awards.

That is not a simpler funding opportunity landscape. That is a diminished one.

This essay is part of an ongoing series reflecting on what I learned over more than two decades working inside the U.S. biomedical research enterprise. Each piece stands alone, but together they examine how science is shaped not only by ideas and funding, but by the structures that support or constrain them.

Sources

National Institutes of Health, Office of Extramural Research. (2026, February 10). NIH support for early-stage investigators in FYs 2024 and 2025. NIH Extramural Nexus. https://grants.nih.gov/news-events/nih-extramural-nexus-news/2026/02/nih-support-for-early-stage-investigators-in-fys-2024-and-2025

Agarwal, K. (2026, March 20). Data show dramatic slowdown in NIH grantmaking. Association of American Universities. https://www.aau.edu/newsroom/leading-research-universities-report/data-show-dramatic-slowdown-nih-grantmaking

Kaiser, J. (2026, February 20). NIH research grant funding rates plummeted in 2025. Science. https://www.science.org/content/article/nih-research-grant-success-rates-plummeted-2025

Patel, V. R., Liu, M., & Jena, A. B. (2026). Clinical trials affected by research grant terminations at the National Institutes of Health. JAMA Internal Medicine, 186(1), 126–128. https://doi.org/10.1001/jamainternmed.2025.6088

National Institutes of Health. (n.d.-a). Research project success rates [Report 25]. NIH Data Book. https://report.nih.gov/nihdatabook/report/25

National Institutes of Health. (n.d.-b). Research project grant (RPG) awards by NIH Institute/Center and mechanism [Report 26]. NIH Data Book. https://report.nih.gov/nihdatabook/report/26

Wilcox, C., Richter, H., Voosen, P., & Kaiser, J. (2025, December 12). Do you wanna build an ice dome? We could live in there on Mars. ScienceAdviser [Newsletter]. Science. https://www.science.org/content/article/scienceadviser-do-you-wanna-build-ice-dome-we-could-live-there-mars#nih-grant

National Institutes of Health. (2025, December 12). Staff guidance: Reviewing grants for priority alignment [Internal document obtained by Science]. https://www.science.org/pb-assets/PDF/News%20PDFs/final_staff_guidance-1765918233.pdf

Ginexi, E. (2026, March 17). Why is the NIH abandoning science? This is not a temporary slowdown. The Chronicle of Higher Education. https://www.chronicle.com/article/why-is-the-nih-abandoning-science

NOFO data was compiled by the author from NIH Guide for Grants and Contracts historical archives and grants.gov records. Analysis covers all funding announcements published from 2012 through March 24, 2026.