Comment from Rita Hamad

I am a Professor at the Harvard School of Public Health and Director of the Harvard Center for Population and Development Studies. My own work, and that of my Center, is devoted to improving population well-being by studying structural, population-level, and societal factors that affect health. As a public health researcher and academic, I am submitting this comment to oppose OMB’s proposed rule, OMB-2026-0034, Office of Management and Budget Regulation for Federal Financial Assistance, which would cause serious harm to scientific research broadly and to work like mine in particular. I urge the agency in the strongest possible terms to withdraw this proposal. If adopted, this rule would radically alter the federal grantmaking process by injecting partisan considerations, financial volatility, and limits on lawful policy-related activities into a system that has historically supported evidence-based work. The proposal would affect the critical funding that agencies such as the Department of Health and Human Services, Centers for Disease Control and Prevention, National Institutes of Health, Environmental Protection Agency, Department of Agriculture, and others provide to state and local governments, community organizations, and scientists. These funds are essential for sustaining evidence-based public health programs, medical and scientific research, safe housing, nutrition supports, education, environmental protections, and other initiatives that protect and enhance health in communities nationwide. Several aspects of the proposed rule are particularly problematic: •The rule would enable political appointees at federal agencies—rather than independent peer reviewers, scientists, and policy experts—to make grant decisions, allowing ideology to override rigorous scientific evidence. Under this approach, grant applications could be turned down if a political appointee deems the work inconsistent with “federal agency priorities and the national interest.” Equally worrisome, agencies could weigh a grantee’s membership in or affiliation with organizations that hold legitimate policy positions the administration simply dislikes. For research like mine, which evaluates how policies influence health, the political preferences of the administration in power could determine whether my work is funded, even when it is entirely scientifically sound and warranted. For research more broadly, this would introduce profound instability, as funding could be curtailed or denied whenever political leadership changes. •The proposal would substantially weaken protections for current grantees by authorizing the administration to cancel, suspend, or alter awards at any time—even when recipients are fully complying with the approved terms. This would expose grantees to heightened risks of mid-project disruption, cancellation, and financial loss, particularly for large, multi-year projects. For research in general, this would mean that funding could be withdrawn on extremely short notice with each government transition, creating chronic uncertainty. This instability will undermine staffing—because researchers and staff cannot rely on continued support—and will slow scientific progress, which depends on predictable and sustained funding streams. •The rule would further prohibit federal support for implementing programs related to diversity, equity, and inclusion, “gender ideology,” illegal immigration, or foreign collaboration, regardless of the quality or relevance of the supporting science. These provisions would have a deeply negative impact on public health and research by forbidding grantees from pursuing activities that political appointees deem inconsistent with the administration’s priorities, even when those activities are scientifically rigorous and necessary for informing policy design and cost-effectiveness analyses. •The rule would also add new restrictions on using grant funds to attend conferences, join professional societies, subscribe to journals, or publish in peer-reviewed outlets without explicit prior approval from the funding agency. These constraints would micromanage researchers’ ability to collaborate and disseminate findings, hinder scientific exchange, and force agencies to spend time and resources reviewing routine line-item spending decisions, rather than focusing on the quality and impact of the science. Taken together, this proposal would have broad and damaging consequences for federal grants and grantees across all agencies, embedding political ideology and financial uncertainty into what should remain an independent and stable process. I respectfully but firmly urge you to withdraw the rule in its entirety.