Comment on OMB-2026-0034-0001

The American Society of Tropical Medicine and Hygiene (ASTMH) supports transparency, accountability, research integrity, and responsible stewardship of federal funds. However, the proposed rule would create significant burdens for biomedical and public health research, weaken scientific collaboration, and undermine U.S. health security and global health research efforts. Please see the attached comment letter for ASTMH’s full comments. ASTMH is particularly concerned by provisions that would discourage international research collaborations. Infectious diseases, antimicrobial resistance, vector-borne diseases, and emerging epidemic threats do not respect national borders. Research on malaria, dengue, emerging zoonotic diseases, and other global health threats often must be conducted where diseases occur. International partnerships are essential to disease surveillance, outbreak response, the development of diagnostics, vaccines, and treatments, and the protection of Americans from health threats originating abroad. U.S.-led collaborations also promote high standards of scientific rigor, ethics, biosafety, transparency, and accountability worldwide. ASTMH urges OMB to preserve independent, expert-driven peer review as the primary basis for scientific funding decisions. Requiring political review of individual awards risks politicizing science, creating uncertainty, and discouraging innovative and collaborative research. ASTMH is also concerned that vague provisions related to research risk assessments, health disparities, and foreign collaborations could chill legitimate scientific inquiry, public health research, and international partnerships that advance U.S. interests. ASTMH strongly opposes broad new authorities that allow the suspension or termination of awards based on shifting agency priorities or undefined national-interest considerations. Research often involves long-term commitments to personnel, laboratories, field sites, international partners, and study participants. Abrupt termination can waste taxpayer investments, disrupt clinical studies, compromise data integrity, harm trainees, and undermine public trust. It can also raise serious ethical concerns by disrupting participant monitoring and follow-up, jeopardizing obligations to human research participants, and compromising responsible study closeout. The Society further opposes restrictions that would make publication costs unallowable or create new barriers to scientific conferences. Publication and scientific meetings are core mechanisms for validating, disseminating, and translating federally funded research into clinical practice and public health action. ASTMH recommends that OMB substantially revise the proposed rule to preserve international scientific collaboration, independent peer review, lawful public health and disparities research, scientific dissemination, and stable long-term research funding. The Society also urges OMB to narrow restrictions on foreign collaboration, provide appropriate procedural protections before award termination, and ensure that regulatory changes do not impede outbreak response, surveillance, clinical research, or preparedness activities. As written, the proposal would weaken the research enterprise that helps protect Americans from infectious disease threats and would diminish U.S. scientific leadership, public health preparedness, and global health security.