Comment on OMB-2026-0034-0001

On behalf of the members of the Materials Research Society (MRS) and the broader United States innovation enterprise, we write today to submit our comments in response to OMB-2026-0034-0001, Regulation for Federal Financial Assistance issued by the Office of Management and Budget on May 29, 2026. As you seek to ensure United States global leadership in research and innovation, MRS would like to express several concerns with the aforementioned proposed regulation that may, rather than advance United States innovation leadership, result in significant hinderance of United States leadership by placing federal grantmaking decisions in the hands of political appointees and by restricting the exchange of knowledge that advances the innovations driving economic development and competitiveness. Specifically, the proposed rule would require the review of all federal research grants by political appointees to ensure alignment with Administration priorities, directing agencies to reject and terminate awards deemed to be inconsistent with administration policy goals. The proposed rule would also reduce independent peer review, which is critical to ensuring the integrity of research that is needed to advance knowledge and innovation. Additional points of concern with the proposed Office of Management and Budget rule include: •The rule proposes sweeping and far-reaching changes to the grantmaking process across the federal government. In particular, the proposal amends 91 parts of Title 2 of the Code of Federal Regulations, including substantial overhauls to many sections of the Code. If enacted, government and institution administrative costs will greatly increase and much of the United States research enterprise will be slowed, or even worse, stagnated. The timing of this proposed change comes as China has already eclipsed the United States in overall investment of research and development (R&D ) , and China also is now the global leader in 66 of 74 critical technologies – from advanced materials and quantum physics to robotics, biotechnology and artificial intelligence. •The rule would effectively eliminate a major safeguard that ensures the credibility of United States research and innovation, stating that peer review recommendations “remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding.” If implemented, independent expert review for scientific merit could be overridden by a political appointee. Peer review helps ensure that the most cutting-edge science to keep the United States as a global innovation leader is selected and funded. Without qualified scientific and technical expertise as a critical basis for the funding selection process, bias and political favoritism can seep into decision-making process undermining and diluting United States scientific excellence. (§200.205(d)) •The rule calls for grants to be reviewed against a “Gold Standard Science” concept from Executive Order 14303 (May 23, 2025). This standard, however, has neither been defined nor documented, leaving broad discretion to political appointees charged with overseeing the process. (§200.205) •The rule limits and, in some cases, prohibits the exchange of information and active collaborations that are fundamentally necessary to advance research, knowledge and innovation. If enacted, these restrictions would adversely affect United States global competitiveness. (§200.220, §200.432, §200.461) We thank you for the opportunity to submit our comments regarding the proposed Regulation for Federal Financial Assistance. We believe that we have the same shared goal of ensuring continued United States global leadership in scientific research and innovation. As our comments indicate, we have several serious concerns with the proposed regulation, and as we also point out in our comments, the timing of the proposed regulations comes at a challenging time – China has already eclipsed the United States as the number one global funder of Research and Development, and, moreover, is now the global leader in the vast majority of critical technologies. In conclusion, we believe that the proposed Regulation for Federal Financial Assistance should be revised to energize the United States scientific grantmaking enterprise, sharpen its focus and inject increased federal funding so that the United States can re-claim preeminence in global research and innovation. Respectfully submitted.