Comment from David Christiani

As a public health professional and advocate, I am writing in opposition to OMB's proposed rule, OMB-2026-0034, Office of Management and Budget Regulation for Federal Financial Assistance. I strongly urge the agency to withdraw this proposal. This troubling proposal threatens to upend the federal grant-making process by introducing political ideology, financial uncertainty and restrictions on lawful policy interventions into the process that provides critical grant funding from all federal agencies to state and local governments, community organizations and researchers and scientists among others. Agencies including 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 crucial funding that is essential to support evidence-based public health interventions, medical and scientific research, safe housing, nutrition assistance programs, education, environmental safeguards and other programs that improve the health of communities across the country. Some of the most concerning parts of this proposal include the following: •The proposal would allow political appointees at federal agencies, rather than independent peer reviewers, scientists and policy experts, to make grant award decisions based on political ideology rather than evidence-based public health, medical and environmental research (§200.205). Grant applicants could be denied based on whether a political appointee believes the proposal runs contrary to “federal agency priorities and the national interest.” Also troubling, the proposal would allow agencies to consider a grantee’s membership or affiliation with other organizations that have legitimate policy positions with which the administration may disagree. •The proposal would significantly undermine and would permit the administration to cancel, suspend, or modify grant awards at any time, even if the grantee is meeting the requirements of the approved award (§200.340). This proposed change increases recipients’ exposure to mid-project disruption or cancellation and financial risk, particularly for large multi-year awards. •The proposal would also block federal funding for implementing programs related to diversity, equity, and inclusion, “gender ideology,” (§200.300) or foreign collaboration (§200.454), regardless of the science and research that may support such programs and activities. These provisions will have a significant impact on public health and research by preventing grantees from engaging in any activities that political appointees determine are not in alignment with the administration’s priorities. Other troubling provisions within this proposal include the use of undefined terms such as "gold standard science", as well as restrictions on the use of grant funds to attend conferences, join professional societies, subscribe to journals, or publish in peer-reviewed journals, without express agency pre-approval. In my particular case, among the areas of biomedical science research in which I work, I conduct epidemiologic studies of human populations exposed to environmental and occupational hazards and estimate disease risk with a goal of prevention and harm reduction. I have had NIH and CDC funding for more than 4 decades. This proposal would have sweeping impacts on all federal agencies’ grants and grantees, inserting financial uncertainty and political ideology into a non-political process. I strongly urge you to withdraw the rule as proposed.