Comment on OMB-2026-0034-0001

We are members of the City University of New York Alliance to Defend Higher Education (CADHE), comprising faculty from a variety of fields and disciplines across CUNY’s 26 campuses. As librarians, mathematicians, scientists, humanists, social scientists, and educators, we are writing to comment on the Office of Management and Budget (OMB)’s plan to radically change the procedures for awarding grants from the National Science Foundation (NSF) and National Institutes of Health (NIH). We strenuously oppose these changes, which will shift decision-making power from peer reviewers to political appointees (§200.205), and grant awards based on the policies and priorities of the federal administration (§200.202). Our objections are both political and scholarly: A cardinal value of academic publication is that scholars follow where the research takes them. Whether or not we like the evidence we find through archival and textual study, experimentation, theoretical analysis, or field work, we are bound by our findings. To impose political or ideological limitations on scholarly research is anathema to the very project of intellectual inquiry. Administrative priorities cannot control what we research or predict what that research reveals. Peer review is the gold standard of all reputable scholarly production. All of us have served as peer reviewers of journal articles, scholarly manuscripts, and tenure/promotion files, and our own work has undergone the same rigorous review. External reviewers are selected with great care and attention both to their expertise and to avoid conflicts of interest. We cannot imagine how a political appointee could possibly have mastered the same levels of knowledge and experience in a field to make an informed decision about any given proposal. The prohibition of studies of disparate racial, gendered, or other impact on environmental and/or social conditions, and of any research that focuses on marginalized populations at its (§200.300 and §200.218) has no scientific or intellectual basis. Studies on heart attack symptoms in women revealed that the warning signs differ significantly by gender. Research on unconscious bias towards female or minority job applicants has led to major policy changes internationally. These new regulations do not just reflect misguided political priorities: they risk the health of both our economy and millions of US citizens. The new regulations leave space for governmental actors to exclude all applications based on the researchers’ institutional affiliations . This provision is astonishing on its face and clearly has nothing to do with the qualifications of the applicant or the merits of the project. Rather, it can only be a way to hold research funds hostage until any given institution conforms to political dictates. This is nothing short of ideological extortion. Our final concern is reputational. Higher education in the United States has already suffered multiple blows through ideological attacks from both state and federal governments that have prohibited, defunded, or severely constrained entire fields of study, from climate science to gender studies. And scholars around the world are taking notice. Our national reputation as an engine of innovation across multiple fields, as a magnet for scholars on the cutting edge of their disciplines, as an incubator for the production of new knowledge, has suffered significantly. Moreover, the prohibition of international collaboration (§200.220) threatens ongoing projects with massive implications: With the limitations the OMB proposes, the US will no longer be seen as (or, indeed, even be) a center of scientific exploration and discovery. The slow trickle of elite scholars out of the country will turn into a steady stream. And the scientific and engineering inventiveness that has characterized American academia will contract for more than a generation. The current federal administration has claimed to oppose the politicization of academia. These proposed changes give the lie to that claim, and reveal that the opposition has only been to scientific and political research that runs afoul of a specific ideology. If these procedures are approved, the NIH and NSF will be reduced to political mouthpieces rather than the objective arbiters of scholarly value they should be. Sincerely, Cristina Bruns, LaGuardia Community College Sarah E. Chinn, Hunter College Jonathan Cornick, Queensborough Community College Beth Evans, Brooklyn College Paul Fess, LaGuardia Community College Jean Halley, College of Staten Island Ernest Ialongo, Hostos Community College Karen Kaplowitz, John Jay College of Criminal Justice Joel Kuszai, Queensborough Community College Mojubaolu Olufunke Okome, Brooklyn College Philip A. Pecorino, Queensborough Community College Larissa Swedell, Queens College Emily Sohmer Tai, Queensborough Community College Karen Weingarten, Queens College