Comment from Erika Hunt

My name is Dr. Erika Hunt, and I serve as Co-Director of the Center for the Study of Education Policy at Illinois State University. Throughout my career, I have directed multiple federally funded education grants and served as an external peer reviewer for five U.S. Department of Education discretionary grant competitions. My experience spans both administering federal grants and evaluating grant applications through the Department's independent peer review process. I urge the Office of Management and Budget to reconsider the proposed procedural changes that would increase the authority of political appointees over federal financial assistance awards and expand agencies' ability to suspend or terminate funding. As a federal peer reviewer, I participated in a highly structured process designed to ensure that applications are evaluated independently and solely on their merits. Reviewers receive extensive training, adhere to detailed scoring rubrics established in the Notice Inviting Applications, disclose potential conflicts of interest, and independently evaluate proposals using clearly defined statutory and regulatory selection criteria. This process is intentionally designed to minimize bias and ensure that funding recommendations are based on evidence, quality, organizational capacity, and the likelihood of successful implementation - not political considerations. As the director of multiple federally funded grants, I have also experienced the process from the applicant's perspective. Whether my proposals were funded or not, I had confidence they were reviewed by independent experts with relevant subject-matter expertise using transparent, objective criteria. While no review process is perfect, the credibility of federal discretionary grant programs rests on confidence that funding decisions are informed by expert peer review rather than political influence. The proposed procedural changes that would expand the role of political appointees in award decisions risk undermining decades of work to establish a trusted, merit-based grant review system. Even the perception that funding decisions may be influenced by political priorities rather than published selection criteria could discourage highly qualified applicants, erode confidence in federal grant competitions, and diminish the effectiveness of federal investments in research, innovation, education, and public service. I am equally concerned about provisions that would make it easier for agencies to suspend or terminate awards. Federal grants support complex, multi-year initiatives that require recipients to hire personnel, establish partnerships, enter into contractual agreements, invest in infrastructure, and implement long-term improvement strategies. Abrupt suspension or termination of these awards can interrupt critical services, undermine years of planning and implementation, waste taxpayer investments, and prevent projects from achieving the outcomes for which federal funds were awarded. Immediate grant termination also creates significant financial hardships for recipients, many of whom have already made legally binding commitments based on approved federal awards. Organizations hire employees, execute contracts, procure equipment and services, and commit institutional resources with the reasonable expectation that the federal government will fulfill its funding obligations. When awards are terminated without sufficient procedural protections, institutions may be left responsible for unreimbursed personnel costs, contractual obligations, and other financial liabilities that cannot easily be absorbed. These impacts extend beyond the grantee organization to the educators, students, researchers, and communities the grants are intended to serve. Current federal regulations already provide agencies with robust mechanisms to address noncompliance through monitoring, performance reporting, financial oversight, corrective action, and audit requirements. These longstanding safeguards appropriately balance accountability with due process. Expanding discretionary authority to suspend or terminate awards without comparable procedural protections introduces unnecessary uncertainty into the federal financial assistance system and may discourage organizations from pursuing innovative solutions to national priorities. The strength of the federal grant system has long rested on its commitment to fairness, transparency, independent expert review, and evidence-based decision-making. I respectfully encourage OMB to preserve these principles by maintaining a strong, independent peer-review process, limiting political involvement in funding decisions, and ensuring that any suspension or termination of awards is supported by clear, objective standards and appropriate procedural safeguards. Thank you for your consideration of the importance of maintaining public confidence in the federal financial assistance process.