Comment on OMB-2026-0034-0001

UAW Local 4100 represents over 2500 postdoctoral researchers at Columbia University, Mount Sinai, and Weill Cornell Medical College. Our workers drive the day-to-day work of scientific discovery and depend on a research system built on stable funding, peer review, collaboration, and open exchange of knowledge. As a union representing early-career academic workers, we strongly oppose OMB–2026–0034. Scientific research is a long-term investment that produces substantial public benefits across many areas. Historically, federally funded research has contributed to advances in healthcare, environmental science, public health, and technology that improve quality of life, strengthen the economy, and address societal challenges. Stable and predictable funding is essential to ensure that research projects have the time and resources needed to deliver these benefits. However, the proposed rule change would allow grants to be cancelled at any time [Section 200.340-42], meaning that long-term investments in research may be lost before projects can produce meaningful outcomes for the public. Beyond funding stability, the process by which research priorities are determined is equally critical. Peer review is one of the fundamental pillars on which the strength and credibility of scientific research are built. By relying on experts to evaluate grant proposals based on scientific merit, peer review ensures that federal funding supports rigorous, innovative, and impactful research. The proposed rule change would allow political appointees to substitute or override peer-review recommendations [Section 200.205]. It would also give these appointees the ability to deny grant applications if an applicant is affiliated with undefined “anti-American activity” [Section 200.206]. This creates the risk that funding decisions will no longer be guided primarily by scientific expertise. As a result, research priorities could increasingly be shaped by political considerations rather than scientific merit, innovation, and potential public benefit. The proposed changes would severely limit scientists’ ability to share their research by restricting the use of grant funds for publishing results [Section 200.461], attending scientific conferences [Section 200.432], and maintaining professional memberships [Section 200.454]. They would also create significant barriers to international collaborations [Section 200.202(e); Section 200.220], which are essential to modern scientific progress. Science is a collective enterprise that depends on the open exchange of knowledge, with each discovery building on previous work. The ability to share expertise, data, and resources—including across borders—has shaped modern science and accelerated discovery. Restricting scientific communication would slow the translation of research into public benefits, undermine transparency and reproducibility, hinder the training and career development of early-career researchers, increase duplication of effort, and ultimately reduce the return on federally funded research investments. Limiting international collaborations would further isolate U.S. scientists, slow innovation, and weaken the nation’s ability to address global challenges through scientific discovery. In addition to limiting communication within the scientific community, the proposed rule would also restrict researchers’ ability to communicate their findings to the public [Section 200.450]. Restricting public communication limits access to research that the public has already invested in, reducing transparency, accountability, and the return on taxpayer investment. These changes seek to undermine scientific research by shifting decision-making power from experts to political appointees. It creates a system of political control over what research gets funded, who receives support, and which questions are allowed to be pursued. These changes threaten to dismantle a scientific enterprise built on peer review, open competition, transparency, international collaboration, and the freedom of researchers to pursue knowledge wherever the evidence leads. Undermining these principles would weaken U.S. science, reduce innovation, and risk driving talented researchers away from the scientific workforce.