AcademyHealth has been tracking the Office of Management and Budget (OMB) proposed rule that would fundamentally change how the federal government awards and manages grants since it was published on May 29. We’ve urged our community to act here and analyzed what the rule would do here. Today, AcademyHealth submitted our official comment where we highlight that this rule would fundamentally devastate the ability of the United States to have a credible scientific and health research enterprise, and call for it to be withdrawn in its entirety.
What the Rule Would Do
The proposed rule would impose a new pre-issuance review process requiring approval from senior political appointees to ensure grant proposals align with the President’s policy priorities, thereby reducing peer review to a merely advisory function. Peer review is a critical, long-standing process that safeguards scientific rigor and merit to ensure the right questions are being asked, and the right methods are being used. Replacing peer review with political review undermines the credibility and integrity of research.
Additionally, the grant proposal must meet “Gold Standard Science,” which are ill-defined, ambiguous, and subjective standards set by the Executive Order. The questions asked, the methods used, the findings reported may all be subjected to political determination. The proposed rule would expand risk factors agencies must consider, including an applicant’s professional or extracurricular affiliation, when evaluating applicant risk. The ambiguity and lack of specific criteria make compliance difficult and may infringe upon the grantee’s constitutional right to freedom of association.
Under this proposed rule, federal grants may not be used to promote or support disparate-impact liability, including funding disparate-impact studies. This provision could prevent researchers from conducting demographic analysis to examine health disparities across racial and ethnic groups. Equity-driven, health disparities-focused research could be restricted or suspended under this provision. Major NIH initiatives such as All of Us, which collect demographic data to study how treatments differ across patient backgrounds, could have been prevented based on the prohibitions of disparate research. Patient safety research funded by AHRQ that examines disproportionate impacts across populations could have been prohibited under this provision.
The proposed rule would prohibit the use of federal awards on DEI or gender ideology policies or practices. A researcher could no longer use federal funding to examine racial and ethnic disparities in health outcomes. Studies exploring suicide prevention among Black youth or why Black individuals experience HIV diagnosis rates eight times higher than White individuals could have been rejected under this provision. Restricting research addressing health disparities does not make them go away; it exacerbates the health inequities in the U.S. Under the proposed rule, federal agencies would gain the authority to terminate or suspend active grants at any time and for any reason including political reasons. For discretionary terminations, federal agencies are not required to provide hearings, appeals, or detailed justifications for the termination. This provision could jeopardize multi-year, on-going research and undermine future scientific innovations.
Additionally, the proposed rule would prohibit the use of federal funds on grantees’ professional memberships, journal subscriptions, conference costs, and publication costs (e.g., page charges, article processing charges, open-access fees). These restrictions would limit researchers’ ability to communicate and disseminate their findings to the broader scientific community. Codifying these radical changes through the proposed rule would institutionalize harmful practices, with consequences for how research is translated, communicated, and made accessible to the general public. In addition, the rule would impose restrictions on foreign scientific collaborations with covered foreign countries. When diseases transcend borders, international research is inevitable. The proposed rule could hinder the development of rare disease treatment, which often relies on international collaboration, data sharing, and global clinical trials.
What We Said
AcademyHealth's comment called for immediate and complete withdrawal. The proposed rule is not final. The comment period is open through July 13, 2026. We urge our members, partner organizations, and the research community to submit a formal comment to protect and preserve America’s research infrastructure. If you are submitting your own comment or encouraging your institution to do so, here is the argument structure we used:
- Lead with the structural stakes.
- This rule is different from the executive actions of 2025, which were subject to reversal by courts or a future administration. This rule writes political control of science into federal regulation permanently. Frame it that way.
- Name the broken bargain.
- The federal research enterprise rests on a basic agreement: public money, publicly accountable methods, publicly available findings. Show specifically how the rule breaks each leg.
- Ground the harm in specific research.
- Name the studies that could not have been conducted under this rule. Name the populations that would lose visibility in the data. Abstract objections are easier to dismiss than concrete ones.
- Make the ask explicit.
- Call for complete withdrawal, not modification. Asking for targeted fixes signals the framework is acceptable. It is not.
Additional guidance on how to submit an effective comment can be found here.
Why This Matters Beyond the Research Community
The impact of this proposed rule is not merely theoretical. In short, this proposed rule would severely degrade the ability of the United States of America to support health and scientific innovation at any meaningful level and would destabilize research organizations and entities that taxpayers have supported and invested in for decades. Such research has driven billions of dollars in economic output, improved American health care, and established America as the world leader in innovation. This rule would corrupt every stage of the research enterprise: whom and what gets funded, what methods are permissible, whom researchers can work with, and how findings get disseminated. This proposed rule would subject researchers to coercion and censorship. Moreover, the rule does not adequately consider the significant consequences these radical changes could have not only on the research itself, but also on the downstream implications for policy, care delivery, and health outcomes broadly.