Freedom Fuels Discovery
Three recent developments to be aware of as we approach the July 13 deadline to submit comments on the Office of Management and Budget’s (OMB) proposed Regulation for Federal Financial Assistance:
- We have learned that Heritage Action is urging comments in support of the proposed rule, in part by cherry-picking a few provisions and framing them in a hyperbolic manner. It’s not an unusual strategy, but it is a disappointing one given that this rule will harm patients. We are all patients, and this rule would, in demonstrable ways, slow the research behind medical progress.
- NSF issued a request for comments on proposed guidance that would, among other things, explicitly seek to conform its grant guidance with the proposed OMB rule. It is unusual for an agency to seek to conform the agency’s guidance to what is supposed to be a first draft of a new regulation.
- The OMB director testified at the Financial Services and General Government Subcommittee of the House Appropriations Committee and was asked if OMB envisions that an AI system would analyze whether grant proposals conform with administration priorities. The essence of his answer was, “Yes.” He did say that the system he envisioned would work as an adjunct to human judgment.
These three developments all speak to the same imperative: keep the advocacy going. Submit comments that ensure OMB is hearing about the many aspects of this rule that threaten progress, jobs, and U.S. economic competitiveness. (Remember that there is no prohibition on making supplemental comments if you have already made one and you have additional thoughts.) Individuals and organizations have submitted more than 143,650 comments on this proposed rule as of today. To help you speak up, Research!America has developed this comprehensive resource page, which provides tools you can use to craft your own effective comments and submit them. Use this action alert to raise awareness with your representatives in Congress. Take action. Make noise.
Russ’s Corner
As the U.S. prepares to celebrate our 250th birthday this weekend, it’s worth thinking about the nation’s standing as a research power. Over the course of our history, American curiosity and ingenuity built a research and innovation ecosystem that became the leader of the world. But will we continue to lead in the future?
Our future as a leader in science and technology (S&T) is not a foregone conclusion. While other countries are ramping up their capacity, attacks on the scientific enterprise are tearing ours down.
The proposed rule from OMB is a case in point. Among many provisions that would destabilize, slow, and shrink the current S&T pipeline, the proposed rule would require federal agency heads to assign political appointees – regardless of whether they are scientists or even took a science class in college – to conduct pre-issuance reviews of all discretionary awards and treat peer review recommendations as no more than advisory. Further, the proposal stipulates that scientific peer review recommendations must not be “routinely deferred to.”
Beyond these political appointees becoming bottlenecks as thousands of complex proposals funnel through them, this proposal would disrupt progress as new appointees come in with new priorities – or different interpretations of the same priorities – and potential research that would have been a logical follow-on project is judged as out-of-favor.
But fundamentally, this proposed regulation misses the point of federal grants in the first place: not one word of OMB’s three primary objectives of the proposed rule is about improving the lives of Americans, of improving America’s economy, or of improving the scientific engine that has been driving American progress for generations now.
Proposed federal regulations should aim higher than giving more power to political appointees. And they should be judged as failures if the likely outcome is an America that is weaker on the global stage.
The American public wants the U.S. to lead the world in medical research, science, and technology. According to a national survey we commissioned earlier this year, 91% of Americans say it’s important that the U.S. is a global leader in research to improve health. And 92% think it’s important that the U.S. is a global leader in science and technology.Americans have spoken, and now it’s time for our policymakers to listen and act accordingly by withdrawing this rule. It’s not too late to celebrate our independence by setting our sights on a healthier, more secure future for everyone.
Russ
Advocate Spotlight: The National Association of Veterans’ Research and Education Foundations (NAVREF) announced that leading veteran organizations are also expressing their concerns about the proposed rule. Together with NAVREF, these organizations warn that the proposed OMB rule would disrupt important scientific studies and slow research to the point of taking away hope from veterans, patients, and their loved ones. Considering referencing or sharing NAVREF’s release when meeting with your members of Congress about this topic.
Alliance Member-only Drop-in Hour: Join us on Wednesday, July 8, from 2-3 p.m. ET for a drop-in hour focused on drafting and submitting public comments on OMB’s proposed rule. Research!America staff will be available to answer questions, provide feedback, and help you navigate the comment process. You’re also welcome to stop by to discuss other research policy-related questions or just say hello! If you are affiliated with a Research!America member organization, please email Jacqueline Lagoy for the Zoom registration link.
Nominate an Advocacy Champion: Now, more than ever, we need to celebrate those who are championing medical research and innovation in America. Who will be among the next Research!America Advocacy Award honorees? Our Advocacy Awards recognize individuals and organizations whose commitment to advocacy for research and innovation has advanced medical, public health, and scientific progress in profoundly important ways. Take a look at the award descriptions and submit your nominations now. The process is easy and the deadline is Friday, July 17.
Support Our Advocacy Work: Your support is critical to our advocacy efforts. Research!America is working every day to ensure our nation’s discovery, development, and innovation ecosystem not only survives, but thrives. Working together, we can make medical research and public health, as well as overall science and technology progress, a higher national priority. Donate now.