"Despite having lived life beyond reasonable limits, I made it to age 80 this year. The main reason is that America's amazing medical research endeavors were always just a little ahead of my needs. In gratitude, I dedicated a lot of my time and energy to the practice of medicine, and I like to think that I helped a lot more people than otherwise. Now I see, with mounting alarm, a proposal to put science under control of political hacks, this at a time when hackism seems to be spiraling out of all reason.
"Please don't fall for this nonsense! Our average lifespan has about doubled recently due entirely to the excellence of American medical science. Our researchers aren't perfect, but they seem to me to be way ahead of whatever comes next."
Thank you for forwarding the information for comment. I will complete the form.
I am an 80-year-old polio survivor who contracted polio at age 7 months. Every day of my life I live with the deleterious effects of poliovirus.
I am grateful for the scientific method applied in the development of the Salk inactivated poliovirus vaccine. Jonas Salk and Nobel Prize scientists, John Enders, Thomas Weller and Frederick Robbins, conducted rigorous lab and community trials of the vaccine before it was acclaimed safe April 12, 1955.
I cannot imagine a world where the Russian-government-funded Sabin vaccine would be our only option for vaccination against polio.
If the U.S. had chosen to vaccinate its children with the live virus Sabin vaccine, American children would be experiencing cases of vaccine-associated paralytic polio each year. To choose this outcome is unconscionable.
America wants the best medicine for children and their families. We cannot allow companies which may be bought by individuals with foreign entanglements and operations not aligned with U.S. established research rules, to override scientists like Salk, Enders, Weller and Robbins.
This is the movie Idiocracy come to life. As a physician of 40+ years I saw this kind of thinking in gradeschool. But then, it was rejected by the integrity of a strong education system. Now, those kids, sitting in the back of science class, throwing spit wads and making farting noises have been voters for 50+ years, and this is the result. Maybe they will wake up when their grandchildren start dying and becoming disabled from treatable and preventable diseases. If not, well, maybe they should have listened to the lessons on Darwin's Origin of Species.
I’m going to venture a guess that there are *already* mechanisms in place to halt studies in the event of fraud. And it’s a particularly galling justification given the rampant, open corruption coming from the same people fearmongering about fraud.
When the studies involve human subjects they can be terminated through several mechanisms. Ethical lapses although rare are much better addressed now (well before this administration) under the existing rules.
Can you please site the exact text which is allowing a study in progress to be unfunded?
I want to leave comment on the importance of publishing even NULL results to prevent the problems of "The Replication Crisis" which is to be countered by preregistering of studies. But I have no idea from where in the document your objections come.
You’re right the document is huge. Within the article I linked these two resources that can help you and give exact section numbers. Thank you so much for being willing to submit a comment!
(2) At the discretion of the Federal agency or pass-through entity.
The Federal agency or pass-through entity, to the extent permitted by law, may terminate a Federal award in part or its entirety if the Federal agency or pass-through entity determines that a termination is in the interest of the Federal agency or pass-through entity, including if a Federal award does not effectuate program goals, Federal agency priorities, or the national interest as they exist at the time of the termination. See also § 200.341;
I think this might be what you indicated might allow cancelation of ongoing research.
CAN YOU CONFIRM?
Is there another or more part of the proposal I might target for objection.
The nature of the objection I intend to make is that this could disrupt studies which should fall under preregistery agreements to publish on completion and further that all science that can be conducted under preregistry to publish agreements should be done so and only when done so.
I also did NOT submit anonymously as I hope at every opportunity to engage and explain the importance of preregtration..
************************************************
Regarding,
§ 200.340
Termination and suspension.
(a) Termination provisions. The Federal award may be terminated in part or its entirety as follows:
(1) For noncompliance by the recipient or subrecipient. The Federal agency or pass-through entity may terminate a Federal award in part or its entirety if the recipient or subrecipient fails to comply with the terms and conditions of the Federal award, including a failure of the recipient to report subawards on SAM.gov pursuant to the award term required by 2 CFR part 170. See also §§ 200.341 and 200.342;
(2) At the discretion of the Federal agency or pass-through entity. The Federal agency or pass-through entity, to the extent permitted by law, may terminate a Federal award in part or its entirety if the Federal agency or pass-through entity determines that a termination is in the interest of the Federal agency or pass-through entity, including if a Federal award does not effectuate program goals, Federal agency priorities, or the national interest as they exist at the time of the termination. See also § 200.341;
I object.
This is written with out consideration of how modern science should be conducted with respect to research and publication with all effort to minimize Replication Crisis like publication bias. I refere readers to the article here:
In particular to the section on Pre-registration of studies which I qutot here:
'Pre-registration of studies
Further information: Preregistration and Clinical trial registration
Scientific publishing has begun using pre-registration reports to address the replication crisis.[215][216] The registered report format requires authors to submit a description of the study methods and analyses prior to data collection. Once the method and analysis plan is vetted through peer-review, publication of the findings is provisionally guaranteed, based on whether the authors follow the proposed protocol. One goal of registered reports is to circumvent the publication bias toward significant findings that can lead to implementation of questionable research practices. Another is to encourage publication of studies with rigorous methods.
The journal Psychological Science has encouraged the preregistration of studies and the reporting of effect sizes and confidence intervals.[217] The editor in chief also noted that the editorial staff will be asking for replication of studies with surprising findings from examinations using small sample sizes before allowing the manuscripts to be published.'
**The nature of the objection I make is that proposed change this could disrupt studies which should fall under preregistery agreements to publish on completion and further that all science that can be conducted under preregistry to publish agreements should be done so and only when done so.**
I will be happy to explain my objection further at my provided contact information.
This article deepens an already alarming picture of research university funding cuts. Since COVID, medicine has become increasingly politicized. Would it move these politicians to know that vaccines and medical advances have saved millions and improved hundreds of millions of lives? I'm no medical expert — but I know that the cancer treatments, heart surgeries, and aortic replacements that have saved people I love didn't happen by accident. They were the product of exactly the research now being defunded. And would anything I write matter — or just trigger a form letter in return?
It’s easy to feel like nothing we do matters but we have seen things be reversed over the last year and a half if there is enough public outcry. So we have a chance. 💕
My first jobs out of public health school were grant-funded projects -- quality of care when it was new, algorithms in medical assessment when unheard of. And the peer review process was essential in tightening us up (and our reviewers were the best in the field). I know my work was life-changing for us all.
One of the things I teach every scientist is to know your audience. With this in mind I have worked with Claude Opus 4.7 to draft seven conservative responses to different parts of the proposed rule change. I have linked these here as a Google Doc. There are seven letters because there are many parts to this OMB rule, each of which deserves careful consideration.
The linked letters are DRAFTS, not final presentations. They are addressed to a congressperson, not as comments to OMB. I will reformat them as OMB comments later and will post a link here. You are free to use any of these letters, or parts of them, but PLEASE edit them for clarity and to put them in our writing style. As I am a retired Biology professor, I instructed Claude to take this into account in the draft letters. This means that the wording may not be appropriate for you. AIs are brilliant at preparing drafts, but if a congressperson thinks that they are getting an AI response they will likely ignore it. Please modify the letter you decide to use so that it comes from you, not an AI.
Remember, we are addressing conservatives. If we want to have an impact I believe that our criticisms must address conservative concerns. Fortunately, there is plenty in this OMB proposal that violates traditional conservative principles.
I also found that much of the proposal went against the Heritage Foundation documents that were cited to support it. The oft-cited "Ditch" held that Congress, not the Executive branch, had the responsibility of fixing the problems with policy over-reach in agencies.
Once significant research grinds to a halt here, the billionaires who have funded the ongoing destruction of America's scientific and educational leadership in pursuit of tax breaks for themselves will happily fly to China for advanced medical treatment, leaving the rest of us to die.
I did it! Here is my letter (BTW: you don't put your name, etc in the letter you write--you give them your name at the end when you click "I am an individual". Also, i attached my letter just to be sure it gets as much circulation as possible. And here it is)
Federal Financial Assistance Rule (OMB-2026-0034)
Regarding Published Document: 2026-10817 (91 FR 32198):
1. Peer-review is a fundamental need to advance science, and we do want to advance science. The peers are the best able people to critique, improve, comment on new science. Politically appointed directors are likely (as in 99.99% certain) to not be qualified to intelligently review and decide on proposals to advance science.
2. Research takes years of work, including previous works and projects as well as parallel research. To be able to cut funding suddenly in mid-stride will hurt the current research as well as crippling or killing adjacent and future research in the same vein. Certainly, occasion may arise when finds show that a line of thinking is wrong or that some individual is duping the system, but that would be rare. And the whole of our science world should not suffer for it.
3. Why the proposed restrictions on scientists speaking to each other and the public about their work and progress? Science is, by and large, a team sport. Unfettered communication (except in rare instances, is necessary to efficiently advance science.
In summation, this OMB suggestion for foundational changes to our science system is anti-science. It seems meant to cripple or kill science in general and specific areas of science in particular. These proposals are not responsible oversight; they are draconian measures meant to make science either slow or absent. My wife has greatly benefitted from the discoveries of the past few decades. She as peritoneal cancer, a subset of ovarian cancer. She is alive and doing well today (although not cured) because she has participated in multiple clinical trials---science in action. For 15 years! And she is currently on an approved medicine that is not a trial drug. And take a guess how that drug came to be accepted and approved. Through trials. And those trials came out of the labs of multiple scientists over many years. Years in which they had peer-review, and had sure funding despite some false starts, and in which they talked to each other freely at conferences. This is the system that I and you should hope will continue when we need it. Please withdraw this proposed rule, Federal Financial Assistance Rule (OMB-2026-0034).
My comments to OMB are too long and detailed to be posted here. You may view them at the following link. I have done my best, with the assistance of Claude 4.7, to write in a way that will force a response from OMB before the final rule is published. I list six areas of concern and document them with reference to the applicable regulatory documents.
You may use any of my text, but I ask that you rewrite the text in your own style.
Since all three branches of our current government are controlled by supplicants in the MAGA clone army, I don't see protest before hand as an effective effort.
Better still would be to keep your eyes and ears wide open to determine when and where the all but certain law suites will emerge from. Then dig deep into your already stretched thin pockets and contribute to the suite(s) or your choice.
This proposal by OMB was all outlined in P2025 that Trump lied about claiming he knew nothing of this. His administration is deeply penetrated by P2025 authors with the lead author being in charge of OMB.
What I wrote to the government:
"Despite having lived life beyond reasonable limits, I made it to age 80 this year. The main reason is that America's amazing medical research endeavors were always just a little ahead of my needs. In gratitude, I dedicated a lot of my time and energy to the practice of medicine, and I like to think that I helped a lot more people than otherwise. Now I see, with mounting alarm, a proposal to put science under control of political hacks, this at a time when hackism seems to be spiraling out of all reason.
"Please don't fall for this nonsense! Our average lifespan has about doubled recently due entirely to the excellence of American medical science. Our researchers aren't perfect, but they seem to me to be way ahead of whatever comes next."
Thank you for forwarding the information for comment. I will complete the form.
I am an 80-year-old polio survivor who contracted polio at age 7 months. Every day of my life I live with the deleterious effects of poliovirus.
I am grateful for the scientific method applied in the development of the Salk inactivated poliovirus vaccine. Jonas Salk and Nobel Prize scientists, John Enders, Thomas Weller and Frederick Robbins, conducted rigorous lab and community trials of the vaccine before it was acclaimed safe April 12, 1955.
I cannot imagine a world where the Russian-government-funded Sabin vaccine would be our only option for vaccination against polio.
If the U.S. had chosen to vaccinate its children with the live virus Sabin vaccine, American children would be experiencing cases of vaccine-associated paralytic polio each year. To choose this outcome is unconscionable.
America wants the best medicine for children and their families. We cannot allow companies which may be bought by individuals with foreign entanglements and operations not aligned with U.S. established research rules, to override scientists like Salk, Enders, Weller and Robbins.
This is the movie Idiocracy come to life. As a physician of 40+ years I saw this kind of thinking in gradeschool. But then, it was rejected by the integrity of a strong education system. Now, those kids, sitting in the back of science class, throwing spit wads and making farting noises have been voters for 50+ years, and this is the result. Maybe they will wake up when their grandchildren start dying and becoming disabled from treatable and preventable diseases. If not, well, maybe they should have listened to the lessons on Darwin's Origin of Species.
Sad but true
I’m going to venture a guess that there are *already* mechanisms in place to halt studies in the event of fraud. And it’s a particularly galling justification given the rampant, open corruption coming from the same people fearmongering about fraud.
Yes you’re right. Grants could be terminated for fraud prior to any of this!
When the studies involve human subjects they can be terminated through several mechanisms. Ethical lapses although rare are much better addressed now (well before this administration) under the existing rules.
The document is HUGE.
Can you please site the exact text which is allowing a study in progress to be unfunded?
I want to leave comment on the importance of publishing even NULL results to prevent the problems of "The Replication Crisis" which is to be countered by preregistering of studies. But I have no idea from where in the document your objections come.
You’re right the document is huge. Within the article I linked these two resources that can help you and give exact section numbers. Thank you so much for being willing to submit a comment!
https://elizabethginexi.substack.com/p/summary-of-key-changes-in-ombs-proposed?r=1z8cho&utm_medium=ios
https://elizabethginexi.substack.com/p/what-we-need-to-do-next-ombs-proposed?r=1z8cho&utm_medium=ios
Very helpful. I was wondering how an individual member of the public but in the medical field could comment. This answered that. Thank you.
You are welcome! Thank you for your time!
That is helpful.
I searched for "200.340" and found
(2) At the discretion of the Federal agency or pass-through entity.
The Federal agency or pass-through entity, to the extent permitted by law, may terminate a Federal award in part or its entirety if the Federal agency or pass-through entity determines that a termination is in the interest of the Federal agency or pass-through entity, including if a Federal award does not effectuate program goals, Federal agency priorities, or the national interest as they exist at the time of the termination. See also § 200.341;
I think this might be what you indicated might allow cancelation of ongoing research.
CAN YOU CONFIRM?
Is there another or more part of the proposal I might target for objection.
The nature of the objection I intend to make is that this could disrupt studies which should fall under preregistery agreements to publish on completion and further that all science that can be conducted under preregistry to publish agreements should be done so and only when done so.
Thanks.
See my actual submitted comment above.
I used Claude to distill this proposed rule and had all of my questions answered.
https://www.federalregister.gov/documents/2026/05/29/2026-10817/regulation-for-federal-financial-assistance
Below is the comment I left.
I also did NOT submit anonymously as I hope at every opportunity to engage and explain the importance of preregtration..
************************************************
Regarding,
§ 200.340
Termination and suspension.
(a) Termination provisions. The Federal award may be terminated in part or its entirety as follows:
(1) For noncompliance by the recipient or subrecipient. The Federal agency or pass-through entity may terminate a Federal award in part or its entirety if the recipient or subrecipient fails to comply with the terms and conditions of the Federal award, including a failure of the recipient to report subawards on SAM.gov pursuant to the award term required by 2 CFR part 170. See also §§ 200.341 and 200.342;
(2) At the discretion of the Federal agency or pass-through entity. The Federal agency or pass-through entity, to the extent permitted by law, may terminate a Federal award in part or its entirety if the Federal agency or pass-through entity determines that a termination is in the interest of the Federal agency or pass-through entity, including if a Federal award does not effectuate program goals, Federal agency priorities, or the national interest as they exist at the time of the termination. See also § 200.341;
I object.
This is written with out consideration of how modern science should be conducted with respect to research and publication with all effort to minimize Replication Crisis like publication bias. I refere readers to the article here:
https://en.wikipedia.org/wiki/Replication_crisis
In particular to the section on Pre-registration of studies which I qutot here:
'Pre-registration of studies
Further information: Preregistration and Clinical trial registration
Scientific publishing has begun using pre-registration reports to address the replication crisis.[215][216] The registered report format requires authors to submit a description of the study methods and analyses prior to data collection. Once the method and analysis plan is vetted through peer-review, publication of the findings is provisionally guaranteed, based on whether the authors follow the proposed protocol. One goal of registered reports is to circumvent the publication bias toward significant findings that can lead to implementation of questionable research practices. Another is to encourage publication of studies with rigorous methods.
The journal Psychological Science has encouraged the preregistration of studies and the reporting of effect sizes and confidence intervals.[217] The editor in chief also noted that the editorial staff will be asking for replication of studies with surprising findings from examinations using small sample sizes before allowing the manuscripts to be published.'
**The nature of the objection I make is that proposed change this could disrupt studies which should fall under preregistery agreements to publish on completion and further that all science that can be conducted under preregistry to publish agreements should be done so and only when done so.**
I will be happy to explain my objection further at my provided contact information.
This article deepens an already alarming picture of research university funding cuts. Since COVID, medicine has become increasingly politicized. Would it move these politicians to know that vaccines and medical advances have saved millions and improved hundreds of millions of lives? I'm no medical expert — but I know that the cancer treatments, heart surgeries, and aortic replacements that have saved people I love didn't happen by accident. They were the product of exactly the research now being defunded. And would anything I write matter — or just trigger a form letter in return?
It’s easy to feel like nothing we do matters but we have seen things be reversed over the last year and a half if there is enough public outcry. So we have a chance. 💕
My first jobs out of public health school were grant-funded projects -- quality of care when it was new, algorithms in medical assessment when unheard of. And the peer review process was essential in tightening us up (and our reviewers were the best in the field). I know my work was life-changing for us all.
Thank you for your work! 💕
One of the things I teach every scientist is to know your audience. With this in mind I have worked with Claude Opus 4.7 to draft seven conservative responses to different parts of the proposed rule change. I have linked these here as a Google Doc. There are seven letters because there are many parts to this OMB rule, each of which deserves careful consideration.
The linked letters are DRAFTS, not final presentations. They are addressed to a congressperson, not as comments to OMB. I will reformat them as OMB comments later and will post a link here. You are free to use any of these letters, or parts of them, but PLEASE edit them for clarity and to put them in our writing style. As I am a retired Biology professor, I instructed Claude to take this into account in the draft letters. This means that the wording may not be appropriate for you. AIs are brilliant at preparing drafts, but if a congressperson thinks that they are getting an AI response they will likely ignore it. Please modify the letter you decide to use so that it comes from you, not an AI.
Remember, we are addressing conservatives. If we want to have an impact I believe that our criticisms must address conservative concerns. Fortunately, there is plenty in this OMB proposal that violates traditional conservative principles.
https://docs.google.com/document/d/1_61xJygXG0Uy9saompHvGs0cYFsWj0lQzmABgAlnRJQ/edit?usp=sharing
I also found that much of the proposal went against the Heritage Foundation documents that were cited to support it. The oft-cited "Ditch" held that Congress, not the Executive branch, had the responsibility of fixing the problems with policy over-reach in agencies.
We need a STAND UP FOR SCIENCE rally, STAT!
Anyone have the information/contacts to get that going ASAP?
Once significant research grinds to a halt here, the billionaires who have funded the ongoing destruction of America's scientific and educational leadership in pursuit of tax breaks for themselves will happily fly to China for advanced medical treatment, leaving the rest of us to die.
I just submitted and saw that there are 13.9K comments! I wonder if anyone outside OMB is evaluating them?
Once again, thank you so much for your well-informed information.
Why isn’t this on the news for the general public to see? Have we all missed it?
I did it! Here is my letter (BTW: you don't put your name, etc in the letter you write--you give them your name at the end when you click "I am an individual". Also, i attached my letter just to be sure it gets as much circulation as possible. And here it is)
Federal Financial Assistance Rule (OMB-2026-0034)
Regarding Published Document: 2026-10817 (91 FR 32198):
1. Peer-review is a fundamental need to advance science, and we do want to advance science. The peers are the best able people to critique, improve, comment on new science. Politically appointed directors are likely (as in 99.99% certain) to not be qualified to intelligently review and decide on proposals to advance science.
2. Research takes years of work, including previous works and projects as well as parallel research. To be able to cut funding suddenly in mid-stride will hurt the current research as well as crippling or killing adjacent and future research in the same vein. Certainly, occasion may arise when finds show that a line of thinking is wrong or that some individual is duping the system, but that would be rare. And the whole of our science world should not suffer for it.
3. Why the proposed restrictions on scientists speaking to each other and the public about their work and progress? Science is, by and large, a team sport. Unfettered communication (except in rare instances, is necessary to efficiently advance science.
In summation, this OMB suggestion for foundational changes to our science system is anti-science. It seems meant to cripple or kill science in general and specific areas of science in particular. These proposals are not responsible oversight; they are draconian measures meant to make science either slow or absent. My wife has greatly benefitted from the discoveries of the past few decades. She as peritoneal cancer, a subset of ovarian cancer. She is alive and doing well today (although not cured) because she has participated in multiple clinical trials---science in action. For 15 years! And she is currently on an approved medicine that is not a trial drug. And take a guess how that drug came to be accepted and approved. Through trials. And those trials came out of the labs of multiple scientists over many years. Years in which they had peer-review, and had sure funding despite some false starts, and in which they talked to each other freely at conferences. This is the system that I and you should hope will continue when we need it. Please withdraw this proposed rule, Federal Financial Assistance Rule (OMB-2026-0034).
My comments to OMB are too long and detailed to be posted here. You may view them at the following link. I have done my best, with the assistance of Claude 4.7, to write in a way that will force a response from OMB before the final rule is published. I list six areas of concern and document them with reference to the applicable regulatory documents.
You may use any of my text, but I ask that you rewrite the text in your own style.
https://docs.google.com/document/d/14pU-3WmADLcw7ns87Yd2w2E9ryewZC0eviP5wbEKR14/edit?usp=sharing
Since all three branches of our current government are controlled by supplicants in the MAGA clone army, I don't see protest before hand as an effective effort.
Better still would be to keep your eyes and ears wide open to determine when and where the all but certain law suites will emerge from. Then dig deep into your already stretched thin pockets and contribute to the suite(s) or your choice.
This proposal by OMB was all outlined in P2025 that Trump lied about claiming he knew nothing of this. His administration is deeply penetrated by P2025 authors with the lead author being in charge of OMB.