Submitted comment on proposed revision of the OMB Guidance for Federal Financial Assistance

For more than 40 years, Woodwell has dedicated itself to objective scientific analysis for the benefit and safety of people and nature. The science we conduct seeks to mitigate and adapt to the amplified threats of extreme weather events, wildfire, food insecurity, and others due to our changing climate. These threats pose immense economic consequences. Thus, not only do we have traditional STEM scientists, but also economic experts who ensure accessible and applied research. We understand the direct economic and societal impacts that our research has on the American people, and we understand that these benefits extend not only from the subject matter of our organization but from all scientific exploration and innovation in the fields of health, technology, and engineering, amongst others.

Woodwell strongly opposes OMB’s proposed rule of Federal Finance Assistance as a whole, and most specifically the provisions outlined below (§200.202; §200.204; §200.205; §200.340; §200.432; §200.454; §200.461; and §200.220). The stated objective of these revisions to “improve transparency, accountability, and oversight for Federal awards across the Federal government” directly contradicts the content of the provisions that color this proposal. “Oversight” is the only objective that this proposal truly strives for, yet the distinction of political oversight rather than scientific oversight is conveniently absent. The space of federally funded scientific research is already heavily regulated, and this proposed rule threatens to suffocate it beyond recovery. This increase in faulty, politically motivated science would negatively impact American livelihoods, the economy, and national security.

§200.202 – Programs Must Align with Administration Priorities
By requiring every grant program to be designed so its goals “align with administration policies and priorities,” the Administration seeks to align research with its own interest areas, manipulating scientific investment for partisan priorities. Tying federal financial assistance to the shifting priorities of any given political administration inherently threatens the continuity of essential, objective research and risks defunding critical studies based on partisan agendas. Subordinating independent, data-driven scientific inquiry to political mandates undermines scientific integrity, jeopardizes vital longitudinal datasets, and ultimately deprives policymakers and the public of the unbiased evidence necessary to effectively combat the very real escalating, evolving, and emerging concerns related to climate, public health, biomedical research, technology, and others that may be inconvenient for an administration’s agenda.

§200.204 – Grant Competitions Exempted from Public Notice
Transparency is an underpinning of scientific integrity. By allowing for exceptions to not post grant opportunities on Grants.gov under the condition that the head of an agency subjectively deems the opportunity as serving the “national interest,” this provision sows distrust within the scientific community and the general public. In order to best serve the national interest, the selection process should be open to competition. Candidates hand-picked by the agency will create grantees who are subject to the political whim of the Administration, rather than to the true “national interest” of the American people. Moreover, this provision fundamentally contradicts the “aim to ensure that basic American principles of equality and equal opportunity are upheld throughout all stages of the award making process” that is advertised in this proposed rule, as all applicants are not equitably provided the opportunity to apply for these specific grants.

§200.205 – Political Appointee Review of Grants
The foundation of credible, high-impact climate science relies entirely on the objective, merit-based peer review of research proposals by qualified scientific experts. Granting political appointees the authority to review and potentially cancel federal grants introduces dangerous partisan bias into the scientific process, threatening to derail critical, long-term research that may be politically inconvenient but is vital for national and global security. This provision fundamentally undermines scientific independence, degrades the integrity of federal financial assistance, and jeopardizes our nation’s ability to respond to evolving and emerging threats, like the climate crisis, with unbiased, data-driven solutions.

§200.340 – Grant Termination
This provision allows an agency to cancel a grant mid-project if it determines that the award no longer aligns with agency priorities or the “national interest.” Complex scientific inquiry inherently requires multi-year planning, continuous data collection, and significant, sustained resource investment. Broadening federal agencies’ and political appointees’ authority to unilaterally terminate grants for reasons unrelated to grantee performance or compliance, such as shifting administrative priorities, introduces uncertainty into the research ecosystem. Similar attempts to freeze grants for subjects and institutions disliked by the President throughout 2025 resulted not only in tremendous economic losses and waste of previously approved investments, but also a critical loss of scientific knowledge.

By subjecting researchers to the whim of the Administration, scientists will hesitate to publish findings important to the American people that challenge the status quo and may inform necessary scientific revisions to long-term policies. By suffocating any hint of scientific dissension, the Administration will promote faulty science that will put America’s scientific reputation, as well as American lives, in harm’s way. To preserve the continuity, stability, and global competitiveness of American scientific innovation, we urge the removal of these expanded termination powers to ensure that merit-based research is protected from abrupt and unwarranted cancellations.

§200.432; §200.454; §200.461 – Indirect Costs
These provisions significantly limit, or openly ban, the use of federal grant funding to cover the vitally important indirect costs of conference attendance, journal subscriptions, and publications, among others. Woodwell strongly opposes the outlined preference towards institutions with lower indirect cost rates in this proposed rule. These costs support the competitive nature of a project through the maintenance of necessary equipment and facilities, as well as public-facing collaboration and debate.

Without the opportunity to share research with other experts, and the general public, researchers lose out on vital knowledge and feedback that leads to improved and more legitimate scientific conclusions. Without the financial ability to publish findings, a scientific experiment may never be reproduced and thus not be seen as a legitimate basis on which to conduct additional research on complicated topics. The myriad of indirect costs necessary for a successful project present extraordinary financial barriers that will make the American federally funded research landscape inherently inequitable, shutting out scientists and institutions who would not otherwise be able to afford these assets.

§200.220 – Prohibition of International Collaboration
This provision, which prohibits the spending of federal funds in relation to foreign collaboration, including on travel or indirect costs, would severely inhibit the ability of the United States to scientifically compete on a global scale and to work with international counterparts who often have specific skills or resources that facilitate and amplify scientific outcomes and innovation. The most pressing scientific challenges of our time, from tracking global climate patterns and biodiversity loss to mitigating public health crises, are global and rely on the exchange of data, resources, and expertise across nations.

Prohibiting federally funded researchers from partnering with international colleagues would isolate the American scientific community, deny experts access to vital global datasets and specialized facilities, and severely stifle innovation. Such a restrictive mandate threatens to dismantle decades of cooperative progress and will inevitably force the United States to cede its position as a global leader in scientific discovery.

The range of countries that fall under this provision of banned collaboration is exceptionally wide and highly variable over time: the qualifying characteristics are those countries considered foreign adversaries or those subject to sanctions or restrictions related to national security, defense, or intelligence activities. Under these rules, even the 17 European Union countries subjected to semiconductor export restrictions at the end of the Biden Administration would be banned from scientific collaboration. The limited outlined exceptions, as dictated by a political appointee, are not sufficient to protect international collaboration.

This provision would override the existing processes to prevent undue influence or security threats, as well as the processes for granting exceptions. Specifically, the restrictions would disqualify federally funded research from the fundamental research exclusion. This exclusion has long exempted basic or applied research from export control regulations to allow for the free exchange and publication of research results. Instead, researchers would need to apply for licenses at the State Department and the Commerce Department’s Bureau of Industry and Security. The proposed changes would significantly increase the costs, timelines, and workloads of international collaboration for these researchers as well as these federal agencies.

Impacts on Climate Resilience and Risk Mitigation
In the field of climate science and risk mitigation, this proposed rule would have exceptionally deep impacts. Although activities such as extreme weather tracking and preparedness, sustainable agriculture, and wildfire are all vital to the lives of everyday Americans, this Administration has a documented history of repressing these efforts in favor of harmful industry activities, including increased logging in previously protected areas.

Fire is a natural and integrally important process in the life cycle of our forest ecosystems. Woodwell scientists study and promote traditional methods of fire management of local and indigenous peoples who recognize the environmental benefits of fire via prescribed burns to reduce the buildup of natural fuels. Conversely, this Administration emphasizes fire tactics that have led to oversuppression, contributing to the buildup of dry fuel on the forest floor. Combined with the ever-warming temperatures destabilizing atmospheric conditions and extreme drought, increasingly frequent lightning strikes ignite these more flammable forests. Without regular fires to periodically clear out this fuel, the land has become more vulnerable to intense and widespread fires that present extreme threats to human health. Over 15,000 deaths have been attributed to wildfire particulate matter over the last 15 years. Without federally funded scientific research to bolster natural wildfire solutions, Americans are increasingly at risk.

Like most climate sciences, wildfires are not constrained by political boundaries. This means that international collaboration is critical to our work at Woodwell. This is especially true of our Arctic partnerships with communities across Alaska, Canada, Mongolia, and more as we study traditional wildfire mitigation tactics in the boreal forest region. Woodwell research has found that from 2006 to 2020, the economic burden linked to climate change-induced wildfire particulate matter alone accumulated to $160 billion. This potential economic payoff of exploring alternative solutions is only one example of the startling economic benefits of wide-reaching scientific research.

The Critical Role of Federal Financial Assistance to Economic and Global Competitiveness
Between the National Institutes of Health (NIH) and the National Science Foundation (NSF), the grants so far frozen or terminated since 2025 have resulted in economic loss across the United States estimated at $2.8 billion.10 The total job loss is estimated at more than 13,000. Texas faces the greatest economic loss of $366.1 million and around 2,000 jobs lost.11 Massachusetts faces an estimated $126.9 million in economic losses and 555 jobs lost. These losses are not exclusive to states on either side of the aisle: they are all-encompassing.

No institution is safe from these financial threats: two-thirds of land-grant universities and nearly half of all Historically Black Colleges and Universities have been affected. Even community colleges have had funding targeted for termination. Public universities and colleges suffered the steepest losses, with financial losses from grant disruptions totalling an estimated $2.1 billion. According to NSF data, the cancelled grants disproportionately affected early career researchers, women, people of color, and those with disabilities.

Private funders cannot step in to fill this funding gap. Basic research generates knowledge that diffuses beyond its original source and the current time, ultimately benefiting competitors. This “knowledge spillover” is great for the broader economy and thus broader population, but bad for companies trying to capture a return on their investment, leading the private sector to underinvest.

Government investments in scientific research and development are, and have historically been, an integral part of our nation’s economy, with returns estimated between 150% and 300% since World War II. In 2024, the knowledge and technology industries in the United States produced $3.3 trillion in added value, accounting for 11% of the U.S. GDP. From 2017 to 2024, the field’s financial contributions to the economy grew faster than the domestic U.S. nonfarm economy as a whole.

Federally funded research not only yields financial returns, but also provides for increases in our standard of living via biomedical advancements, a more favorable startup environment with increased job opportunities, and enhanced national security through the creation of advanced defense technologies. Economy-wide, long-term returns are calculated at $5 for every $1 invested in research and development. Further, $1 of public investment in research and development has been found to yield an additional $3 in follow-on private research and development investment. Economic researchers have concluded that the United States should invest much more in science and innovation than it does currently, especially given findings that federally funded research and development yields substantially higher returns than other forms of federal investment, including even physical infrastructure.

In cutting federal funding for scientific innovation, the United States puts its status of technological dominance in jeopardy. China’s annual research and development growth rate has rapidly outpaced that of the United States by more than 200% for over two decades. In 2024, the United States and China were neck and neck as the top producers of knowledge and technological industry, with $3.3 trillion and $2.9 trillion, respectively. However, that same year, China topped the US as the largest knowledge and technological manufacturing producer with 10% more of the global share.25 Under current projections, Chinese scientists will overcome US dominance in the fields of AI, semiconductors, materials, and high-performance computing in only 5 years. When considering the implications of this Federal Financial Assistance proposed rule, with its many problematic and restrictive positions, it can only be assumed that China’s dominance would be more inevitable and even faster-approaching than ever before.

Conclusion
The proposed revisions of the OMB Guidance for Federal Financial Assistance abandon scientific integrity. Woodwell urges the Office of Management and Budget to rescind the proposed revisions of the Guidance for Federal Financial Assistance so that science remains independent and free of any partisan agenda. The politicization of science is completely contrary to scientific value, and will irreparably damage America’s international reputation in this field. Most importantly, the stifling of scientific innovation will endanger American citizens through detrimental impacts on livelihoods, the economy, and national security.