On May 29, the Office of Management and Budget published a proposed rule that would fundamentally reshape how the federal government funds scientific research. The rule covers dozens of agencies — NSF, NIH, NASA, DOE, USDA, and more — in 412 pages of proposed revisions to 2 CFR Part 200, the government-wide grants management framework. Public comments are due July 13, 2026 at docket OMB-2026-0034.
This post evaluates the proposed rule through the framework of my 2007 book The Honest Broker: Making Sense of Science in Policy and Politics (Cambridge University Press, 2007). I argued that science supports democratic deliberation and decision making when it remains open, contestable, and simultaneously engaged with politics yet not captured by politics. Science becomes pathologically politicized when it becomes a tool for short-circuiting democratic decision making, such as when political actors embed their preferred conclusions into the machinery of expert authority via stealth advocacy.
For eighty years, federal science funding has rested on a social contract rooted in Vannevar Bush’s 1945 Science: The Endless Frontier: the public provides resources and a high degree of autonomy, and in return scientists produce knowledge that ultimately serves the public interest. That contract has been under strain for some time now, as often discussed here at THB.
Alvin Weinberg gave that contract a useful characterization in “Criteria for Scientific Choice” (Minerva, 1963): “science for policy” — research that informs public decisions, and “policy for science” — government stewardship of the research enterprise.
The proposed OMB rule would redefine both halves of that contract in explicitly political and partisan terms, collapsing Weinberg’s productive tension into one-way, top-down executive control. The result would not be better science policy — or even science policy at all. Instead, the new rule offers pathologically politicized science dressed up in regulatory language.
Federal science funding has real problems — replication failures, lack of rigor, and ideological capture in some programs. Even so, the proposals of the OMB rule are far worse than the problems they claim to address.
This week, Science editor-in-chief Holden Thorp wrote that the Trump administration “seems as determined as ever to mortally wound the nation’s scientific enterprise” and issued a call to action at his Substack. I agree with Thorp that the scientific community needs to mobilize a response — but how it mobilizes matters enormously, and if done poorly, could even make things worse. More on that later in this post.
First, let’s take a look at five problems with the proposed new OMB rule.
Problem #1: Political Appointees Now Formally Outrank Peer Review
“[S]enior appointees (or their designee) must not ministerially ratify or routinely defer to the recommendations of others, but must instead use their independent judgment when evaluating Federal award proposals.” — §200.205(c)
This single sentence proposes a consequential structural change in the proposed rule: all discretionary research awards must “demonstrably advance the President’s policy priorities.” Peer review in awarding extramural research grants has always been advisory — as anyone who has received or reviewed a grant well knows. However, the decisions of panels and program officers have never been subject to political review for conformance to a political agenda.
That by itself represents a shredding of the social contract for science.
In The Honest Broker, I identified the “science arbiter” role — the expert who provides authoritative technical answers to questions posed by decision makers so policy choices remain visible and contestable. Policy makers pose the questions — enlisting expertise as a part of the political process, and experts offer answers (complete with uncertainties and contestation) — keeping science apart from political meddling.
Once political officials override experts, that division of responsibility collapses. What remains is what Sheila Jasanoff (1990) called “regulatory science” that is captured by its principals. Russell Vought’s own Project 2025 chapter described OMB as the “keeper of ‘commander’s intent’” — this OMB rule operationalizes that vision.
Experts are reduced to providing the “science” that political leaders prefer to have. And that is not science at all, but pathologically politicized science.
References:
Jasanoff, S. (1990). The Fifth Branch: Science Advisers as Policymakers. Harvard University Press.
Guston, D. (2000). Between Politics and Science. Cambridge University Press.
Sarewitz, D. (2004). How science makes environmental controversies worse. Environmental Science & Policy, 7(5), 385–403.
Problem #2: “Gold Standard Science” Is a Political Label, Not a Scientific Standard
“[A]pplicants should commit to complying with administration policies, procedures, and guidance respecting Gold Standard Science.” — §200.205(b)(5)
“Gold Standard Science” appears five times in the regulatory text but receives no definition in 412 pages. Its origin traces to Executive Order 14303 (”Restoring Gold Standard Science,” May 2025), which is equally vague. An undefined standard is ad hoc, inconsistent, without accountability — a slogan, not policy.
For instance, the rule prohibits funding for activities that deny “the sex binary in humans or the notion that sex is a chosen or mutable characteristic” — embedding into federal funding criteria a specific position on an empirical question that is perfectly reasonable for experts to discuss and debate. Imagine a Democratic administration doing the mirror image — prohibiting funding for activities that reflect a view that “the sex binary is absolute.”
Science is science because researchers have freedom to research, debate, and discuss controversial subjects. In science it is OK to be wrong. Science exists to sort out competing knowledge claims, not to reflect a catechism built upon dogma.
In The Honest Broker, I described the “stealth issue advocate” — the actor who encodes contested value and empirical conclusions into supposedly neutral governance frameworks, making political choices invisible and removing them from democratic accountability. This is not a new pathology: Jasanoff (1987) documented it in EPA and FDA regulatory science. When contested empirical claims enter grant criteria, science stops serving democratic deliberation and starts foreclosing it.
References:
Jasanoff, S. (1987). Contested boundaries in policy-relevant science. Social Studies of Science, 17(2), 195–230.
Hajer, M. (1995). The Politics of Environmental Discourse. Oxford University Press.
Wynne, B. (1992). Misunderstood misunderstanding: Social identities and public uptake of science. Public Understanding of Science, 1(3), 281–304.
Problem #3: The Rule Builds Regulatory Architecture on Partisan Politics
“Federal programs were frequently designed between 2021 and 2024 to include preferences and selection criteria aimed at advancing identity-based DEI policies.” — Preamble §A.1 (citing Heritage Foundation Backgrounder No. 3710 and Heritage Foundation report, Apr. 18, 2024)
Federal rulemaking carries legal and democratic weight because it builds on a foundation that historically has been viewed to be authoritative, legitimate, and salient — such as peer-reviewed literature, government audits, and Inspector General reports. That doesn’t mean that rules are always beneficial or based on science that might later be revisited — only that democratic legitimacy has been served.
The rule does cite legitimate sources — a 2023 GAO report, several IG findings. But the ideological narrative that justifies the rule’s most consequential changes rests on partisan advocacy documents, such as Russell Vought’s Project 2025 chapter. The significant literature on science and technology policy and science and technology studies has no presence.
A rewriting of the social contract that has governed U.S. research and development for more than 80 years may well be a good idea. I have argued for thirty years that the existing social contract for science needs updating. A serious rewriting might well be warranted. But to succeed, such a project must build upon broad democratic legitimacy — not narrow partisan authority.
References:
Weingart, P. (1999). Scientific expertise and political accountability. Research Policy, 28(6), 869–883.
Boswell, C. (2009). The Political Uses of Expert Knowledge. Cambridge University Press.
Michaels, D. (2008). Doubt Is Their Product. Oxford University Press.
Problem #4: The Foreign Collaboration Ban Would Compromise U.S. Science
“Federal funds may not be obligated or expended by a recipient or subrecipient to support a bilateral or multilateral collaboration, agreement, program, or activity with a covered foreign country or covered foreign entity.” — §200.220(a)
The proposed rule would prohibit federal funds — including indirect costs — from supporting any bilateral activity with a “covered foreign country.” The rule provides no scientific impact analysis, no estimate of affected grants, and no mechanism for scientific review of exceptions. An agency head may grant exceptions upon a national-interest determination requiring no expert input and no documentation standard.
Modern science is structurally international. A 2023 Nature analysis found that internationally co-authored papers draw substantially higher citations. The NSB’s 2024 Science and Engineering Indicators documents that U.S. researchers co-author with Chinese counterparts more than with researchers from any other country.
As Caroline Wagner showed in The New Invisible College (Brookings, 2008), modern science operates as a global network that centralized national control cannot replicate or replace. Preventing technology transfer to adversaries is a legitimate goal. A blanket prohibition with no scientific triage, no impact analysis, and no expert review process is not a serious policy instrument.
References:
Wagner, C.S. (2008). The New Invisible College: Science for Development. Brookings Institution Press.
National Science Board. (2024). Science and Engineering Indicators 2024. NSF.
Weinberg, A. (1963). Criteria for scientific choice. Minerva, 1(2), 159–171. — The foundational text on distinguishing “science for policy” from “policy for science,” the balance this rule destroys.
Problem #5: The Rule Substitutes Partisan Acceptability for Democratic Accountability
“[S]enior appointees (or their designee) must not ministerially ratify or routinely defer to the recommendations of others, but must instead use their independent judgment when evaluating Federal award proposals.” — §200.205(c)
The rule creates a comprehensive new accountability architecture for grantees: pre-issuance review, mandatory payment justifications, expanded risk criteria, E-Verify requirements, subaward reporting, and new compliance conditions. That accountability structure ends with political appointees making final judgments.
Former NIH Director Elias Zerhouni — appointed by George W. Bush — told Science magazine that the rule’s structure alarmed him. In that same article, Neal Lane, who served as science advisor to President Bill Clinton, agreed, citing the case of NSF:
“NSF makes grant decisions based on the deep knowledge of experts in the field, not on whether it meets an ideological agenda. That’s what merit review is all about. Replacing it with top-down decision-making will destroy that process and result in bad science being funded.”
There are many aspects of federal R&D that might be improved — giving political appointees ultimate power to approve or deny who or what is funded would not be an improvement.
References:
Guston, D. (2000). Between Politics and Science. Cambridge University Press.
Heclo, H. (1977). A Government of Strangers. Brookings Institution Press.
Jasanoff, S. (2011). The Practices of Objectivity in Regulatory Science. In Camic, Gross & Lamont (eds.), Social Knowledge in the Making. University of Chicago Press.
What Should Happen Next
The comment period closes July 13, 2026. Substantive comments addressing specific regulatory text carry more legal weight than general objections. Here is a short action agenda with specific actors named.
1. OMB: Withdraw or substantially revise the proposed rule
Merit review criteria must rest on peer-reviewed scientific standards, not on undefined political labels or contested empirical claims written into grant conditions. OMB should develop specific, measurable quality standards through consultation with NSF, NIH, and the scientific community — not sourced from partisan manifestos. This is of course unlikely to happen.
2. Congress: Exercise oversight now, and make it bipartisan
The House Science Committee and Senate Commerce Committee should hold hearings before this rule takes effect on October 1, 2026. Crucially — Republicans should note the fundamental asymmetry: partisan control of federal science governance via the executive branch would not disappear when Democrats win the next (or some other) election.
That means that every elected official representing a major research university, medical center, or national laboratory has a direct constituent interest in improving federal science policy in a way that benefits all Americans, regardless who happens to be in office.
Congress should in parallel advance scientific integrity legislation. In my 2019 testimony before the House Science Committee, I argued that scientific integrity obligations fall on appointed officials, not only on scientists, and that such protections require bipartisan support to survive changes of administration.
Rep. Paul Tonko (D-NY) and Rep. Brian Fitzpatrick (R-PA) co-introduced the Scientific Integrity Act (H.R. 1106) in the 119th Congress — with 111 Democratic and 1 Republican cosponsor beyond the two sponsors. As I discussed in “Trump vs. Biden on Science Integrity” at THB last August, that ratio remains a problem: scientific integrity protections mean nothing if they are not bipartisan. Congress should engage federal science policy in a bipartisan manner, starting now.
3. OMB: Replace the rule’s international provisions with a targeted national security review process
Replace the blanket prohibition on foreign collaborations with a risk-stratified framework by research type, institution, and collaboration structure. Federal agencies and units — like JASON, the NSF Inspector General, and the intelligence community — have the tools. Use them. Fix and improve processes — don’t just break them.
A Warning: Don’t Try to Fight Partisan Fire with more Partisan Fire
Leaders in the scientific community should take on the proposed new rule, but how they take it on makes a huge difference.
Casting debate over the rule as science-versus-Trump would hand the rule’s authors the argument they want. The preamble argues at length that federal science functioned as an arm of the political left for four years — an argument with enough traction that a scientists-versus-MAGA frame simply confirms the rule’s own diagnosis.
If the scientific community accepts or reinforces that framing it would tell the public: yes, this is a culture war, and we scientists are on one side and half of America is on the other side. The scientific community should not walk into that trap.
As well, every Republican who might cheer on this rule today should understanding that they are handing a a powerful political weapon to the next Democratic administration. Permanent executive control of science funding serves no one’s long-term interest.
That requires leaders in the scientific community to do several things that they would surely find uncomfortable: acknowledge that some programs became ideologically captured during the Biden years (and even earlier); build a coalition that explicitly includes Republican scientists, Republican university presidents, and Republican members of Congress with major research institutions in their districts; and frame this as a defense of American national capacity, not framed as a defense of a Democratically-aligned scientific establishment against the MAGA Republicans.
The social contract that has sustained federal investment in research for eighty years — producing along with the private sector modern medicine, the internet, GPS, and the foundations of American agriculture — does not belong to either political party. This proposed rule treats that contract as a political instrument of the current executive. That is a bad idea whether the president is a Republican or a Democract.
Science is for all Americans. This rule is anti-American.
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Government funding corrupts any scientific research it touches, so it should be minimal and only for research the government immediately needs, as in defense research funding for example. Businesses should fund research they deem necessary for their business. This modern idea of passing out money to researchers so they can look into anything that strikes their fancy is wrong and a corrupt use of government funds. It turns into, "I want you to produce a paper that supports my political ambitions." Very bad idea.
Every body in favor of these changes needs to apply the 'Shoe on the other foot" doctrine. Ask "What would my worst political enemy do with this if or when he or she has 51% of the votes in the next election?" it might be a sobering thought.