This article, about the Federal government’s proposal to regulate science and other grants, was written by Dorit Rubinstein Reiss, Professor of Law at the University of California Law, San Francisco, who is a frequent contributor to this and many other websites, providing in-depth and intellectually stimulating articles about vaccines, medical issues, social policy, and the law.

Professor Reiss writes extensively about the social and legal aspects of vaccination in law journals. Reiss is also a member of the Parent Advisory Board of Voices for Vaccines. This parent-led organization supports and advocates for on-time vaccination and the reduction of vaccine-preventable diseases. She is also a member of the Vaccines Working Group on Ethics and Policy.

The Trump administration’s Office of Management and Budget (OMB) has proposed a strict new rule to regulate all federal grants. Although I am focused on science, this rule will regulate grants for housing, education, defense, NASA, and many other agencies. It would fundamentally change how scientific (and other) research is conducted in the USA.

Elisabeth Marnik, PhD, goes into detail as to how this new rule will devastate scientific research in the USA. Basically, there are three reasons why this is a bad thing:

1. Political appointees would decide which science gets funded, and peer review would be explicitly sidelined or ignored.
2. Grants could be canceled at any point, without warning, in the middle of ongoing work.
3. Researchers would have a harder time communicating their findings without pre-approval from the federal government.

This post is a reminder that the comment period for the OMB rule is open until July 13, 2026, and please submit comments here.

Why should you comment on the science grants rule?

Why comment?

1. You can hope to influence the agency – but that is often limited: at the point of a proposed rule, agencies have more or less made their mind, and your ability to get change is real, but limited.
2. For observers: your comment can help outsiders understand what is going on and what the issues are.
3. Issues raised in comments are hooks for litigation: ignoring them risks the rule being overturned on judicial review.

Here is Regulations.gov‘s own guide to submitting comments, which is pretty good, likely because it predates this administration:

I’ll have resources below on this specific rulemaking, but do note that you should write your own comment – it’s fine to draw on others’ talking points, but the agency will collapse issues together, so just repeating exactly what someone else said has limited value (though some value).

As I hope this makes clear, it’s worth commenting even if you don’t think the agency will listen.

Some public resources for this rule:

1. Webinar about it, July 1.
2. Elizabeth Ginexi’s public comment, as an example.
3. Issue brief by Governing for Impact.
4. Breakdown by Elisabeth Marnik.

Take the time to comment; it might have a larger impact than you might think. Again, here is the link to comment on this proposed regulation.