APS Submits Formal Comments Opposing Proposed OMB Grant Rule

My organization runs one major conference with approximately 3000 attendees and 1-2 small conferences of approximately 150 attendees each year. In the new rule "OMB proposes to expand § 200.432 to add a requirement that costs for attending conferences are allowable only if participation in the conference is expressly approved by the agency and included in the terms and conditions of the award." This would be incredibly detrimental to the success of our conferences. Scientists make decisions about which conferences to attend based on several factors: the state of their research and whether they are ready to present; the focus of the conference; the cost of the conference; and the convenience of the location, which also factors into travel costs. Our conferences change location and the smaller conferences change focus each year. This means that grantees would not have sufficient information at the time of the award to decide whether they will need to attend a future APS conference. If they must obtain permission from the agency before registering for a specific conference it will create a significant administrative burden and discourage scientists from attending conferences. Currently 86% of our conference attendees use federal funds to cover costs of attendance. APS has invested substantially in our conference program and designed our smaller conferences to be financially sustainable, but subsidizing the cost of registration for attendees. If this revenue is negatively impacted the conferences would become financially unsustainable and result in approximately a $1.1M decline in our revenue. I request that conference costs be allowable without prior approval and inclusion in the terms and conditions of the award.

My organization is neither a country club nor has a primary purpose of lobby although we do a small amount of advocacy work within the limits of our 501(c)3 status. The new rule would "add a requirement for prior approval of the federal agency" for costs related to subscription or memberships. This significant administrative burden will discourage scientists from belonging to scientific societies, which provide professional support that helps them do their job more effectively. According to surveys of our members more than 30% of them use federal funds to help pay for their membership. If they are no longer able to do so it could represent a loss to our business of $286,000.

This section also addresses subscriptions to journals. APS has implemented a very successful approach to publication subscriptions called Subscribe to Open. In this format libraries pay for the subscriptions to the journals and once enough of them have subscribed the journals are open to everyone. If the cost from federal grants can't be used for publications or if there is a significant administrative burden to using these funds then we will be unable to maintain this model, which is central to our business. I request that prior approval is not necessary for membership, subscriptions and professional activity costs.

APS publishes 16 scholarly publications. The proposed rules states "Publication costs are not inherently necessary to carry out the core programmatic objectives of most Federal awards" and argues that they should not be allowed. That could not be farther from the truth in science. Scholarly peer-reviewed publications are the primary way that scientists exchange information about their discoveries and create the scientific record. By contributing and reading articles, scientists ensure that they are building on established findings and making new discoveries. A significant amount of APS's revenue comes from publications. If scientists and institutions are unable to use federal funds to publish in and subscribe to our journals the loss to APS could be as high as $6.1M. This would be devastating to our bottom line and would likely result in loss of jobs. I request that publication and subscription costs continue to be allowed in federal grants.

APS' overarching goal and purpose is to empower scientists to understand life, health and disease. Their important work leads to the development of treatments and cures and saves lives. Thank you for the consideration of my requests.

Despite a peer review system that has made the U.S. a global leader in scientific research over the past several decades, the proposed rule would establish pre-issuance review of federal grants by senior political appointees aimed at, among other things, ensuring that discretionary awards "demonstrably advance the President's policy priorities" and avoid promoting anti-American values. These standards are vaguely defined, highly subjective, and inherently political in nature.

Each presidential administration brings its own set of scientific priorities and interests to government programs, identifying areas that are ripe for investment. Examples of this include President John F. Kennedy's focus on the space program and President Richard Nixon's creation of the National Cancer Institute. By focusing resources on areas of emerging scientific opportunity and bringing a whole government approach, significant progress can be made in a short period of time. Using existing mechanisms to focus research on priority areas, as President Trump is doing with artificial intelligence, creates opportunities to advance research in specific areas while not disrupting ongoing federal programs intended to support broad based investigator-initiated research focused on solving the world's most pressing health challenges.

Some federal research agencies including NSF and NASA routinely make funding decisions that reflect the agency's scientific priorities and strategic objectives in addition to merit review scores. This existing system works well for certain agencies with targeted missions because it allows agency leadership to direct research toward national priorities, which is particularly important during periods of national emergency or technological change. Key to the success of this system are the qualifications of the administrators who are making those decisions. Decision-makers should possess substantive expertise in the relevant scientific domains and demonstrate a genuine understanding of the research landscape. Funding decisions must be justified on scientific merit and alignment with declared agency missions, not based on political affiliation, patronage or ideological considerations unrelated to the research itself. When discretion is used in making award decisions, agencies should articulate the scientific and strategic rationale for discretionary awards, allowing the research community to understand how priorities are established and evaluated.

In contrast to the system described above, the NIH utilizes a peer review process that relies more directly on panels of science experts from the community to identify and fund the most promising ideas in a specific biomedical research area. Under the current system at NIH, peer review panels (study sections) provide expert review of proposals, followed by funding decisions made by the Councils at each institute or center. These Councils are populated by thoroughly vetted content experts who can assess whether proposals align with the agency's mission and are likely to advance scientific goals. The system currently used by NIH stands in contrast to the proposed process, which calls for senior political appointees or their designees to "use their independent judgment" when evaluating award proposals. Nowhere is it required that the appointees possess content expertise relevant to the proposals under evaluation. Such a system will lead to high-stakes decisions about science being made by non-scientists based on vaguely written and subjective political criteria. The proposed process for pre-issuance award review lacks transparency about who is making decisions and how those decisions are being made. It would also add a layer of bureaucratic administrative review that will slow the grantmaking process.

The proposed changes to section 200.205 requiring pre-issuance review of all federal grants across agencies with different sizes, scopes and missions by senior political appointees will erode the quality of federally funded science by allowing vaguely defined political considerations to routinely override expert level peer review. The proposed regulation specifies that "peer review recommendations remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding." However, as noted by the government in section 200.205, "merit review is an objective process of evaluating Federal award applications." The importance of merit review was also noted in President Trump's May 2025 Executive Order on Restoring Gold Standard Science, in which section 3 lists unbiased peer review as one of the essential elements for conducting Gold Standard Science. Reliance on peer review has made the U.S. a dominant global leader in the sciences over the past century. If peer review and council review have limited impact on grant decision making, it is likely that fewer scientists will volunteer their time toward the peer review process, potentially leading to collapse of the peer review process itself.

Recommendation: Withdraw 200.205 in its current form and continue to allow federal research agencies to use discretion in establishing peer review processes that are based on scientific merit and alignment with declared agency missions. The quality of research proposals as judged by the merit review process should be a primary factor guiding decisions about which science to fund, irrespective of alignment with political objectives.

The proposed changes to the allowability of costs related to publications and conferences will eliminate the ability of federally funded scientists to communicate the results of their research with their peers. Researchers rely on sharing information through peer-reviewed publications and at scientific conferences. These activities allow them to learn from one another, build upon each other's work, and spark new ideas for future lines of research. Eliminating these methods of communication will force researchers into silos and impede innovation. In the proposed changes, the government seeks to only support those activities that directly advance program outcomes. Publishing and sharing the results of federally funded research at conferences are essential activities that advance program outcomes. Researchers cannot solve the complex problems facing our nation without working together.

It is essential that researchers have access to adequate funds to publish their work and comply with federal requirements. Federal agencies including NIH and NSF require researchers to make the published results of their research freely available to the public as a term and condition of their grants. Expanding access to the results of federally funded research offers clear benefits to the scientific community, healthcare providers and patients, and the public. Publishers play a key role in this process by providing a forum for sharing research that ensures the long-term integrity of the scientific record. Requiring free and immediate access to research articles while at the same time prohibiting the use of federal funds to support costs associated with publication amounts to creating an unfunded government mandate.

In sections 200.461 and 200.454, OMB proposes prohibiting the use of federal funds to cover costs associated with scientific publications including subscriptions, article processing charges, and page fees, except as approved in advance by the federal agency on a case-by-case basis. Requiring agency approval on a case-by-case basis is not feasible given the scale of research sponsored by agencies such as the NIH and NSF. This prohibition would exact a heavy toll on researchers and scientific societies and put at risk the integrity of scientific literature and the historical research record.

At many academic institutions, the facilities and administrative, or indirect, costs that come with grants to individual researchers support library budgets, including the cost of journal subscriptions. While OMB did not propose to change the indirect cost rates in this revision of the Uniform Guidance, disallowing the use of federal funds for publications effectively subverts the will of Congress which has expressly prohibited the administration from making changes to the current process for negotiating indirect cost rates.

APS relies heavily on revenue from subscriptions held by libraries, universities and other institutions to cover the costs associated with high-quality and rigorous publishing, and loss of that revenue will destabilize the business model of many society publishers including the APS. APS is committed to providing high-quality open access options to ensure that authors can share their research widely, but high-quality scientific publishing requires substantial investment in editorial oversight, peer review and ethics management, content curation, technology infrastructure and long-term preservation. Without adequate revenue, those services cannot be provided.

When articles are submitted to APS journals, they undergo a rigorous peer review process led by subject matter experts. APS invests substantially in the infrastructure required to make this an efficient and robust process. Upon submission of an article to an APS journal, research methods are checked using an external tool that provides an initial measure of rigor and reproducibility. After an article is referred for review, the reviewers use a comprehensive checklist to ensure the research meets standards for rigor and reproducibility. The checklist addresses adherence to requirements for human and animal research; detailed information on the use of cells, antibodies, and other reagents; and standards for presenting data.

Once articles are accepted, they are copyedited and formatted for deposition into repositories as accepted manuscripts. This process is critical for minimizing errors in the published literature. Research published in APS journals also undergoes review for ethical issues to ensure the integrity of the science being published. APS reviews articles for potential ethical issues before publication and is also a key stakeholder in ensuring the post-publication integrity of the scientific record. The costs associated with ensuring research integrity are growing as technology evolves and new threats to research integrity emerge. Providing these services requires significant investment by APS in technology and personnel.

Recommendation: Withdraw sections 200.461 and 200.454 and continue to allow the use of federal funds to support journal subscriptions and costs associated with the publication of articles that result from federally funded research. This prohibition is directly at odds with agency policies requiring researchers to provide access to the peer-reviewed results of research supported by federal grants. Prohibiting the use of federal funds for subscriptions and publications costs will halt scientific progress, erode the quality of the scientific record and substantially harm researchers who rely on developing a robust record of scientific publications to communicate their work and advance their careers. Publishing the results of federally funded research in peer-reviewed publications is essential for researchers to demonstrate their progress, build credibility, and secure future grant funding.

Scientific conferences provide critical opportunities for researchers to report on the results of their federally funded research, learn from colleagues in their fields, and initiate collaborations. This method of scientific communication is essential to research progress. Early career researchers also rely on conferences to network, participate in career development, and learn new skills. Revisions to section 200.432 would make costs for attending conferences unallowable unless expressly approved by the agency at the time of the award and included in the terms and conditions of federal awards. Implementing these changes would cut off a crucial channel for communicating the results of federally funded research.

As noted elsewhere in the APS response, most research grants issued by the NIH span five years. It may not be possible for a researcher to know when applying for a grant which conferences would be most advantageous to attend. There are times when research leads down a novel scientific pathway, requiring investigators to create new professional networks to advance their work. In addition, requiring agency approval of conference attendance may substantially increase administrative burden for both grantees and federal agencies.

APS holds an annual conference that spans the breadth of physiology research, showcasing the newest findings and giving researchers the opportunity to meet, network and develop collaborations. These annual conferences play a particularly important role for early-career researchers who need to build their professional networks and demonstrate their findings. In addition to the annual meeting, APS sponsors smaller, member-driven conferences throughout the year that bring together research specialists to focus on specific areas of research. As an example, next year APS will convene a Signals and Systems: Interorgan Communication in Health and Disease Conference, which will bring together physiologists studying interorgan cellular communication, signaling pathways, organ crosstalk, interorgan pathology and pathogenesis. Physiologists play a unique role in this emerging area of science, and the conference will bring together researchers to learn from one another and share their ideas. Understanding how these complex physiological systems work together will help researchers solve the complex health challenges facing many Americans today.

In 2025, APS conferences collectively served over 3,000 physiologists, nearly half of whom were graduate students and post-doctoral fellows just launching their scientific careers. A recent survey of APS members shows that approximately 85% rely on federal grant dollars to support their conference registration fees, abstract submission fees and travel to attend the meetings. If these costs are no longer allowed to be charged to federal grants as proposed in section 200.432, it will not be financially possible for scientific societies such as APS to sponsor scientific meetings and researchers will lose the opportunity to communicate their research, advance their science through collaboration and grow their professional networks. These conferences are essential for scientific progress, and they contribute to maximizing the government's investment in research by ensuring that the results of federally funded research are communicated and built upon.

Recommendation: Withdraw section 200.432 and allow costs related to attending conferences to be charged to federal grants. Requiring researchers to include conference attendance in award terms and conditions is not practical, and requiring agency approval will increase administrative burden.

The changes proposed in section 200.340 would allow agencies broad authority to terminate awards if they are determined to "not effectuate program goals, Federal agency priorities, or the national interest." Current rules call for grants to be terminated for failure to comply with the terms and conditions of the award, usually under circumstances of scientific or financial misconduct. These rules are necessary and appropriate to protect scientific integrity. Under the proposed guidance, ongoing grants could be terminated whenever there is a turnover in the presidency, which results in changing policy priorities. Given that research grants issued by the NIH generally have a standard length of five years, many awards will span a change in presidential administrations and therefore be subject to altered policy priorities.

Section 200.340 would also create the ability to temporarily suspend grants if it is determined that a suspension is "in the interest of the Federal agency." These terms are poorly defined and highly subject to interpretation, making them impossible to apply consistently across agencies. Further complicating the termination and suspension rule changes is the language in section 200.208, which would allow agencies to add or remove specific conditions throughout the award period. It appears that this language would allow an agency to add or remove a condition to an award at any time during the award period and then terminate or suspend the award for noncompliance.

The negative consequences of these policy changes for researchers are substantial. When researchers apply for grants and design their research, they plan for multiple years in advance to ensure that they have access to necessary materials, expertise and equipment and that they can hire and train staff to successfully carry out the research being proposed. In addition to using federal grant funds to purchase materials and equipment, salaries are a major expense. Allowing termination or suspension at any time for vaguely defined reasons or changes to award conditions mid-stream will destabilize scientific careers and discourage people from entering the sciences.

Abruptly terminating ongoing grants wastes taxpayer resources already invested in the research project. If a grant has been underway for multiple years when it is canceled due to a change in policy priorities or the interest of the Federal agency, it is likely that ongoing experiments will be disrupted and the data already generated from that research will be lost. In the case of research that includes human or animal subjects, arbitrary terminations and suspensions may also represent a risk to the people and animals involved in the research. A study published last year in the Journal of the American Medical Association Internal Medicine found that grant cancellations affecting ongoing clinical trials between February and August 2025 involved approximately 74,000 participants, some of whom may have been receiving interventions when the grants were terminated. This represents an unacceptable level of risk for human participants, and an unethical waste of taxpayer resources that were already invested at the time of cancellation.

Recommendation: Withdraw revisions to sections 200.340 and 200.208 and continue to limit award termination to cases of scientific misconduct or failure to comply with the terms and conditions of the award. Terminating or suspending grants using vague criteria such as administration policy priorities or the interest of Federal agencies will harm individual researchers and waste taxpayer resources.

APS acknowledges that research security is a real concern, and collaboration with foreign entities requires appropriate risk assessment, approval processes, mitigation measures and ongoing monitoring. Over the past several years, federal agencies have taken significant steps to safeguard research security by putting in place a layered framework for reviewing and approving international collaborations. In addition to existing disclosure requirements, prohibitions on recruitment of foreign talent, and agency-level review mechanisms, two recent changes have further strengthened research safeguards:

The Department of Justice issued a final rule implementing Executive Order 14117, which prohibits and restricts transactions involving the transfer of significant quantities of sensitive personal data to countries of concern.

The NIH published a policy on "Enhancing Security Measures for Human Biospecimens" placing new restrictions on entities that hold human biospecimens of U.S. persons collected, obtained, stored, used, or distributed using ongoing or new NIH funds. As of Oct. 24, 2025, the NIH policy prohibits the sharing of human biospecimens with individuals or entities located in the federally designated countries of concern.

However, APS is concerned that the proposed revisions in sections 200.220 and 200.202(e) would compromise U.S. leadership in the sciences by preventing important opportunities for international collaboration. Science is an inherently global endeavor. Researchers in the U.S. routinely work with colleagues in other countries to access techniques, expertise, data, and materials that don't exist in the U.S. Applying broad restrictions on foreign collaborations or requiring new layers of justification and approval will diminish these opportunities and put U.S. researchers at a global disadvantage.

One of the most pressing questions raised by the changes in sections 200.220 and 200.202(e) is how researchers in the U.S. will be able to effectively monitor and study emerging infectious pathogens or relatively rare diseases without collaborative relationships with scientists in the countries where the diseases originate or provide access to larger numbers of patients. These collaborative relationships are necessary for researchers to understand how emerging pathogens are transmitted, how emerging pathogens or rare diseases present in patients, and how pathogens or rare diseases can be targeted with therapies and prevention strategies. Prohibiting these relationships will impair the country's ability to respond to infectious disease threats before they reach American borders and compromise national security. Rare diseases will remain understudied because of a lack of access to significant numbers of patient samples or data.

Recommendation: Withdraw sections 200.220 and 200.202(e) and continue to fully implement the robust and layered safeguards that are already in place to protect research security. Ensure that the rules for foreign collaborations are sufficiently clear to grantees, both institutions and individual investigators, such that they can easily be followed and enforced.

It is well known that federal investment in biomedical research has substantial economic benefits, with an estimated $2.56 return for every $1 invested in NIH research. Those returns come through related business endeavors, including scientific societies such as APS. As a scientific society, APS serves a community of more than 8,000 members and 80,000 authors. Revenue losses resulting from the proposed rule changes will be financially devastating to APS as an organization, compromising our ability to fulfill our mission of empowering scientists to understand life and improve health by advancing and communicating discoveries in physiology and medicine. The effects of the proposed changes will reverberate across the economy and result in broad economic damage across the U.S.

The proposed revision was issued on May 29, 2026, with a 45-day comment period. APS requested an extension in writing on June 3, 2026, which was denied. APS also joined with more than 300 other organizations in requesting an extension on June 12. For a proposed revision of this size and scope, 45 days is not enough time to fully analyze the rule and understand the possible impacts on the economy, the U.S. scientific enterprise, the physiology community, and our organization.

Recommendation: Withdraw OMB-2026-0034-0001 in its entirety to avoid negative impacts on the U.S. economy and scientific enterprise.