On August 7, the White House issued an executive order (EO) claiming to improve oversight of federal grantmaking, but experts are deeply concerned that the actual impact would dramatically politicize grantmaking and undermine the U.S. scientific enterprise. The EO hands over final approval of funding solicitations and discretionary grants to political appointees and allows for awarded grants to be cancelled at any time, for any reason.
[The White House has released a fact sheet for the EO, which can be found here.]
The EO claims that federal grantmaking is deeply flawed, while requiring federal agencies, grantees, and applicants to adopt new grantmaking processes that will introduce more serious problems than it postures to address.
Each federal agency head must designate a senior appointee—most likely selected by the president—who will review and approve all new notices of funding opportunities (NOFOs), all new individual grants, and all existing grants (on an annual basis) to “ensure that they are consistent with agency priorities and the national interest,” which have yet to be defined. This begs the question if appointees will have the necessary subject-matter expertise to effectively evaluate the scientific merit of NOFOs and grants.
In reviewing NOFOs, grants, and proposals, the senior appointee must apply several principles unrelated to scientific merit, for example:
- Awards must advance the Administration’s policy priorities “where applicable” (not defined).
- Awards cannot “fund, promote, encourage, subsidize, or facilitate” racial preferences, illegal immigration, the denial of a sex binary, or “any other initiatives that compromise public safety or promote anti-American values.” Once again, the EO fails to define a critical concept—anti-American values—leaving substantial room to reject grants for non-scientific reasons.
The EO directs appointees to give preference to applicants from institutions with lower facilities and administrative (F&A) cost rates. As both the courts and the Senate have rejected its previous attempts to cap F&A cost rates at 15 percent, incentivizing low rates in this manner may be the only way for the Administration to exert control over the issue. This will result in poorer quality research and/or less research overall if institutions are unable to afford the necessary F&A expenses.
In direct contrast to a previous EO calling for federal agencies to implement “Gold Standard Science” (GSS) (see previous FABBS article), this EO explicitly sidelines the peer review process. While senior appointees must have at least one subject-matter expert assist in reviewing scientific research NOFOs, grants, and proposals, the Administration instructs them to not defer to experts when making funding decisions and “instead use their independent judgment.” In other words, peer review recommendations will be “advisory” only and wield no real influence in the grantmaking process, blatantly opposing the GSS the administration has claimed to champion.
The EO orders all relevant federal agencies to revise their grantmaking guidance and regulations to allow for the termination of any grant at any time “for convenience.” Currently, awarded grants can only be terminated “for cause,” e.g., misuse of funds and scientific malfeasance. This policy would apply to both future and existing grants. Subjecting research to the ever-changing political winds—turnover in the “president’s policy priorities” occurs every four to eight years—will repeatedly and severely disrupt scientific progress in the U.S.
Finally, rather than streamlining federal grantmaking, the changes resulting from this EO will further complicate the process. Perhaps most notably, grantees must now request approval each time they wish to drawdown money from their award, i.e., any time a grantee wants to use their awarded money, they must, in writing, re-seek approval and re-justify their expenditures. This requirement serves no scientific purpose and will only slow down an already complex process. Furthermore, the introduction of political review on top of scientific review will increase an applicant’s workload, as they will now have to consider both scientific merit and political biases when writing a proposal.
Overall, this new EO suggests that, rather than caring about improving the grantmaking process, the Trump Administration is instead concerned with controlling how federal money is spent. The other two branches of government—the courts and Congress (which, per the Constitution, has the power of the purse)—have pushed back against the executive branch’s attempts to control the federal budget and upend our scientific infrastructure, but the Administration is actively trying to circumvent that pushback with this EO. By subjecting federal science funding to political beliefs and biases, the Administration will ensure that only research it agrees with will be funded, and most likely less research being conducted and less money being spent.
FABBS will continue to monitor the fallout of this EO, including how federal agencies such as the National Science Foundation (NSF) and the National Institutes of Health (NIH) plan to implement it. According to the EO, until these new requirements are implemented in an agency’s grantmaking process, that agency cannot issue new funding solicitations; however, some agencies have indicated plans restrict all grantmaking in the meantime. FABBS is working with the broad science and health community to communicate our concerns about the EO and its consequences to Congress.
