The Trump Administration's Existential Threat to Scientific Research

You want a request for comment?! I got your comment right here.

Photo by Julia Koblitz on Unsplash

In my Carnegie paper about the future of American network power, I warn about the the administration’s threats to the U.S. lead in scientific and technological research:

For example, one reason the United States has remained the epicenter of critical science and technology innovation networks is… the preeminence of U.S. higher education in the research ecosystem. The current administration’s immigration and research policies, however, are sapping that strength. In the fall of 2025, international student enrollment had declined by 17 percent; the decline in international graduate students was even higher, estimated to be 24 percent. At the same time, international enrollments in European and East Asian universities have increased. If critical masses of global talent establish bases of operation in other countries, the structural power of the United States in this area risks collapse.

Last month the administration released a sneak preview of another frontal assault on American research excellence, all under the innocuous-sounding plan to “revise the Guidance for Federal Financial Assistance to improve government-wide policies and requirements related to the management of grants, cooperative agreements, and other forms of assistance.”¹

Even a quick scan of the proposed regulation rewrite, however, reveals where this administration is coming from. It claims that, “Federal awards were often used during [the Biden] years to promote a ‘woke’ policy agenda that did not reflect the values of the vast majority of the American public” and “far-left activists hijacked the critical work done by the U.S. President's Emergency Plan for AIDS Relief (PEPFAR), which was established to respond to the AIDS crisis in Africa. Due to wasteful spending, PEPFAR became a left-wing foreign aid entitlement that attempted to promote abortion and gender ideology.” The latter claim relies on a Heritage Foundation argument that the hard-working staff here at Drezner’s World called bullshit on about three years ago.

Former NIH official Elizabeth Ginexi looked at the rule and immediately fired off a flare demonstrating how drastic the proposed change would be:

The rule explicitly states that peer review recommendations “remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding.” This directly dismantles the post-WWII system used by NIH, NSF, DOE, NASA, and nearly every science agency, in which independent expert peer review was the primary measure of scientific merit. Under this rule, a political appointee can simply override the scientific community’s judgment with no finding of cause.

The New York Times’ Tony Romm provides a clean summary of the OMB proposal:

Mr. Trump’s ambitions were made clear in a roughly 400-page blueprint that was released to little fanfare on Friday. If finalized, it would require all federal grants to be approved by the president’s political appointees, who must ensure that the money would “demonstrably advance the president’s policy priorities.”

For the agencies that issue those awards and the nonprofit groups, local governments, universities and other entities that receive the money, the Trump administration would also impose a set of highly prescriptive and political criteria….

Many researchers expressed particular alarm about the implications for their work, citing the risks in having political appointees, not subject-matter experts, deciding the merit of scientific pursuits.

“It means that all grants, not just science grants, are now subject to the rules that are defined by the White House, rather than by a technical agency,” said Cole Donovan, the director of science policy and advocacy at Stand Up for Science, a group that supports federal research spending. He previously served as an international technology adviser in the Biden administration….

“This is a major escalation in the Trump administration’s war on science and its efforts to choke off funding to whatever communities Trump decides to target,” said Senator Patty Murray, Democrat of Washington, who leads her party on the Senate Appropriations Committee. She added in a statement that “Republicans should work with Democrats to stop this rule in its tracks.”

Marginal Revolution’s Alex Tabarrok expands on the real dangers of this proposed wholesale rewrite of federal grant-making:

American science has long been state funded but not state directed. Since Vannevar Bush, money has flowed through many agencies to independent universities, allocated largely by peer review. The system has flaws—conformity, gerontocracy, waste—but it had one great virtue, the system was decentralized and not under state control. This rule proposes to bring science funding under top-down, state control.

Program goals must now be “aligned with administration policies and priorities” (§ 200.202). Merit review is subordinated to politics: “senior appointees must conduct these reviews,” ensuring “that discretionary awards advance the President’s policy priorities,” while “peer review remains advisory and does not replace agency discretion” (§ 200.205). And every grant becomes terminable at will, whenever it “no longer effectuates program goals, Federal agency priorities, or the national interest *as they exist at the time of the termination*” (§ 200.340, emphasis added). Universities must even ensure their subrecipients don’t “significantly damage the reputation of… the Federal Government” (§ 200.332)—a loyalty clause for scientists.

All this is sold as cutting “burdensome conditions,” a goal I would support, but sadly that is bullshit. The proposed rules add more paperwork and many more layers of bureaucratic review. Payment requests must include written justifications. Every disbursement gets screened through Treasury’s “Do Not Pay” system. Every recipient must run E-Verify. Applicants must disclose any employee who worked at the awarding agency within two years. And on top of the existing review machinery sits a new pre-issuance review committee of “senior appointees” second-guessing the experts. Fixed amount awards—pay for outputs, not inputs—an innovative reward mechanism are *eliminated*, so every award now gets routine cost monitoring and financial reporting.

Political review of every award, peer review demoted, agency review promoted, termination whenever “priorities” change. Chilling. It’s a nightmare of petty low-trust review of the kind that is already drowning science. I must deal with this kind of nonsense all the time. More is not better.

The machinery is centralized too. OMB’s guidance becomes binding regulation, effective government-wide with no agency rulemaking. One dial in the White House now turns every grant program in the country.

The new rules will be sold as getting rid of DEI but that is an excuse to bring in the commissars. The new rules don’t depoliticize science they create even more politicization with the sign flipped, and the drafters admit it.

Yeah, if I was trying to ruin American leadership in scientific research this is pretty much the kind of rule I would write. Furthermore, the very act of issuing the rule and requesting comments means this is a more substantive shift than just another executive order. OMB Director Russel Vought’s goal here is a permanent shift in how funding is allocated. And I’d expect him to supervise this about as well as he supervised DOGE.

So is this a done deal? Not necessarily.

Inside Higher Ed’s Ryan Quinn explains that in requesting comments — which is required for this kind of proposed rule change — the administration is getting more than is bargained for:

Through social media, video calls, Substacks and petitions, scientists, universities and groups representing them have called for a flood of public comments. They’ve shared resources listing objectionable provisions they’ve identified in the more than 400-page proposal. They’ve provided online guides to the public on how to write comments pushing back on specific changes that would affect them.

The input might lead the White House to alter its proposal. But, even if that doesn’t happen, opponents say the comments could still slow implementation of the changes because the OMB must reply to them. And a monsoon could persuade Congress, which has repeatedly rejected Trump’s previous proposals to gut research funding, to use its power to stop these changes.

Comments also put into the public record objections that, if the government doesn’t address them, could be raised again in lawsuits to stop the changes.

The deluge opponents have called for has arrived: The proposal has already received roughly 90,000 public comments, and the comment period isn’t over until July 13….

LinkedIn has been a major forum for discussion of and pushback against the proposal. “Continue to flood the zone!!” Logan Spector, a University of Minnesota–Twin Cities pediatrics professor, wrote on the site last month.

Prestigious scientific journals are also speaking out in editorials.

“The scientific community needs to flood OMB with responses during the public comment period,” Holden Thorp wrote in Science, of which he’s editor in chief. He added that “universities and associations must speak out as a united front to mobilize Congress and be ready to file lawsuits once the regulations are finalized.”

“The red light is now flashing,” he wrote. “All hands, report to stations.”

The New England Journal of Medicine compared the proposal to Lysenkoism, when the U.S.S.R.’s political rejection of genetics set the country back in agriculture and other areas.

One of the genuine difficulties with observing the second Trump term is that the assault on state capacity and impartiality has been so multipronged that it is difficult to keep track of everything going on. But these proposed rule changes are monumental and catastrophic. Unfortunately, “monumental and catastrophic” are the perfect adjectives to describe what Trump will bequeath his successor, as well as the rest of us.

1. In this newsletter I’m going to be focusing on the threats to the federal funding of scientific research but it should be noted that the implications of this rewrite extend to almost every federal grant made to state and local authorities.