Statement on Proposed NIH Funding Cuts FY2026

June 7, 2025

Dear ASRI Community,

ASRI members work tirelessly to advance reproductive immunology and improve the health of American women and men so that they can build healthy families and have healthy babies. Federal support for biomedical research has been essential to progress in pregnancy research, maternal–fetal health, infertility, infection, inflammation, immune tolerance, and reproductive health across the lifespan.

The White House Office of Management and Budget has released a proposed rule that would revise federal grantmaking policies across agencies, including those that support NIH-funded research. ASRI is reviewing the proposal closely because several provisions could affect how research is reviewed, funded, shared, and supported, including support for trainees, scientific meetings, publications, collaborations, and research infrastructure. See below for details.

Reproductive immunology is a field built on collaboration across disciplines, institutions, countries, and communities. Policies that shape federal research funding directly affect our ability to train the next generation, share discoveries, and advance reproductive, maternal, fetal, and infant health. Ultimately, they affect our ability to improve the health of American families and support the birth of healthy babies.

What are the implications for ASRI members?Much of the important research by reproductive immunologists seeks solutions to significant problems in human reproduction such as infertility, pregnancy complications, congenital and hereditary disorders, and the development origins of health and disease. These challenges impact people world-wide and disproportionately impact vulnerable, marginalized, and economically disadvantaged populations.  Our work clearly benefits from transdisciplinary and international collaborations;  our community of investigators is global. The proposed changes are likely to slow scientific progress and stifle innovation.

To this end, the ASRI Outreach and Engagement Committee has highlighted the following ASRI Advocacy and Action Priorities:

Protecting reproductive and maternal–fetal health research: ASRI will emphasize that federal research funding is essential to advancing reproductive immunology, infertility research, pregnancy health, fetal and infant outcomes, and the ability of American women and men to have healthy babies.

Defending rigorous, merit-based peer review:ASRI will oppose changes that could weaken scientific peer review, introduce unclear or non-scientific criteria into funding decisions, or reduce confidence in the fairness and quality of federal research grantmaking.

Supporting the research infrastructure that science depends on: ASRI will highlight the importance of supporting trainees, early-career investigators, scientific meetings, publications, collaborations, and the institutional infrastructure needed to conduct high-quality biomedical research.

Supporting scientific collaboration and exchange: ASRI will stress that reproductive immunology is inherently interdisciplinary and international, and that policies should strengthen—not restrict—responsible collaboration, data sharing, and scientific communication.

Mobilizing the ASRI community: ASRI will prepare an organizational comment reflecting the concerns of our members. We hope you will take a few moments to review the proposed rule and share your perspective with ASRI and undersign by June 20th, 2026, so that your voice can help shape our organizational comment on behalf of the reproductive immunology community.

We also encourage ASRI members to consider submitting an individual public comment by July 13, 2026.

SUBMIT YOUR COMMENT: https://www.regulations.gov/commenton/OMB-2026-0034-0001

Comments can be brief. A few sentences explaining how the proposed changes could affect your research, trainees, collaborations, institution, patients, or scientific community can be meaningful. Personalized comments are especially valuable.

When submitting a comment, please remember:

• Submit through the official regulations.gov portal under docket OMB-2026-0034.
• Begin each comment with the relevant section number in brackets, for example: [200.414].
• If using your title, institutional affiliation, or institutional email address, please follow your institution’s policies and clarify, when appropriate, that you are commenting as an individual scientist.

Respectfully,

Anna M Powell, MD MSCR and Liza Konnikova, MD PhD

ASRI Outreach and Engagement Committee

Indira Mysorekar, PhD, President, ASRI

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Below are detailed points about the proposed changes that could have significant negative consequences include but are not limited to:

1. Required review by political appointees (§200.205): OMB proposes revising section 200.205 to codify the August 7, 2025 Executive Order on Improving Oversight of Federal Grantmaking, including requiring senior political appointees to review awards prior to issuance for “ensuring that discretionary awards advance the President’s policy priorities, prohibit the use of funds for discriminatory or otherwise impermissible purposes, and emphasize ensuring compliance with applicable law.”
2. Ability to cancel grants at any time, for any reason (§200.340): The proposal explicitly expands and clarifies agencies' ability to terminate discretionary awards that are no longer considered aligned with agency priorities or are no longer viewed as being in the government's interest. Multiple federal courts have scrutinized grant cancellation efforts in 2025, including NIH research grant terminations and other federal assistance programs. In several cases, judges found that agencies had failed to provide adequate justification, conduct individualized review, or follow established administrative procedures before terminating previously awarded funding [see: Massachusetts v. Kennedy, 2025; Individual NIH termination appeals (Boston College, Rice University, University of Hartford, St. Mary's); EPA grant cancellation litigation Judge slams EPA’s climate grant cancellations: ‘You have to have some kind of evidence’ - POLITICO]
3. Disruption of the Peer-Review process (§200.205(d)): The proposal also reinforces that the role of peer review is advisory relative to agency decision-making: “Peer review remains advisory and does not replace agency discretion.”
4. “Gold Standard Science” without a defined standard (§200.205): The rule invokes the concept of “Gold Standard Science” which was first issued with Executive Order 14303 on May 23, 2025 without a clear or measurable definition. However, under the proposed rule changes, all grants but include benchmarks for complying with the Standard, agencies must prioritize institutions that have “demonstrated success in implementing Gold Standard Science”, and compliance with this standard is prioritized over institutional prestige and historical reputation.
5. New restrictions and justification requirements for international research: The proposed rule establishes a "domestic-first" framework for research funding, requiring additional justification for international collaborations and research activities conducted outside the United States. While intended to prioritize domestic research capacity, these requirements may create additional administrative hurdles for global research partnerships that are essential for studying infectious diseases, maternal health, and other conditions that disproportionately affect populations worldwide.
6. Changes to award selection criteria: The proposed rule encourages agencies to prioritize institutions demonstrating "rigorous and reproducible scholarship," adherence to "Gold Standard Science," and strong commitments to research integrity. While these goals are broadly supported, the lack of clear definitions and implementation standards may introduce uncertainty into grant review and funding decisions.
7. Expanded conflict-of-interest disclosures: Recipients would be required to disclose whether employees involved in preparing or conducting a project were employed by the awarding federal agency within the previous two years. Although intended to enhance transparency, this requirement may create additional administrative reporting obligations for investigators and institutions.
8. Increased mandatory disclosure and referral requirements: The proposal would require agency Offices of Inspector General to transmit mandatory disclosures to the U.S. Attorney's Office within ten days of receipt. Institutions may respond by increasing internal compliance reviews and legal oversight, potentially adding complexity to grant administration.
9. Elimination of fixed-amount awards: The proposed rule would largely eliminate fixed-amount awards and subawards, citing concerns regarding transparency and oversight. This change could increase administrative and financial reporting requirements for smaller projects, pilot studies, and early-stage translational research.
10. Expanded subaward reporting and monitoring: The proposal places greater emphasis on tracking and monitoring subawards, including relationships with affiliated entities and collaborators. Multi-institutional and international research programs may face additional reporting, oversight, and compliance requirements as a result.
11. Expanded payment documentation requirements: Federal agencies and pass-through entities would be encouraged to exercise greater diligence before issuing payments, including requiring additional justification for payment requests. These changes could increase administrative workload and potentially delay funding disbursement for active research projects.
12. Requirement to categorize research awards: Federal agencies would be required to classify awards as basic research, applied research, or experimental development and communicate these classifications to recipients. While intended to improve transparency, this requirement may introduce additional administrative processes and classification challenges for multidisciplinary research projects.
13. Changes to allowable costs, including publications: OMB proposes a number of specific revisions to prohibit or put limitations on allowable costs for a wide range of activities, including public relations, advocacy, lobbying, conference attendance, and professional memberships and subscriptions. The Rule also proposes “to make publication costs unallowable unless such costs are expressly required by statute or approved in advance by the Federal agency on a case-by-case basis.”
14. Codification of multi-year awards: The proposed rule encourages federal agencies to use multi-year awards with longer budget periods rather than issuing separate annual funding opportunities. While this approach may reduce administrative burden and improve funding stability, it could also reduce the frequency of funding competitions and opportunities for new investigators to enter the federal research portfolio. This has been reflected in a significantly reduced number of Notices of Funding Opportunities (NOFOs) issued: since January 2025, only 84 NOFOs have been issued compared to 787 from 2024, representing a 89% reduction [Kaiser J].
15. Further hits on women’s health research.  Women's health research has historically received disproportionately less federal funding relative to disease burden, making the field particularly vulnerable to reductions in available research support.

Why should you care: The proposed rulecodifies a number of policies already being implemented across federal agencies by the Administration without congressional approval or oversight, making it not only more difficult to obtain grants due to NIH budget cuts (the 2027 budget proposes a $5 billion reduction to NIH), but easier for Agencies to terminate awards, giving the administration final say over what constitutes research priorities, and essentially creating an unfunded mandate where institutions will be required to conduct more oversight of research with fewer resources than before.

The proposed changes will stifle scientific communication if enacted. The proposed restrictions on allowable costs raise concerns regarding scientific meetings and professional conferences. Rather than broadly limiting conference-related expenditures, OMB should first evaluate the actual proportion of federal grant funds used for conference attendance, the number of investigators supported, and the costs associated with these activities. Scientific conferences are a critical mechanism for disseminating findings, establishing collaborations, mentoring trainees, and accelerating scientific progress. Policies intended to reduce waste should be guided by data demonstrating that conference-related expenditures represent a significant source of inefficiency within the federal research enterprise.

Publication costs rule changes conflict with federal open-access policy. The proposed revision to §200.461, which would make publication costs unallowable unless specifically required by statute or approved on a case-by-case basis, appears to conflict directly with existing federal open-access requirements. In 2022, the Office of Science and Technology Policy (OSTP) directed federal agencies to ensure immediate public access to federally funded research publications and supporting data. Because compliance with these policies frequently requires payment of article processing charges and other publication-related expenses, OMB should explicitly reconcile this conflict before finalizing the rule. Investigators should not be placed in the position of being required to publish their findings in compliance with federal policy while simultaneously being prohibited from using federal funds to cover the costs necessary to do so.

Peer review is the benchmark for scientific advancement and U.S. scientific leadership. The proposed rule also risks weakening the role of peer review, which has served as the foundation of U.S. scientific leadership since the post-World War II era. Following publication of Vannevar Bush's landmark 1945 report, Science, The Endless Frontier, federal research funding was deliberately structured around independent scientific peer review rather than political review, allowing funding decisions to be guided primarily by scientific merit, innovation, and public benefit. This framework helped establish the United States as the global leader in biomedical research, technological innovation, and scientific discovery for more than seventy years. Any policy that shifts authority away from independent expert review toward political review should be scrutinized for its potential impact on scientific excellence and public trust. More broadly, the proposed rule would shift resources away from the generation, dissemination, and translation of scientific knowledge and toward compliance activities, despite little evidence that these activities represent a major source of waste within the federally funded research enterprise.

While each individual provision may appear modest or incremental, their cumulative effect will shift investigator effort away from scientific discovery and patient-centered research toward burdensome compliance activities. Clinical investigators already face substantial administrative burdens related to IRB review, human subjects’ protections, conflict-of-interest disclosures, financial reporting, effort certification, and regulatory oversight. The proposed changes risk creating additional layers of grant administration that may disproportionately affect early-stage investigators, multicenter clinical studies, and international collaborations that are essential to advancing women's health research.

Additionally, if the regulatory requirements expand while research teams and universities are not allowed to account for the substantial cost of institutional infrastructure, research institutions may face growing unfunded compliance obligations. Over time, this could reduce institutional willingness to sponsor complex clinical and translational research, particularly in lower-margin areas such as women's health, pregnancy research, infectious diseases, and early-career investigator development. The result may be fewer studies conducted, slower scientific progress, and a diminished return on federal research investments.

In academic medicine, investigators often lead multiple grants that support distinct but interconnected activities, including clinical cohorts, biorepositories, translational research, training programs, and multicenter collaborations. Limiting the number of grants per investigator could further fragment successful research programs, reduce opportunities for trainees, and slow the translation of scientific discoveries into improvements in patient care, and be particularly devastating to those who rely primarily on grant funding for salary support.

Increased transparency, fraud prevention, conflict-of-interest monitoring, and responsible stewardship of taxpayer dollars are important goals. However, scientific discovery depends on investigator independence, long-term funding stability, international collaboration, and the freedom to study important public health problems—including those that involve women, pregnancy, minorities, and infectious diseases. Policies that overtly politicize scientific priorities or create barriers to collaboration could slow biomedical innovation and disproportionately affect historically underfunded areas such as women's health research.

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Other articles of interest:

U.S. science must innovate or die, National Academy of Sciences president says | Scientific American

Misguided Brushes of a Pen Continue to Dismantle and Destroy Biomedical Research in the United States: We Can No Longer Afford Complacency and Fear. We Must All Act Now! | Diabetes Care | American Diabetes Association

REFERENCES:

Deborah Carr, OMB Releases Proposed Revision of Regulation for Federal Research Funding | Center for Innovation in Social Science

John Timmer, Proposed new US funding rules: We can cancel any grant at any time. 5/29/2026. Ars Technica.

Office of Management and Budget. Budget of the United States Government, Fiscal Year 2027.

Washington, DC, U.S. Government Publishing Office, 2026

Kaiser J. Delays in awards and funding calls worry NIH-funded researchers. 

Science, 3 March 2026. Accessed 7 June 2026. Available from Link to Delays in awards and funding calls worry NIH-funded researchershttps://www.science.org/content/article/delays-grant-awards-and-funding-calls-worry-nih-researchers

Summary of Key Changes in OMB’s Proposed Federal Financial Assistance Rule