Dear Mr. Reisig and Mr. Savary:

I write to express the concerns of Stanford University with the Office of Management and Budget’s notice of proposed rulemaking to revise the Guidance for Federal Financial Assistance.

Stanford’s mission is to educate undergraduate and graduate students and help train the future American workforce; to generate research, discoveries, and innovation – and then disseminate them widely for the benefit of humanity; and to deliver health care to the wider community. Our pursuit of this mission is rooted in an abiding commitment to ethics, integrity, and civic responsibility.

Stanford’s relationship with the federal government, particularly in the area of research, is longstanding, deep, and tremendously productive. For more than a century, federally funded research conducted at Stanford has led to breakthroughs that have improved human well-being and strengthened American competitiveness. Stanford discoveries launched the computer age in Silicon Valley, played a pivotal role in establishing the biotechnology industry, and developed key aspects of the science that underpins today’s artificial intelligence boom. The federal government’s close relationship with research universities like Stanford has enabled the United States to become the most innovative country in the world, with the strongest economy – a place where Americans thrive and live longer, more productive lives.

Stanford shares OMB’s commitment to responsible stewardship of federal dollars. This means ensuring that uses of extramural research support are transparent and subject to adequate oversight, but not burdened by unnecessary regulation. Stanford also welcomes the Administration's attention to the importance of rigor and reproducibility in research. Indeed, we are home to three centers dedicated to those goals: the Stanford Program on Research Rigor and Reproducibility (SPORR), the Meta-Research Innovation Center at Stanford (METRICS), and the Center for Open and Reproducible Science (CORES).

That said, we wish to register significant concerns with several components of the proposed rule. We believe they will have deleterious effects on university-based research, impede future generations of educators and researchers, and undermine American scientific leadership in the world. That is why we endorse the comments submitted by the American Council on Education, the Association of American Universities, the Association of American Medical Colleges, and COGR. We urge the Office of Management and Budget to reconsider this proposed rule.

The specific comments that follow address three parts of the proposed rule that are of greatest concern to the Stanford community – namely, the changes proposed to merit review of grant applications, grant termination procedures, and global collaboration.

Merit Review - §200.205

In President Trump’s Executive Order 14303 (Restoring Gold Standard Science), the “weight of scientific evidence” is defined as “an approach to scientific evaluation in which each piece of relevant information is considered based on its quality and relevance, and then transparently integrated with other relevant information to inform the scientific evaluation prior to making a judgment about the scientific evaluation. Quality and relevance determinations, at a minimum, should include consideration of study design, fitness for purpose, replicability, peer review, and transparency and reliability of data.” Stanford fully supports this approach to evaluating scientific rigor, and we believe the proposed rule’s process of pre-issuance review by political appointees, using non-scientific criteria, runs counter to it.

The proposed rule states that senior political appointees “must not ministerially ratify or routinely defer to the recommendations of others, but must instead use their independent judgment when evaluating Federal award proposals” (§200.205(c)); it also requires that discretionary awards “demonstrably advance the President's policy priorities” (§200.205(b)). In effect, this provision prioritizes the view of a political appointee, who cannot be an expert in all scientific domains, over a panel of scientists, who collectively possess expertise in multiple scientific domains that enables them to judge the quality and feasibility of a grant application.

Movement away from merit review as the presumptive determinant of scientific merit is a backward step. It threatens the partnership between the federal government, universities, and the private sector that has delivered innumerable returns to the national interest.

In the wake of World War II, the United States recognized an urgent need to be at the forefront of science and technology. It acted decisively and proceeded to build the world’s preeminent scientific enterprise. A foundational principle was that federal dollars should fund the best science, as determined through a competitive, merit-based process, with merit judged by independent scientific experts. Universities, for their part, recruited top talent and gave these researchers the freedom to explore their best ideas, seek external funding, and publish their results openly. The private sector then picked up promising discoveries from this work, developed them further, and took them out into the world. The economic benefits of this “virtuous cycle” for the United States have been widely documented: federal investments in science generate estimated returns of 140% to 210%; they have produced innovations such as the internet and GPS, and brought technologies to medicine, energy, and agriculture that have transformed these sectors¹.

Identifying the most promising scientific ideas at an early stage is challenging. Very often the link between research proposals and future economic and strategic applications is hard or even impossible to foresee. Many historical and contemporary examples demonstrate this.

• Google’s search algorithm was originally developed under a National Science Foundation-funded project on digital libraries. Although commercialization came quickly, none of the original grants explicitly focused on world wide web; there were less than a hundred web pages when the NSF project was conceptualized².
• Federal funding for cognitive research in the late 1970s and early 1980s led to the development of neural networks and backpropagation. These methods were later viewed as a dead end but now underpin modern artificial intelligence.
• Many of the tools that fuel modern biomedicine and cures have come from studies of the fundamental biology of bacteria: restriction enzymes, Taq polymerase, and CRISPR/Cas9 gene editing.
• The discoveries of RNA interference process and green fluorescent protein – each recognized with Nobel Prizes – originated from studies of animals that did not anticipate their profound implications for human health.
• Stanford materials scientists are currently developing hydrogels that are highly promising candidates to deliver long-lasting drugs for chronic conditions. An unexpected application already being tested is to more accurately deliver flame retardants in wildfire-prone areas.

By focusing on the quality, creativity, and originality of proposed scientific projects, scientists are best placed to assess both their immediate merit and their longer-term potential. Scientists have the domain knowledge necessary to assess whether a proposed methodology is sound, a hypothesis is novel, and a research team has the requisite expertise. Merit review also provides iterative feedback to applicants that improves the quality of project proposals – a benefit that disappears when authority for deciding merit shifts away from experts.

Political appointees can play an important role in the scientific enterprise. They can encourage research panels to be ambitious and take risks, and they can articulate broad directions for research that align with the nation’s strategic interests. However, they are not well positioned to substitute for expert review across vast areas of science. Moreover, political appointees frequently turn over with changes in Executive Branch leadership, which may lead to grant approvals to increasingly tracking partisan cycles rather than scientific merit.

In sum, the proposed rule would fundamentally alter the merit-based review system that has proven highly effective in allocating federal science funding. Through a competitive process, this system identifies the best science, including exciting research ideas with long time horizons and uncertain payoffs. To be sure, the current system is not perfect. For example, timelines can be long, established researchers and “sure bets” tend to fare better, and the most creative ideas are not always recognized and rewarded. The system has always undergone reforms to tackle shortcomings, and such incremental changes should continue. Nonetheless, the American system of merit review for federal research funding stands as the envy of the scientific world. Turning grant-making decisions over to political appointees who are charged with ensuring ideological alignment, rather than relying on scientific experts who are equipped to evaluate gold standard science, will harm American science. It would be a damaging departure from 80 years of bipartisan consensus.

Termination of Awards - §200.340

The proposed rule also places politics over merit review by introducing expanded and potentially unchecked authority to terminate federal awards. The rule broadens agency power to terminate any award that does not advance “program goals, Federal agency priorities, or the national interest as they exist at the time of the termination.” The explicit addition of “the national interest” and “at the time of termination” has troubling implications. It suggests that grants that were fully vetted at the outset through merit review, were appropriately awarded, are delivering on the approved scope of work, and are generating successful results may nonetheless be terminated midstream if the political landscape shifts.

In addition, the proposed rule contemplates that “a class of award,” not just individual grants, could be terminated at once. A new 90-day suspension authority (§200.340(e)) allows agencies to pause awards while considering termination. And procedural protections are minimal, as agencies need only provide a brief written summary of reasons and are not required to provide a detailed analysis, offer hearings, or allow formal appeals.

Taken together, these proposed changes put at risk the significant investments universities and researchers themselves make in reasonable reliance on the continued funding of a competitively won award. More generally, they weaken a trusted, reliable, and stable model of funding that has delivered immense benefits to society.

Stability through the life of a funded project is key to the scientific process; it is also critical for the biomedical and scientific training programs that produce the next generation of scientists for academia, industry, and business. A typical research grant involves execution of a multi-year plan. The laboratory or research group hires and trains the staff and students who form the study team; agreements and budgets with collaborating institutions and external vendors are set in place; necessary regulatory steps are undertaken (e.g., institutional review board approvals for studies involving human or animal subjects); and the step-by-step plan for fulfilling the project aims begins. The progress of students and trainees toward completing their degrees is typically tied to these steps. This is how scientific research and training unfolds in university labs.

The federal grant-making process has long provided the necessary stability to support these carefully planned investments of time, energy, and capital. At the outset, the federal agencies evaluate and award grants through well-established, nonpartisan, merit review processes with clear deadlines and timelines. These processes were developed and refined over decades and are well understood by the research community. Of course, competition for federal funding is usually fierce, and success for any application is never guaranteed. But once awarded, the steps described above begin. Grant terms of three to five years became the standard investigative period for many agencies for important reasons; researchers’ plans form around those known timelines.

Recent disruptions highlight how counterproductive instability in the life of a federally funded award can be. Prior to early 2025, terminations and suspensions of federal grants, other than for cause, were unprecedented. In 2025-26, thousands of NIH, DOE, and NSF scientific and biomedical research grants were terminated or suspended during their normal grant cycle. Affected grants experienced halts and disruptions to their scientific process, resulting in lost data, lost assays, lost ability to test study hypotheses, and in some cases, wasted taxpayer dollars on prematurely halted research studies.

Grant terminations and suspensions have had a particularly chilling effect on the staff, faculty, and trainees (including students) conducting the research. Nearly 40% of the initially terminated NIH grants in 2025 were research training and career development awards, constituting over $500 million in lost funding for trainees across the country.

Codifying the ability of a new administration to terminate and suspend grants will greatly limit universities’ capacity to effectively recruit, train, and retain the next generation of scientists and technicians – essentially, tomorrow’s workforce in biotechnology, artificial intelligence, energy, and other critical, innovation-driven industries in the United States. It is important to recognize that the negative impacts of instability stem as much from uncertainty in the shadow of termination and suspension possibilities as it does from termination and suspension actions themselves. If continued over the medium-to-long term, such uncertainty can be expected to lead trainees, staff, and faculty to leave university laboratories, weakening the future of the American economy in these critical industries.

Global Collaboration - §200.202(e) and §200.220

International partnerships and collaborations have long been a source of scientific strength for the U.S. research enterprise. American scientific leadership has depended on the ability of our universities and researchers to engage with and learn from scientists around the world. U.S. researchers have expanded the cutting edge of American innovation through global collaboration, not in spite of it. For example, an international team led by Stanford researchers discovered a gene that, when mutated, increases insulin resistance – a major step forward in understanding the genetic basis of type 2 diabetes. The work emerged from the GENESIS consortium, an international collaboration launched by Stanford and funded by NIH, the European Union, and Taiwan.

Stanford recognizes that international research collaborations do not exist in a geopolitical vacuum. They may entail risks. Stanford fully supports efforts to address legitimate national security concerns arising from foreign collaborations. We applaud the Executive Branch taking seriously its responsibility to protect the integrity of federally funded research. And we share the government’s commitment to safeguarding American national security interests against espionage and intellectual property theft.

To protect the integrity of its research and guard against risks posed by malicious foreign actors, Stanford has implemented a variety of policies and practices. The university’s Research Security team (part of the Office of the Vice Provost and Dean of Research) leads these efforts, working closely with federal funding agencies to identify and mitigate risks of undue foreign influence. This includes supporting the agencies’ national security risk assessments, and when appropriate, implementing robust research security risk mitigation plans. In addition, Stanford has been a leader in studying and developing best practices to address undue foreign influence – on our campus and across the country – through ongoing research based at the Hoover Institution.

The protections in place at both the federal and university levels demonstrate that robust research security and international collaboration can successfully coexist. It is vital that federal policies balance national security concerns with the free exchange of knowledge and ideas that has long underpinned U.S. scientific and technological leadership.

The “domestic-first” framework set forth in the proposed rule disincentivizes working with foreign collaborators, including collaborators from allied nations. Under the framework, international collaboration is treated as an exception that must be justified, not as the essential component of successful federally funded research it so frequently is (§200.202(e)). The proposed rule also indiscriminately bans international engagement with covered foreign countries and entities (§200.220). These provisions do not appear to weigh or balance the negative impact of such sweeping policies, nor contemplate less disruptive alternatives. As such, they are at odds with approaches and requirements set forth in existing federal statutes and regulations.

If codified in a final rule, the changes proposed in these provisions will have negative impacts on the advancement of American science in critical fields of study, ranging from biomedical research to artificial intelligence. Americans benefit from international research collaborations, including some with Chinese collaborators (with appropriate safeguards). Broad prohibitions on international collaborations will sever important scientific relationships with talented researchers at foreign institutions who do not pose genuine security threats – an outcome that will ultimately undermine U.S. competitiveness.

In sum, Stanford understands and supports the need to prohibit certain types of interactions with foreign entities; our national security requires it. However, these prohibitions should be targeted, appropriately scoped, and applied in ways that do not inadvertently subvert beneficial scientific exchange. Stanford urges that any policy or prohibition related to limiting foreign collaborations be narrowly tailored and accompanied by clear definitions that align with current federal statutes (P.L. 117-167). We also request greater clarity: universities like ours need clear guidance to meet our compliance obligations without disrupting valuable research unnecessarily.

Multiple components of the proposed rule would move the federal research enterprise away from a focus on scientific merit and toward deference to political considerations of the day. The most troubling components are political influence over merit review, expanded authority to terminate or suspend awards already in progress, and unwarranted barriers to international collaboration. Each of these changes risks undermining U.S. global scientific leadership and disrupting the kind of long-term, high-risk research that leads to major discoveries across all fields of science and technology.

The concerns raised in this letter reflect a desire to buffer science from shifting political winds. In prior administrations, some federally funded programs drifted toward ideological capture, and legitimate questions about accountability are important for any administration to raise. The social contract underlying American scientific discovery does not belong to any political party, and the merit review system was designed in part to shield science from political changes in either direction.

Stanford believes the shared goal across the political spectrum should remain a federal science enterprise that is rigorous and accountable, where the best ideas win funding on their scientific merits, and where the next generation of American scientists and trainees has every reason to stay, build, and discover in the United States.

Sincerely,

David M. Studdert
Vice Provost and Dean of Research
Stanford University