The Society for Pediatric Research Organizational Comment on OMB Proposed Rule
Docket OMB-2026-0034
July 9, 2026
The Honorable Russell Vought
Director
Office of Management and Budget
The White House
Washington, DC 20500
Re: Regulation for Federal Financial Assistance, Docket OMB-2026-0034
Dear Director Vought:
We write today to provide an organizational comment on the Office and Management Budget’s proposed rule [OMB-2026-0034-001], also titled Regulation for Federal Financial Assistance, on behalf of the Society for Pediatric Research, a membership organization made up of more than 4,000 pediatric researchers across the United States and Canada, primarily.
While we appreciate the OMB’s stated interest in “improving transparency, accountability and oversight for how taxpayer dollars are used in the context of Federal grantmaking”, we are also concerned with several provisions included within the proposed rule that will harm the leading research enterprise in the world. Additionally, while the stated goal is to increase transparency, most changes (e.g., alignment with administrative priorities versus scientific merit evaluation) would almost certainly reduce transparency and make the scientific grant review process
susceptible to political ideology rather than unbiased scientific discovery. Overall, the Proposed Rule appears to be an effort to greatly expand regulatory oversight of federal research without providing sufficient justification for expanded regulation.
Our focus is on the following provisions:
[§200.205] FEDERAL AGENCY REVIEW OF MERIT OF PROPOSALS
SPR’s concerns in this area primarily focus on the portion of the section that states revisions “clarify that peer review remains advisory and does not replace agency discretion”. For many decades, peer review and basing the success or failure of a grant proposal only on the science, reviewed by fellow scientific experts, has been an approach that has served the United States well. Peer-review led investment in research has brought us the scientific exploration and efforts that have allowed more than 80% of kids with cancer to survive, virtually cured cystic fibrosis, spinal muscular atrophy, sickle cell disease, beta thalassemia, and many additional scientific breakthroughs with clinical impact (“Seven great achievements in pediatric research in the past 40 y”; https://www.nature.com/articles/pr201695). In fact, many SPR members serve on NIH Study Sections where they leverage their expertise and spend significant time and energy to highlight and choose which grant proposals have the best chance at success to make meaningful impacts on behalf of the American people for the children and adolescents who will be impacted by these
projects. While we concede that peer review has always been “advisory”, the final decisions of what to fund have been made by a NIH Council, which is mostly made up of scientists, providing funding to programs other scientists have deemed the strongest of what has been submitted. We are very concerned with the potential that in the future, even though the peer review process will still identify these outstanding scientific proposals, decisions will be deferred to an unelected, non scientist to make a decision perhaps based on where a grant applicant lives, whether their institution has a high indirect cost rate, or other non-scientific determination.
[§200.340] TERMINATION AND SUSPENSION
Discovery sometimes happens when we least expect it. There are many examples of research that has been focused on one area that has helped solve another issue. For example, investigation in adult cancer treatments has been assessed and successfully adapted to pediatric cancers like osteosarcoma and medulloblastoma, creating more opportunities for successful treatment and longer survivorship. Additionally, research in anti-malarials like hydroxychloroquine has allowed them to commonly be used in treating rheumatoid disease. This is at the crux of this provision in the proposed rule – research isn’t linear and sometimes the end result isn’t what was expected, but taking the opportunity away from researchers to complete their work using broad and undefined language and terms such as “national interest” or “public interest” (which often shift regularly) sets us up for abuse in the future. When a researcher has been provided funds from the American taxpayers, after a rigorous and exhaustive process, they deserve to have certainty that they will be able to complete their work in an unencumbered way without constant fear of losing their funding at any time if someone may not like the work they’re doing or the results they are seeing. That remains true regardless of which political party holds power.
This certainty, within the reporting guidelines and parameters set by the NIH, is imperative for researchers and their institutions to invest in the people, the equipment, and the other necessary
resources to conduct the world-class research that has happened in the United States for decades. In pediatric research, these investments happen across the country. Additionally, there is significant waste in truncating ongoing research prior to completion since even negative studies
provide considerable meaningful information to scientists and clinicians as we strive to improve child health.
Ensuring the continued health of our children is something we should all be able to agree on, and continued certainty in researchers’ ability to do their work without constant concern about interference and termination of their funding is imperative to that continuing to happen.
[§200.432, §200.461, §200.421] RESTRICTIONS ON USE OF FUNDS
These sections largely impose restrictions on using funds for communicating research results including publication costs, attendance at conferences, and even public communication. This effort runs counter to the goals of federally funded (as opposed to privately funded) research, which is to enter the data into the public domain. This will limit interaction of federally funded investigators, diminishing the necessary dissemination (i.e., presentations and conversations) that lead to new lines of investigation that advance scientific discoveries.
[§200.206] FEDERAL AGENCY REVIEW OF RISK POSEDS BY APPLICANTS
This section allows disqualification of applicants based on undefined professional affiliations which reduces transparency. Specifically, failing to define what constitutes an organization that is engaged in activities that “undermine public safety” allows an administration-regardless of political party- to target specific organizations who are not looked upon favorably. This approach
appears capricious and could directly impact members of professional societies such as the Society for Pediatric Research.
We appreciate the chance to provide this input and welcome any questions or discussions you may be interested in having. We hope you will reconsider this proposed rule and consider the many
wide-ranging implications it will have on the future of our research enterprise, our country, and ultimately the health of our children.
Sincerely,
The Society for Pediatric Research® Council
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About the Society for Pediatric Research
The Society for Pediatric Research® (SPR) encourages and supports pediatric research endeavors by cultivating a diverse network of child health researchers through collaboration, community, mentorship, and advocacy. Collaboration among SPR members creates meaningful progress for the future of children’s health. For more information, please visit www.societyforpediatricresearch.org, and follow us on LinkedIn, Bluesky, and X.
