for Fiscal Years 2027–2031
NOT-OD-26-047 | Submitted to the National Institutes of Health | May 2026
Introduction
New York Academy of Medicine submits these comments in response to the NIH’s Request for Information (NOT-OD-26-047)[1] inviting public feedback on the proposed Framework for the NIH-Wide Strategic Plan for FY2027–31. We support the NIH’s mission that no other sector (public or private) can replicate at scale, and offer the following recommendations to strengthen an essential agency that is central to sustaining a strong US biomedical research enterprise[2], and in the spirit of strengthening an agency that is vital to American health, economic, and scientific leadership.
Priority 1: Research Areas (Goal 2: Prevent Disease and Promote Health Across the Lifespan)
Accelerating Lifespan-Aware Research Through a Healthspan Framework
New York Academy of Medicine supports NIH’s focus on research across the lifespan and encourages the agency to accelerate this work by formally adopting “healthspan” (defined as the years of life spent in good health, reducing chronic disease and disability impact) as a guiding metric alongside lifespan. This distinction has direct implications for how research is designed and what it measures. Recent analyses using World Health Organization Global Health Observatory data estimate a global mean healthspan-lifespan gap of 9.6 years based on 2019 WHO Global Health Observatory data, indicating that many people live a substantial portion of later life with disease or disability. The healthspan-lifespan gap for the United States is 12.4 years – the largest of any of the 183 countries included in the study.[3]
A growing body of research, including the expanded framework of the hallmarks of aging (Cell, 2023),[4] supports a systems-based approach targeting the underlying biology of aging rather than treating each age-related condition in isolation. This approach would align well with the Administration’s priorities around chronic disease and prevention.
Recommendation: Explicitly adopt “healthspan” as a measurable outcome in Priority 1 research goals and prioritize cross-Institute research that tracks years of healthy life, not merely longevity.
The Question of NIH’s Organizational Architecture
Stakeholders have raised questions about whether NIH’s current organ-system structure best supports cross-cutting, whole-person science in the 21st century. Some proposals, including congressional frameworks,[5] call for stronger coordination and a lifecourse approach that reduces silos. New York Academy of Medicine takes no position on optimal number of Institutes and Centers, although we do urge NIH to use the FY27–31 Strategic Plan to specify how it will prioritize and resource cross-Institute collaboration, regardless of how internal structures evolve. Moreover, we affirm the value of systems science and community-engaged research methodologies to strengthen health science discovery and translation, which is a key driver for the US economy.
Emerging Science: Research on Climate-Related Health Impacts
We also encourage NIH to retain explicit attention to climate-related health risks that are shaping population health and healthcare outcomes and costs now, and that will accelerate in the coming decades. NIH’s Climate Change and Health Strategic Framework outlines research needs across health effects, interventions, training, and communities facing disproportionate climate burdens.[6]
Priority 2: Research Capacity (Goal 1: Develop, Sustain Interdisciplinary Research Workforce)
Protecting the Interdisciplinary Health Research Workforce
NIH’s goal of developing and sustaining an interdisciplinary research workforce is directly challenged by Department of Education’s final rule narrowing the definition of “professional degree programs” eligible for certain forms of federal student aid to a limited set of fields.[7] The finalized list excludes nursing, public health, and allied health disciplines that are essential to biomedical research, clinical translation, prevention science, and community-based implementation. New York Academy of Medicine strongly disagrees with this policy determination and is concerned about its downstream effects on the education and research pipeline.
The implications are not theoretical. In 2022 alone, 78,191 qualified applications were turned away from US nursing schools due largely to faculty and training constraints.[8] In addition, CDC survey data show that 44% of governmental public health workers consider leaving their jobs in the next five years.[9] Eroding the health professions pipeline at the education stage would directly undermine NIH’s workforce capacity goals at precisely the moment the nation faces a nursing shortage, a depleted public health workforce, aging populations, and growing chronic disease burden.
Recommendation: NIH should formally assess and publicly document how the Department of Education’s finalized professional degree designation constrains the biomedical and health research workforce pipeline. NIH should engage the Department of Education, the Office of Science and Technology Policy, and Congress to mitigate these impacts, preserve access to training in nursing, public health, and allied health fields, and ensure that federal education policy aligns with federal research and health priorities.
Priority 3: Research Operations (Goal 1: Enhance Scientific Stewardship & Decision-Making)
The Economic Case for Sustained NIH Funding
The current funding environment warrants direct attention. According to AAMC, NIH had obligated $5.8 billion in research grants by March 20, 2026, which is 34% below the same point in FY2024.[10] These are not abstract numbers. NIH-sponsored research underpinned all 356 FDA-approved drugs between 2010 and 2019,[11] and the downstream economic and health returns are substantial.
A synthesis of 34 studies by The Pew Charitable Trusts found that every dollar invested in public health interventions saves approximately $14 in medical and societal costs.[12] While many return-on-investment estimates reflect downstream public health programs, NIH’s role is foundational because NIH-funded research enables the evidence base that makes prevention and treatment advances possible at scale. Childhood vaccination programs alone have saved an estimated $540 billion in direct medical costs and $2.7 trillion in broader social costs over 30 years. Reducing NIH investment does not save money; it defers and amplifies costs.
Recommendation: The FY27–31 Strategic Plan should make an explicit, evidence-based case for sustained and stable research funding, articulating the downstream health and economic returns that NIH investment generates for every state and community in the nation.
Conclusion
The NIH’s FY27–2031 Strategic Plan is an opportunity to reaffirm the agency’s foundational commitment to science in service of human health. New York Academy of Medicine urges NIH to:
- Adopt healthspan as a core research framework and metric and accelerate cross-Institute work on the biology and social determinants of healthy aging.
- Articulate a systems-oriented research vision that transcends organ-system silos and advances whole-person and population level health approaches.
- Defend the interdisciplinary health workforce by opposing education policy changes that would restrict access to professional training in nursing, public health, and allied health.
- Make the economic case for NIH investment by documenting the measurable returns, in lives and dollars, that federal research funding generates.
We look forward to engaging with NIH as this plan develops and remain committed to supporting a research enterprise that advances both the length, quality, and equality of American lives.
[1] NOT-OD-26-047. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-26-047.html
[2] National Academies of Sciences, Engineering, and Medicine. The State of the U.S. Biomedical Research Enterprise: Key Messages. Washington, DC: National Academies Press, 2024. https://nap.nationalacademies.org/resource/27588/The-State-of-the-U.S.-Biomedical-Research-Enterprise-Key-Messages.pdf
[3] Garmany A, Terzic A. Global Healthspan‑Lifespan Gaps Among 183 World Health Organization Member States. JAMA Network Open. 2024;7(12):e2450241. doi:10.1001/jamanetworkopen.2024.50241. https://pmc.ncbi.nlm.nih.gov/articles/PMC11635540/
4 López‑Otín C, Blasco MA, Partridge L, Serrano M, Kroemer G. Hallmarks of aging: An expanding universe. Cell. 2023;186(2):243–278. https://doi.org/10.1016/j.cell.2022.11.001
5 House Energy & Commerce Committee. Reforming the National Institutes of Health: Framework for Discussion. 2024. https://d1dth6e84htgma.cloudfront.net/NIH_Reform_Report_f6bbdca821.pdf
6 National Institutes of Health. NIH Climate Change and Health Strategic Framework. 2022. https://www.nih.gov/sites/default/files/research-training/initiatives/climate-change/nih-climate-change-framework.pdf
7 Response to Stripping “Professional Status” as Proposed by the Department of Education – New York Academy of Medicine
8 American Association of Colleges of Nursing. New Data Show Enrollment Declines in Schools of Nursing, Raising Concerns About the Nation’s Nursing Workforce. May 2, 2023. https://www.aacnnursing.org/news-data/all-news/new-data-show-enrollment-declines-in-schools-of-nursing-raising-concerns-about-the-nations-nursing-workforce
9 Hare Bork R, Robins M, Schaffer K, Leider JP, Castrucci BC. Workplace Perceptions and Experiences Related to COVID-19 Response Efforts Among Public Health Workers ; Public Health Workforce Interests and Needs Survey, United States, September 2021–January 2022. MMWR Morb Mortal Wkly Rep. 2022;71(29):920–924. https://www.cdc.gov/mmwr/volumes/71/wr/mm7129a3.htm
10 Association of American Medical Colleges. Tracking NIH Awards in FY 2026. March 2026. https://www.aamc.org/about-us/mission-areas/biomedical-research/publication/tracking-nih-awards-fy-2026
[11] Association of American Medical Colleges. Robust NIH Funding Saves Lives, Strengthens America. September 18, 2025. https://www.aamc.org/about-us/aamc-leads/robust-nih-funding-saves-lives-strengthens-america
[12] Wenderoff J. Public Health Initiatives Deliver Big Returns on Investment. The Pew Charitable Trusts. July 8, 2025. https://www.pew.org/en/research-and-analysis/articles/2025/07/08/public-health-initiatives-deliver-big-returns-on-investment