Introduction
New York Academy of Medicine submits these comments in response to the Office of Management and Budget’s proposed revisions to 2 CFR Part 200, published in the Federal Register on May 29, 2026.
Founded in 1847, New York Academy of Medicine has spent more than 175 years advancing health through scientific inquiry, scholarly publication, professional convening, and the translation of evidence into practice. New York Academy of Medicine is also the publisher of the Journal of Urban Health, a peer-reviewed scientific journal that serves as an international forum for research on urban population health. New York Academy of Medicine also convenes Fellows, researchers, clinicians, policymakers, and community leaders to address the most pressing health challenges of our time.
We appreciate the opportunity to comment on a proposal of significant consequence for the institutions, researchers, and communities that depend upon the federal research and public health enterprise.
We unhesitatingly support the proposal’s stated objectives of transparency, accountability, and responsible stewardship of federal resources. At the same time, we are deeply concerned that several proposed revisions, if finalized as written, would weaken the foundational systems through which scientific knowledge is generated, evaluated, communicated, and translated into improvements in human health.
These comments focus on four areas in which New York Academy of Medicine has both direct institutional experience and a longstanding obligation to speak: the role of expert peer review, the conditions necessary for scientific exchange, the stability required for long-term public health investments, and the connection between evidence and practice.
Areas of Agreement
New York Academy of Medicine recognizes the importance of ensuring that public funds are used responsibly and that federal grant programs operate in a manner that is transparent, accountable, and focused on public benefit.
We support:
- Transparency in federal grantmaking, including clear notice of funding opportunities, public access to award information, and consistent application of eligibility criteria.
- Accountability for recipients of federal funds, including appropriate oversight, reporting, and audit requirements.
- Sustained efforts to prevent waste, fraud, and misuse of public resources.
- Clearly defined performance expectations and measurable outcomes that allow agencies, recipients, and the public to evaluate the impact of federal investments.
These principles reflect responsible stewardship of public resources and are consistent with the standards New York Academy of Medicine applies to its own programs. We encourage OMB to advance these objectives in ways that strengthen the federal grant enterprise without undermining the scientific and operational foundations on which it depends.
Recommendations
The United States has one of the most productive research systems in history. The federally supported research ecosystem, anchored by expert peer review, independent scientific inquiry, scholarly publication, and open scientific exchange, has produced generations of medical breakthroughs, improved health outcomes, strengthened American competitiveness, and fueled economic growth.
The returns are measurable. NIH research funding generated approximately $94 billion in economic activity nationwide in FY2025 and supported nearly 391,000 jobs across the country. According to analyses cited by NIH and United for Medical Research, every $1 invested in NIH-supported research generates more than $2.50 in economic activity. [8, 9]
Accountability and transparency are essential. But reforms should build upon a system that has consistently delivered scientific, economic, and public benefit, rather than weaken the mechanisms responsible for its success.
1. Preserve Expert Peer Review as the Foundation of Scientific Excellence
For more than eight decades, the federal research enterprise has been built on the principle that scientific quality is best evaluated by individuals with relevant scientific expertise. Peer review is the foundation upon which the credibility, rigor, and global leadership of American science rests.
The United States became the world’s leading engine of biomedical innovation because funding decisions have historically been guided by scientific merit, expert evaluation, and competitive review. [10] Weakening that process risks eroding one of the nation’s most successful public investments.
Provisions of the proposed rule that materially diminish the central role of expert peer review in funding decisions raise serious concerns. As publisher of the Journal of Urban Health, representatives from New York Academy of Medicine administer peer review every day and understand directly the value it provides. Peer review enables qualified experts to identify scientific weaknesses, strengthen methodology, validate findings, and ensure that what is ultimately published meets the standards on which scientific progress depends.
Accountability and expert review are synergistic. Strong accountability is reinforced when funding decisions are grounded in transparent, expert evaluation of scientific merit.
New York Academy of Medicine urges OMB to:
- Preserve expert peer review as the primary determinant of scientific merit.
- Maintain clear separation between scientific evaluation and political or policy review functions.
- Ensure that oversight mechanisms reinforce scientific rigor rather than substitute for expert judgment.
Similar concerns regarding predictability, institutional planning, and grant administration have been discussed extensively by organizations representing research institutions, local governments, and nonprofit recipients of federal funding. [2,3,5,6]
2. Protect Scientific Exchange, Scholarly Communication, and Innovation
Scientific progress rarely occurs in isolation. Discovery advances through critique, replication, collaboration, publication, and convening. Conferences and scholarly journals are not ancillary activities; they are core infrastructure of the scientific enterprise.
Many of the nation’s most important advances in medicine and public health emerged from collaborations that crossed institutions, disciplines, sectors, and national borders. Policies that discourage those interactions risk slowing innovation at precisely the moment global scientific competition is accelerating. [10] New York Academy of Medicine is also concerned by proposed changes that could limit support for publication costs associated with federally funded research. As the publisher of a peer-reviewed scientific journal, we believe such restrictions may create unintended barriers to scientific dissemination.
Provisions of the proposed rule that limit conference participation, constrain publication activity, restrict access to the scientific literature, or impede professional collaboration would undermine these essential functions of the scientific enterprise.
New York Academy of Medicine urges OMB to:
- Preserve allowability of conference participation and scientific convenings.
- Protect researchers’ ability to publish findings in peer-reviewed journals.
- Avoid restrictions that disproportionately impede interdisciplinary or international scientific collaboration.
- Preserve allowability of reasonable publication expenses, including costs associated with the open-access dissemination of federally funded research.
- Affirm that scholarly communication is a legitimate and essential component of federally supported research.
3. Preserve Stability for Economic and Population Health Improvement
Research funding not only fuels scientific progress, it is also a workforce and economic development investment. Research institutions hire scientists, train future researchers, purchase equipment and services, and contribute to local economies in every state. Abrupt policy uncertainty can disrupt those functions long before any grant is formally terminated. NIH-supported research funding supported nearly 391,000 jobs nationally and generated more than $94 billion in economic output in FY2025 alone. [9]
Many of the most important advances in population health unfold over years and decades rather than over single budget cycles. Research, practice, and market advances in areas such as healthy aging, cancer treatment, chronic disease prevention, maternal and child
health, workforce development, environmental health, and health innovation depend on durable partnerships, long-term planning, and predictable funding environments.
Research institutions, and companies that benefit from basic and applied research, hire scientists and staff, enroll participants, train students, build community partnerships, and develop infrastructure on the basis of reasonable expectations that awarded grants will be honored over their stated periods of performance.
Provisions of the proposed rule that significantly expand the grounds for discretionary termination of awards risk introducing substantial uncertainty into long-term research and population health investments. Even when termination authorities are not exercised, the existence of broad discretionary termination standards can affect institutional planning, workforce stability, and the willingness of partners including the private sector to commit to sustained engagement.
New York Academy of Medicine supports clear and appropriate authorities for agencies to address noncompliance, misuse of funds, and demonstrable program failure. We are concerned, however, by provisions that go beyond these traditional grounds and create uncertainty for ongoing, multi-year scientific and population health work.
New York Academy of Medicine urges OMB to:
- Limit post-award termination authority to clearly defined and objective circumstances.
- Require written notice and an opportunity to cure or respond before termination.
- Protect previously awarded funding commitments except in cases of demonstrated noncompliance or misuse.
- Recognize the workforce, economic, and community impacts that abrupt grant disruptions create.
4. Preserve the Flow of Evidence into Policy and Practice
Federally funded research generates the greatest public value when its findings can be applied. Evidence improves health outcomes when it can inform the decisions of clinicians, public agencies, community organizations, policymakers at every level of government, and companies aiming to bring innovation to market.
New York Academy of Medicine has long served as a bridge between research, practice, and policy. Our work depends upon the ability of researchers, scholarly publications, and convenings to communicate findings to those who can act upon them.
Provisions of the proposed rule that limit the communication of research findings, restrict engagement between federally funded researchers and public agencies, or constrain the dissemination of evidence raise serious concerns. Such provisions risk weakening the essential connection between publicly funded research and the public benefit it is intended to produce.
We support appropriate distinctions among scientific communication, lobbying, and political activity. We are concerned, however, that the breadth of the proposed restrictions
could discourage researchers from sharing findings on matters of significant public consequence, including disease prevention, healthcare delivery, environmental health, and the wellbeing of communities.
New York Academy of Medicine urges OMB to ensure that final rules preserve the ability of federally funded researchers and institutions to communicate scientific findings to practitioners, public agencies, policymakers, and the health innovation sector in support of evidence-informed decision-making.
These concerns are consistent with positions advanced by leading organizations across the biomedical research, public health, and scientific advocacy communities regarding the importance of preserving scientific communication, research stability, and evidence-informed policymaking. [1][4][7]
Conclusion
New York Academy of Medicine supports the proposal’s stated objectives of transparency, accountability, and responsible stewardship of federal resources. We share these goals and believe they are essential to maintaining public confidence in federally funded research and public service programs.
At the same time, we are deeply concerned by provisions of the proposed rule that would weaken expert peer review, impede scientific exchange and scholarly communication, create substantial uncertainty for long-term research and population health initiatives, or inhibit the translation of evidence into policy and practice.
The United States has built one of the world’s most successful systems of scientific discovery and health improvement through sustained investment in independent inquiry, rigorous peer review, scholarly publication, interdisciplinary collaboration, and evidence-informed decision-making. The
success of this model is measurable. NIH-supported research generates billions of dollars in economic activity each year, supports hundreds of thousands of jobs nationwide, catalyzes private-sector innovation, and continues to produce advances that improve and extend lives. These systems are the foundations on which scientific progress, public health advancement, economic competitiveness, and societal benefit depend. [8, 9, 10, 11]
New York Academy of Medicine respectfully urges OMB to revise the proposed rule in a manner that strengthens accountability and transparency while preserving the essential systems through which scientific knowledge is created, evaluated, communicated, and applied for the benefit of the public.
Respectfully submitted,
Ann Kurth, PhD, CNM, MPH
President and Chief Executive Officer
New York Academy of Medicine
References
1. Dzau VJ, Yamamoto KR. Government-Funded Health and Biomedical Research Is Irreplaceable. National Academy of Medicine; August 18, 2025. https://nam.edu/perspectives/government-funded-health-and-biomedical-research-is-irreplaceable/
2. Association of American Medical Colleges. The impact of federal actions on academic medicine and the U.S. health care system. June 11, 2025. https://www.aamc.org/about-us/aamc-leads/impact-federal-actions-academic-medicine-and-us-health-care-system
3. Ropes & Gray LLP. OMB Proposed Revisions to the Uniform Guidance: Key Takeaways for Award Recipient Organizations. June 2, 2026. https://www.ropesgray.com/en/insights/alerts/2026/06/omb-proposed-revisions-to-the-uniform-guidance-key-takeaways-for-award-recipient-organizations
4. American Public Health Association. APHA v. NIH. April 2025. https://www.aclu.org/cases/apha-v-nih
5. National Association of Counties. OMB proposes major overhaul of federal grant rules. May 29, 2026. https://www.naco.org/news/omb-proposes-major-overhaul-federal-grant-rules
6. Debevoise & Plimpton LLP. OMB Proposes Significant Changes to Federal Grant Administration. June 3, 2026. https://www.debevoise.com/insights/publications/2026/06/omb-proposes-significant-changes-to-federal-grant
7. Research!America. OMB Proposed Rule Resources and Advocacy Materials. 2026. Research!America notes that the May 2026 OMB proposal would significantly change how federal grants and cooperative agreements are awarded, managed, and terminated across the federal government and encourages organizations to submit public comments on the proposal. Available at: Research!America. Accessed July 2026.
8. National Institutes of Health. Direct Economic Contributions. Updated April 18, 2025. Available at: https://www.nih.gov/about-nih/impact-nih-research/serving-society/direct-economic-contributions. Accessed July 2026.
9. United for Medical Research. 2026 Update: NIH’s Role in Sustaining the U.S. Economy. March 2026. Available at: https://www.unitedformedicalresearch.org/annual-economic-report/. Accessed July 2026.
10. National Institutes of Health. Spurring Economic Growth. Updated April 18, 2025. Available at: https://www.nih.gov/about-nih/impact-nih-research/serving-society/spurring-economic-growth. Accessed July 2026.
11. National Institutes of Health. NIH Awards by Location and Organization (RePORT). FY2024 funding data. Available at: https://report.nih.gov/award/index.cfm?fy=2024. Accessed July 2026.