Relevant sections: 2 CFR § 200.205 (Merit Review), § 200.450 (Issue Advocacy)

The proposed rule would require a “pre-issuance review” to be conducted independently by political appointees of every discretionary grant before it’s awarded. The appointees are explicitly forbidden from deferring to peer reviews for their recommendations and must grant awards that “...demonstrably advance the President’s policy priorities.”

Rather than experts, researchers and a peer-reviewed process driving budgetary decisions, now administrative ideologies would be the prime decision-makers determining which projects are granted funding. Additionally, it seeks to ban “issue advocacy” on “divisive ideologies” such as climate science and public health research. Rather than issuing funding based on merit or need, it will be done based on political alignment.

Relevant sections: 2CFR § 200.220 (Covered Foreign Collaborations), § 200.300 (Statutory and national policy requirements)

International collaboration would be increasingly difficult under proposed regulations, which prohibit the use of federal funds for bilateral or multilateral collaboration with “covered foreign countries,” any country designated by statute, Executive Order or other Federal law as a foreign adversary, a country of particular concern, or a country subject to sanctions or restrictions related to national security, defense, or intelligence activities. Federal funds would also be blocked from supporting or promoting Diversity, Equity, and Inclusion (DEI/DEIA) initiatives, even from a separate program or agency within the grantee organization.

These restrictions place unnecessary exclusions on the scientific industry and risk losing the diversity of thought and peer collaboration required to advance science. Our ocean extends beyond our nation’s borders, and so our science must do the same to be effective.

Relevant sections: 2CFR § 200.340 (Termination and Suspension)

Proposed changes would allow federal agencies to rescind funding for active grants without findings of fraud or noncompliance, and without requiring a detailed explanation. Grants could be terminated for being “inconsistent with program goals or agency priorities,” putting political ideologies once again at the center of decision-making and disrupting the financial ecosystem that allows science to progress most effectively.

Many grants are planned over multi-year periods and include funding for permits, equipment, staff positions and more in order to meet project objectives. If the newly proposed changes take effect, those research projects could be perpetually at risk of ending at any moment based on political beliefs.