In May 2025, the Office of Management and Budget, along with 41 other Federal agencies, released a proposed rule titled “Regulation of Federal Financial Assistance”, which would fundamentally alter the award and administration of federal grants. The proposed rule would create a process for political review of grants and allow the government to deny and terminate grants based on whether they align with the administration’s priorities. The rule would also prohibit work deemed as “DEI” and some grant expenses such as journal publication fees and conference attendance.
In response, several LDI Senior Fellows submitted formal comments.
LDI Executive Director Rachel M. Werner, MD, PhD focused on provisions of the rule that would create a pre-issuance review of grants by political appointees, which peer review demoted to an advisory capacity. This would allow for mid-award termination of grants for “shifting priorities”, and would limit the ability of grant funds to be used on conferences, publications costs, and open-access fees.
Scott Halpern, MD, PhD focused his comments on the importance of peer review and the harms caused by funding decisions not grounded in rigorous scientific evaluation.
Carmen Guerra, MD, MSCE, focused on the cumulative impacts of multiple provisions of the rule, including prohibitions related to DEI and gender ideology, the ban on disparate-impact research, restrictions on foreign collaboration, the requirement that programs align with administration priorities, the treatment of publication costs as unallowable, and political appointee review of grants. Her comments examined how these changes, taken together, would affect her research.
Lynne Moronski, PhD, RN wrote about her research improving health outcomes for individuals with intellectual and developmental disabilities (IDD), a population that experiences well-documented health disparities. Her comment warns that DEI-related prohibitions and the termination of related research could further harm this already vulnerable population.