On September 24, 2025, AGU joined more than 50 science and medical organizations to express concern regarding the Executive Order “Improving Oversight of Federal Grantmaking. 

 

As scientific and medical research organizations, we wish to formally express our concerns regarding the Executive Order (EO) titled “Improving Oversight of Federal Grantmaking,” issued on August 7. Our nation’s federal grantmaking ecosystem serves as the gold standard forsupporting cutting-edge research and driving technological innovation worldwide. Ongoing evaluation and oversight of this ecosystem contribute to its effectiveness in the U.S.; however, specific directives within this EO raise questions regarding the possibility of politicization in federally funded research. We respectfully request that Congress provide guidance as agencies implement this EO. It is critical that we safeguard the integrity of the merit-based peer review process.

The U.S. has led scientific innovation and breakthroughs for decades; this is in large part due to a gold standard merit-based framework that governs scientific funding decisions. Our leading science institutions, such as the National Institutes of Health, the National Science Foundation, the Department of Energy, the U.S. Department of Agriculture, and the National Aeronautics and Space Administration, have built peer review systems that direct federal funding to researchers with cutting-edge ideas and that ultimately drive breakthrough innovations that improve the lives of Americans in every state.

Without the oversight traditionally applied by appropriators and committees of jurisdiction, this EO will significantly increase administrative burdens on both researchers and agencies, slowing, and sometimes stopping altogether, vital scientific research that our country needs.

We call on Congress to urgently exercise its oversight authority to prevent potentially significant damage to U.S. leadership in scientific and medical research. Below we detail specific concerns with several provisions of the EO.

Political Appointees [Sec. 3]

The role of political appointees in Cabinet positions and as agency leads provides an administration with the means to advance its defined agenda while still executing the legislative mission and mandate of each agency. The EO’s directive to shift review and selection of individual awards to political appointees fundamentally threatens the integrity of the grantmaking process by removing key subject matter expertise.

This unprecedented oversight by political appointees risks injecting partisan political bias into what has long been an impartial, merit-based system. The peer review system, a process widely regarded as the gold standard for evaluating scientific merit and funding decisions, is built on the rigorous evaluation of proposals by independent scientific experts. This ensures that funding decisions are based on missiondriven scientific innovation and potential impact – not political considerations, which is why the U.S. has consistently led the way in driving breakthrough research and accelerating technological innovation. Shifting final authority to political appointees will significantly undermine the grant review and award system and could distort federal research priorities based on ideological or partisan agendas, stifle innovation, and erode public confidence in research. Research should focus on scientific inquiry, promise, and innovation to advance science and improve public health above politics.

We urge Congress to ensure that independent peer review remains the cornerstone of the scientific grantmaking process, such that the most meritorious proposals are funded in this and all future administrations.

Termination of Grants for Convenience [Sec. 5 and Sec. 6]

The expansion of “termination for convenience” authority in the EO has the potential to waste taxpayer resources and weaken the nation’s scientific enterprise. Canceling grants midstream due to ever-shifting agency priorities would squander investments already committed to facilities, equipment, and specialized personnel, reducing our return on federal spending and potentially undermining the principle of accepting negative results as positive outcomes. Further, permitting awards to be terminated for reasons unrelated to performance or compliance opens the door for administrations of either party to effectively end funding for lines of research deemed politically sensitive. Employing such terminations will create perverse incentives to align research results with political agendas.

This prospect has the very real potential to generate a chilling effect across the research community. Scientists may avoid submitting grant proposals in areas that could be perceived as controversial, even when those fields hold considerable promise for transformative discoveries. The threat of termination for convenience will undercut U.S. competitiveness in a global research environment where other countries offer more predictable funding streams free of political interference.

We urge Congress to ensure that federal research funding remains insulated from short-term political pressures by directing science agencies not to amend the terms and conditions of discretionary grants to permit termination for convenience.

Repeat Grant Recipients [Sec 4. (b) (iv)]

We support the EO’s goal of maintaining a balanced and broad portfolio of grant recipients, and we applaud existing efforts by science agencies in support of this goal, like the Established Program to Stimulate Competitive Research (EPSCoR) and the Institutional Development Award (IDeA). However, the EO is alarmingly vague about how “repeat players” will be identified in practice. Funding a large research group, and thereby providing training opportunities for its undergraduate, graduate student, and postdoctoral members, may require applying for multiple funding opportunities each year. Limiting the number of grants that an individual can apply for could compromise research in areas where large teams are needed and undermine the development of a strong national STEM workforce. It should also be noted that some agencies already have statutory processes in place for evaluating limits on proposals. For example, in 2008, the National Science Board submitted a report to Congress on Limits on Proposal Submissions by Institution, as directed by the NSF Authorization Act of 2007.

We urge Congress to work with the scientific community, including groups like the National Science Board, to evaluate current practices and recommend measures to support a broad portfolio of grant recipients.

Overall, this EO adds inefficiencies to the grant process. For instance, the EO institutes new requirements for the drawdown of approved grant funds, including “written explanations or support, with specificity, for requests for each drawdown.” Such requirements introduce undue interference and will likely exacerbate, rather than lighten, the burden of administrative costs on federal grants – contrary to the EO’s stated goal. Additionally, the EO increases researchers’ administrative workload by requiring all federal grantmaking agencies to implement new processes for reviewing notices of funding opportunities and discretionary grants, both pre- and post-selection. Adding new layers of review and approval across the entire grant portfolio will entail significant agency staff time and resources, and risks slowing the process of reviewing and awarding grants.

Finally, Congress must stop the Administration’s proposal to prioritize research proposals from academic institutions with the lowest indirect (Facilities & Administration) cost rates. Current F&A rates are methodically negotiated and audited by the federal government. No changes to this process should be made without proper legislative and regulatory changes to the federal code. F&A costs can vary from state to state and from academic institution to academic institution, depending on the resources and capacities of individual departments as well as the complexity and focus of the research in question. Issuing research awards based on the lowest indirect cost rates undermines what should be the driving factor in awarding federal science funding – the ability to produce demonstrable results that lead to innovation, new technologies, and a return on public investment.

On balance, the EO does not advance the Administration’s goal of implementing Gold Standard Science. More review and oversight are needed by Congress before the full implementation of this EO goes into effect. The scientific community is eager to work with Congress and the Administration to strengthen our scientific enterprise.

 

Sincerely,

Academic Data Science Alliance

Academy for Radiology and Biomedical Imaging Research

American Association for Dental, Oral, and Craniofacial Research

American Association of Immunologists

American Association of Physicists in Medicine

American Association of Physics Teachers

American Astronomical Society

American College of Medical Genetics and Genomics

American College of Radiology

American Educational Research Association

American Geophysical Union

American Geosciences Institute

American Industrial Hygiene Association

American Institute for Medical and

Biological Engineering

American Institute of Biological Sciences

American Mathematical Society

Academic Pediatric Association

American Pediatric Society

American Physical Society

American Physiological Society

American Phytopathological Society

American Psychological Association Services

American Society for Biochemistry and Molecular Biology

American Society for Cell Biology

American Society for Microbiology

American Society for Pharmacology and

Experimental Therapeutics

American Society for Transplantation and Cellular Therapy

American Society of Plant Biologists

American Society of Tropical Medicine and Hygiene

American Statistical Association

American Thoracic Society

Association for Women in Science

Association of Medical School Pediatric Department Chairs

Association of Population Centers

Biophysical Society

Botanical Society of America

Coastal and Estuarine Research Federation

Computing Research Association

Ecological Society of America

Electrochemical Society

Endocrine Society

Entomological Society of America

Geological Society of America

International Society for Stem Cell Research

Natural Science Collections Alliance

Pediatric Policy Council

Population Association of America

Society for Neuroscience

Society for Pediatric Radiology

Society for Pediatric Research

Society for Personality and Social Psychology

Society for Public Health Education

Society of Behavioral Medicine

Society of Chairs of Academic Radiology

Society of Environmental Toxicology and Chemistry of North America

SPIE, the international society for optics and photonics

The Association for Research in Vision and Ophthalmology

The Oceanography Society