Public Comment on the Office of Management and Budget Proposed Regulation on Federal Financial Assistance
This is the comment I submitted in response to the OMB call for public comments on the proposed rule on federal financial assistance. Comments must be submitted by Monday, July 13, 2026, before the regulations are scheduled to take effect on October 1, 2026. Please take action and submit your comments here.
I am the USC Associates Chair in Natural Sciences and a Professor of Chemistry at the University of Southern California (iOpenShell n.d.). I write as a scientist who has spent nearly 30 years conducting federally funded research, training graduate students and postdoctoral scholars, serving on grant review panels, and participating in the scientific peer-review system. My work in theoretical chemistry, summarized in more than 300 publications, has received national and international recognition.
My career trajectory spans the USSR, Israel, and the USA. Given my first-hand experience with an authoritarian regime, I am acutely aware of the perils of politicizing and bureaucratizing science (Krylov 2021). When merit is subjugated to ideology, the production of knowledge suffers. When political bureaucrats micromanage researchers, the scientific enterprise ceases to produce breakthroughs and instead becomes an exercise in bureaucratic compliance. Whether the political control comes from the Left or from the Right, the result will be the loss of technological supremacy, with devastating consequences for industry and society at large.
I have written critically about how the Left has politicized science (Abbot et al. 2023; Efimov et al. 2024). I support the current Administration’s objective of restoring merit-based science funding and eliminating ideological, non-scientific criteria from the funding process. Federally funded research should be judged on scientific merit, not political fashion.
Unfortunately, several provisions of the proposed regulations would replace one form of politicization with another, while substantially increasing the already crushing administrative burden on researchers. Instead of reducing bureaucratic micromanagement of science and scientists (Krylov 2025), these provisions will further divert resources from the creative process. By instituting new mechanisms for control over scientists by political appointees, these provisions pave the way for future abuses by subsequent administrations (Krylov 2026). Rather than strengthening American science, these provisions would reduce productivity, competitiveness, and capacity for innovation. Below, I elaborate on these points.
[§ 200.205] Political review of scientific awards
The proposed rule would require review of scientific awards and funding decisions by senior political officials.
This would be a fundamental departure from the model of science funding that America has followed—with overwhelming success—since the end of the Second World War. This time-tested model, in which elected officials establish budgets and broad priorities while scientific experts determine which proposals have the greatest scientific merit, has enabled the U.S. to become the uncontested world leader in scientific research.
Political officials lack the expertise to evaluate the merits of technical proposals. At best, they could do little more than rubber-stamp the decisions of scientific panels and program officers. At worst, they could make deleterious, politically motivated decisions.
Rather than improving science, inserting political appointees into the funding process will institutionalize the politicization of science and transform scientific funding into a political football to be kicked in whichever direction the party in power happens to favor. Furthermore, this additional level of bureaucracy will lead to increased administrative costs and delays in processing grant applications.
Historical examples, such as the former Soviet Union, have made one thing clear: when commissars control scientific decisions, the integrity of science is undermined (Graham 1991).
The United States benefits when the best science is funded. The process of peer review and evaluation by experts may not be perfect, but inserting political appointees into the process would only erode the outcome.
[§ 200.303, 200.216, 200.329] Administrative burden and reporting requirements
The proposal would burden scientists and scientific institutions with numerous additional certifications, reporting requirements, demands for documentation, and compliance obligations.
Federally funded research is already over-burdened by excessive administrative overhead (Krylov 2025). Over the past twenty-five years, the process of obtaining and managing a federal grant has evolved from a relatively straightforward scientific exercise into a death march through a bureaucratic quagmire, involving multiple electronic systems, numerous compliance documents, mandatory certifications and trainings, excessive reporting requirements, and extensive institutional oversight. Scientists now spend enormous amounts of time completing paperwork that contributes nothing to scientific quality. Universities and funding agencies spend significant resources to manage compliance.
This extensive bureaucracy:
Diverts energy and resources toward paperwork, thereby reducing scientific productivity;
Discourages innovative and high-risk research;
Shifts incentives from achieving scientific results toward documenting administrative processes;
Makes academic research less attractive to talented young scientists; and
Increases costs without producing any value.
The proposed rule will make this even worse. America’s continued leadership in science will depend on maximizing discovery—not maximizing paperwork. Rather than creating additional compliance obligations, OMB should encourage federal funding agencies to simplify grant administration by reducing reporting requirements, eliminating unnecessary certifications and trainings, and focusing oversight on scientific outcomes rather than procedural minutiae. In other words, it should do exactly the opposite of what is being proposed.
[§200.202(e), 200.220] Domestic hiring ( “America First”) and broad restrictions on international collaboration
The proposed requirements concerning international hiring are counterproductive.
America became the world’s scientific leader because it attracted exceptional talent from around the world. Many Nobel laureates, innovators, entrepreneurs, and leaders of American science came from abroad.
Principal investigators should hire the best qualified person for a position, subject to existing immigration, export-control, and security laws. Requiring additional justification for hiring international researchers adds bureaucracy while making American science less competitive. The national interest is best served by ensuring that the United States remains the destination where the world’s best scientists choose to work.
In the same vein, broad restrictions on international collaborations will lead to the isolation of American scientists, while providing an edge to our adversaries.
[§200.432] Conference participation
The proposed restrictions on conference attendance is an example of harmful micromanagement. Scientific conferences are essential for disseminating results, establishing collaborations, mentoring young scientists, and accelerating innovation. Investigators are already bound by detailed federal rules governing allowed uses of funds and are further subject to extensive institutional oversight on how the funds are spent. Scientists should be allowed to manage their research funds in a way that maximizes their scientific output. Additional federal oversight of conference participation imposes administrative costs with no public benefit.
Again, the result is less science and more paperwork.
In summary:
The proposed regulation correctly seeks to restore merit-based science and improve accountability. Unfortunately, several provisions would have the opposite effect.
Political review of scientific awards would politicize funding decisions and increase bureaucracy. Additional compliance, oversight, and documentation requirements will increase bureaucracy at the expense of discovery, outcomes at odds with the proposal’s own stated objective of improving efficiency and reducing recipient burden. Restrictions on international hiring will ultimately weaken U.S. science by restricting the available pool of scientific talent. Restrictions on international collaborations will have similar deleterious consequences.
The United States became the world’s scientific leader by attracting the world’s best talent, funding the best ideas through expert peer review, and granting scientists the freedom to pursue discovery rather than navigate unnecessary bureaucracy. The final regulation should preserve the principle of meritocracy while eliminating ideological requirements and reducing—not expanding—the administrative burden on researchers.
References
Abbot, D., et al. 2023. “In Defense of Merit in Science.” Journal of Controversial Ideas 3: 1–26.
Efimov, I. R., et al. 2024. “Politicizing Science Funding Undermines Public Trust in Science, Academic Freedom, and The Unbiased Generation of Knowledge.” Front Res Metr Anal 9: 1418065.
Graham, L. R. 1991. Science, Philosophy, and Human Behavior in the Soviet Union. Columbia University Press.
iOpenShell: Laboratory for Theoretical Studies of Electronic Structure and Spectroscopy of Open-Shell and Electronically Excited Species. https://iopenshell.usc.edu
Krylov, A. I. 2021. “The Peril of Politicizing Science.” J Phys Chem Lett 12 (22): 5371–5376.
Krylov, A.I. 2025. “Funded Research at a US University: Death by Bureaucracy.” Heterodox STEM, Substack, April 6. https://hxstem.substack.com/p/funded-research-at-a-us-university
Krylov, A.I., et al. 2026. “Whiplash: Politicization and Counter-politicization in Research Funding.” Perspectives in Biology and Medicine; in press. https://muse.jhu.edu/pub/1/article/995379/pdf; press release here.
Thank you, Anna, for your thoughtful article on the dangers of political leaders and partisan ideologies interfering in scientific research. The internal politics within academia—particularly within individual fields—are already damaging enough. We can certainly understand the strong push by the current U.S. White House and Congress to enforce the Civil Rights Act and to eliminate the current racial and gender biases in academic institutions. You argue, quite eloquently, that in doing so they have gone too far.
I agree that burying scientists with paperwork and regulation is a poor use of their time. That said, the academic community has demonstrated that it CANNOT be trusted to make funding decisions without heavy influence from political appointees who will see that the national interest of the nation whose taxpayers pay the bills are attended to. Consider that the vaunted peer review process actually only addresses the ideas of about 25% of PhD level scientists/academics because 75% of faculty are on contingent appointments denying them both the protections of tenure and the ability to submit proposals in their own name. The federal government did NOT create this apartheid system (though it has not lifted a finger to correct it.) It was academics including scientists that created the academic caste system focusing university resources and opportunity to a limited few at the expense of others. No amount of political appointee influence can cause as much harm to American science as that has.
Second, the argument in favor of unrestricted hiring of foreign scientists is also misguided and harmful to both the US and science overall. The more foreign scientists hired by American universities and companies, the less incentive Americans have to go into science. They see the fate of the many Americans who wasted their time getting PhD degrees that offer no return on investment due to lack of opportunity as their jobs were taken by foreign scientists who were no more, and often less, qualified than the Americans whose places they took. If other countries hired American scientists at the same rate as the US does, one might be able to justify this "exchange" of talent. Since that does not happen, the US needs to adopt the policy of Canada and make hiring of its own people the priority. There is a simple way to incentivize both Americans to go into science and the hiring of foreign talent where needed: Restrict visas for foreign students, faculty and employees by country to equal those that the foreign country has brought in from America the year before.
Third, while science may be "global" in some aspects, there are serious implications for national security when a globalist scientific class shows no loyalty to the countries that host and pay for their work. That is how we get Iranian scientists accessing American mainframes from inside Iran for "research" purposes with the assistance of foreign scientists based in the US. Science is important to national security...but only when it is not co-opted to serve hostile forces. Similarly, conference attendance is a privilege...NOT a right...and its time that scientists were disabused of the notion that their work is above the same regulatory requirements placed on other industries. The Trump administrations policies would not be necessary if the scientific community had not created the current system which is, sadly, not in the interest of the American people.