OMB, joined by forty grant-making agencies—NSF, HHS, DOE, NASA, DOD among them—proposed a sweeping rewrite of the rules governing all federal grants, the Regulation for Federal Financial Assistance.
American science has long been a status quo funding but not the situation directed. Since Vannevar Bush, money has flowed through many agencies to private universities, largely through peer review. The system had its flaws—compromise, gerontocracy, waste—but it had great virtues, the system was decentralized and not under state control. This law proposes to bring science funding under top-down government control.
Program goals must now be “consistent with administrative policies and priorities” (§ 200.202). Merit review is subject to politics: “executive appointees must conduct this review,” ensure “that discretionary awards advance the President’s policy priorities,” while “peer review remains advisory and does not substitute for agency discretion” (§ 200.205). And every grant is terminated at will, whenever it “no longer serves the purposes of the program, the priorities of the Federal agency, or the national interest *as it exists at the time of termination*” (§ 200.340, emphasis added). Universities must also ensure that their recipients do not “significantly harm the reputation of… the State Government” (§ 200.332)—the scientist’s fiduciary clause.
All of this is being sold as “burdensome circumstances,” a principle I can support, but sadly that is nonsense. The proposed rules add more paperwork and more layers of bureaucratic review. Payment requests must include written reasons. Every payment is checked by the Treasury’s “Do Not Pay” system. Every recipient must use E-Verify. Applicants must disclose any employee who has worked for the awarding agency within two years. And on top of the existing review machinery sits a new pre-release review committee of “senior nominees” who second-guess experts. Fixed value rewards—paying for output, not input—the new reward system is *being* phased out, so all rewards now receive standard cost monitoring and financial reporting.
Top candidate review for all awards, peer review reduced to advisory, terminated whenever “priority” changes. Dating. It’s a nightmare for a little credibility review of the kind that is already sinking science. I have to deal with this kind of nonsense all the time. More is not better.
Equipment is also centralized. OMB’s guidance becomes binding law, effective throughout the government without agency rulemaking. One dial at the White House is now changing the entire grant system in the country.
The new rules will be marketed as eliminating the DEI but that is an excuse to bring in the commissioners. The new laws don’t remove the science and politics they create even more politics with a flipped sign, and the writers agree:
In the previous administration, executive agencies often chose to fund and clearly prioritize projects based on their conceptual alignment with the categories of activities discussed in the proposed version of § 200.300. See, for example, EO 13985, sec. 1, 86 FR 7009, 7009 (Jan. 25, 2021) (“It is therefore policy [the Biden] Management that the Federal Government should follow a comprehensive approach to promote equality. . . “). In this administration, executive agencies will continue to exercise their authority in a manner consistent with current Executive Branch policy. If executive agencies had the right to fund those types of activities during the previous administration, there is no constitutional basis to prevent the government from reaching a different policy decision about which activities should be funded during this administration.
Read that twice. Tip your hat to the new constitution, get a new revolution. Will science succeed when fueled by political volatility? The study works with ten time scales; The administration is held for four years.
A decentralized financing system does not work in the same way that markets and federalism do—we give up some economies of scale and get testing, error correction, and robustness in return. A system in which all awards advance the President’s “policy priorities” works as well as science departments. We know how that test ends.
America is going in the wrong direction. We have to look twice at what makes America great. Instead we adopt all the failed policies of authoritarian nations.
