GSA’s public comments to OMB on the proposed rule “Regulation for Federal Financial Assistance”

The Genetics Society of America submitted comments on the Proposed Rule “Regulation for Federal Financial Assistance” (Docket no. OMB-2026-0034) electronically via www.regulations.gov by the July 13, 2026 deadline, in a letter (PDF attachment) addressed to the Honorable Russel T. Vought, Director of the Office of Management and Budget (OMB). The comments included here have been stripped of the official letter format used to easily share with our community on GSA’s blog. 

Dear Director Vought:

The Genetics Society of America (GSA) is an international scientific society of more than 4,000 members, dedicated to supporting scientists of all career stages conducting research in genetics and genomics. Our community of scientists extends far beyond our membership to include GSA conference attendees, journal authors and reviewers, and other colleagues. We, the Board of Directors, would like to express our serious concerns regarding the proposed changes to Uniform Guidance. These changes, if enacted, will irrevocably damage scientific integrity, progress, and the strength of the United States research enterprise.

[§200.205(d)] 

A primary concern is §200.205(d), Merit Review, which shifts federal agency review of grant applications and proposals away from expert scientific peer review toward greater discretion by political appointees. This poses a major risk to scientific integrity if expert reviewers only serve in an advisory capacity. Peer review allows not a single expert, but a group of experts, to evaluate and rank the importance and merit of proposals. A group of trained experts discusses the validity of the premise, the rigor and reproducibility of the proposed studies, and the potential impact for influencing the field. A rigorous peer review process improves the final product, including in grant reviews. The panels bring related, but disparate expertise to the table to fine-tune critiques and to ensure that the very best experiments are being proposed and are likely to succeed. This reinforces sound investment of research dollars.

[§200.340] 

With these proposed changes, agencies would be able to terminate active grants if a project no longer aligns with federal priorities. Funding interruptions don’t just delay research; they compromise it. Many studies cannot be paused and restarted without jeopardizing the integrity of the results, leading to a significant waste of already-invested taxpayer funds if partially-completed research is abruptly terminated. This policy will profoundly impact the scientific labor force. A person would rather secure a non-U.S. based position, retire, or choose a different field altogether rather than enter into a multiyear postdoctoral or graduate appointment when funds could be terminated at any time; indeed, we are already seeing a mass exodus of students abroad and out of industry. Discoveries are not made in a year, but involve persistent and sustained effort, often over decades. Most ground-breaking scientific discoveries of our generation (CRISPR, RNA interference, genome sequencing) came not from companies or political desires, but from tedious, painstaking experiments at the lab bench and microscope. Indeed, many of these discoveries were serendipitous and came from fundamental studies into bacteria, fungi, plants, and a range of animal models (frogs, flies, worms, mice, and others). The NIH and NSF have had a long-standing commitment to foundational scientific studies using a range of organisms driven by the knowledge that we cannot predict where the next breakthrough will be. Sustained and continuous funding, free from political interference, is essential to ensure that a wide range of research topics are pursued and that a secure workforce in STEM is maintained.

Research conducted by the genetics and genomics community often mentions gender and/or sex differences in grant applications, because sex-specific biological differences are inherent to organisms with X and Y chromosomes that encode distinct genes, producing different hormones that lead to distinct traits and impacting a multitude of physiological processes that need to be better understood to improve human health. Studies in model organisms such as flies, worms, mice, zebrafish, and even plants allow us to better understand fundamental genetic, developmental, and evolutionary sex-specific processes. In medicine, for example, it is critical to understand sex-based differences in human health and disease, and in therapeutic drug dosage and effects. Diversity is another term used regularly in research and the scientific literature; for example, it is critical to understand the diversity of pathogenic genetic mutations and tumour types in order to develop personalized cancer treatments. Flagging these terms and having a non-scientifically trained appointee review the application or proposal creates the risk that scientifically sound research could be rejected based on criteria other than scientific merit.

[§200.220, 200.202(e)] 

The proposed “domestic-first” framework will hurt U.S. science. Our community advances science through collaboration both within the U.S. and internationally. Genetics has historically advanced through international partnerships that combine shared community infrastructure, specialized expertise, and unique resources like stock centers, model organism databases, and open access to data. Progress in genetics research depends on the global sharing of specialized expertise, computational tools and software, data, and biological materials like stocks and strains. Science works best when it is collaborative. Restricting collaborators to those only in the U.S. limits what researchers might study as well as the long-term impact on the field.

Some of the most impactful discoveries in genetics arose out of this ethos, including the Nobel Prize-winning work on RNA interference, green fluorescent proteins, and cell cycle regulation. The 2001 Nobel Prize in Physiology or Medicine was awarded to Lee Hartwell and British scientists Sir Paul Nurse and Sir Timothy Hunt for the discovery of molecular mechanisms that regulate the cell cycle. Hartwell, a longtime GSA member whose work was supported by NIH funding, used yeast as a model organism in research that, together with the work of Nurse and Hunt, has greatly impacted our understanding of cancer biology and contributed to targeted drug development to treat cancer. CRISPR genome editing emerged from an international collaboration between GSA community member Jennifer Doudna and the French scientist Emmanuelle Charpentier and was recognized with the 2020 Nobel Prize in Chemistry. CRISPR has revolutionized the treatment of many diseases, including, most recently, sickle cell disease treated with the gene therapy Casvegy.

Corn (maize) is the single most valuable agricultural product in the U.S. Continued efforts to improve maize, from identifying disease resistance genes to understanding stress response, rely on access to diverse maize lines. While the USDA germplasm repository has an extensive collection, the most diverse collection of maize from the wide array of environments and growing conditions is maintained by the International Maize and Wheat Improvement Center (CIMMYT) in Mexico. Restricting access to these materials or collaboration with scientists in CIMMYT would slow or obstruct research that could benefit U.S. companies and farmers.

On the journals’ side, an analysis of articles whose authors had received NIH funding from 2009-2017 found that in 2017, approximately 35% included at least one coauthor affiliated with an institution outside the U.S. (Grubbs et al., 2019), a percentage that has steadily increased since 2017. These papers had substantially higher citation impact than publications authored solely by U.S.-affiliated investigators, which illustrates the usefulness of these international collaborations.

In a stratified random sample of 2025 articles published in GENETICS and G3: Genes|Genomes|Genetics during 2025, 66.4% reported support from U.S. federal agencies. Approximately one-quarter of federally funded papers included both U.S. and international institutional affiliations. These findings indicate that international collaboration is routine within our research community. 

Prohibiting the use of federal funds for partnerships with certain foreign countries or entities, which remain largely undefined, will interfere with the ability of the U.S. scientific workforce to pool data, expertise, and resources with international colleagues. This will result in less impactful, lower-quality research, ultimately risking the U.S. standing as a global leader in science and innovation.

[§200.461] 

Our members also rely on publishing their research in peer-reviewed journals, like our publications GENETICS (over 21,710 published articles since 1916; 37,197 citations) and the open access journal G3: Genes|Genomes|Genetics (4,848 published articles since 2011, 10,771 citations). Our journals disseminate the latest science and present findings on a global scale. They also provide access to data underlying research findings, in accordance with U.S. federal requirements on public access to data.

Publication costs are a necessary part of disseminating these findings, and most genetics labs rely on federal funding, without alternative means to pay these charges. The proposal to exclude publication fees from grant awards will mean that most GSA members will be unable to pay such fees. This will seriously hinder the dissemination of research findings and the timely communication of federally-funded results to the public. This in turn will compromise the return on U.S. investment in science. The use of preprint servers or the review of preprints are not effective substitutes for the gold-standard of high-quality peer review and publication of manuscripts in reputable journals.

[§200.432] 

Regarding the restrictions on use of government grant funds to attend scientific meetings, scientists attend conferences to present new research to the broader community, to receive feedback that helps them shape their work, and to form collaborations that drive innovation. Since 2021, GSA conferences have hosted 20,226 attendees, with 73% hailing from the U.S. Reducing funding for meetings or setting strict limitations on allowable expenses will hurt collaboration across institutions and slow the communication of scientific discoveries. Our members may not know years in advance which GSA or other scientific conference will best suit their needs, and so it may be infeasible to seek permission in the grant application. Further, such a requirement impedes the creation of conferences that may tackle the most salient and pressing issues of our time (e.g., the use of AI in healthcare). Finally, almost all GSA conferences are held in the U.S., which has contributed to local hotels, restaurants, and small businesses (i.e., local economies). 

Overall, GSA believes that barriers to the dissemination of research and the formation of vital collaborations impede the development of new technologies, diagnostics, and therapeutics, to the detriment of public health. This would also negatively affect advances in breeding technologies and crop genetic improvement, with downstream consequences for U.S. agriculture and food security. Funding shortfalls arising from the proposed revisions will have far-reaching consequences. Owing to funding uncertainty, many of our members have already rescinded offers to graduate students, postdoctoral researchers, and early-career faculty. If these proposed revisions take effect, it will be difficult to course correct. This snowball effect will result in significant job losses at universities and medical centers that in turn will decrease consumer spending and negatively affect local economies. Importantly, it will reduce the pipeline of scientists, which will have long-term repercussions in fueling biomedical innovation in the U.S. in the decades to come.

While we recognize that these revisions are intended to reduce waste of funds and ease the administrative burden on award recipients, they would likely have the opposite effect by increasing costs and requiring grant applicants to devote additional time and resources to logistical and administrative tasks. We respectfully urge OMB to reconsider these proposed revisions, which undermine the merit-based, gold-standard system that has positioned the U.S. as the global leader in science, threaten to impact future advances in medicine, crop yields, and gene therapies, and weaken American economic competitiveness. Basic research is a major driver of the technological advancements that have long made the U.S. the world leader in science and powered our nation’s continued economic growth.

Respectfully submitted,

The Genetics Society of America Executive Committee, on behalf of the Board of Directors

Cassandra G. Extravour, President
David Greenstein, Vice President
Brenda J. Andrews, Past President
Maureen Barr, Secretary
Mary C. Mullins, Treasurer