Comments Submitted to the Members of the Office of Management and Budget

Press Release - For Immediate Release
July 13, 2026
Contact: contact@aaup-hfc.org

AAUP-HFC Comments Submitted to the Members of the Office of Management and Budget

13 July 2026

Dear Director Vought and Members of the Office of Management and Budget:

We write to strongly oppose proposed rule OMB-2026-0034 and urge OMB to withdraw the rule in its entirety. The proposed rule extends the authority of the Office of Management and Budget in ways that far exceed its legal authority, threatening the ability of Congress to establish funding priorities for the people of the United States and, instead, providing the President with undue power to advance a partisan agenda. Specifically, the proposed rule would formally give political appointees authority to review and approve grants before they are issued, with peer review demoted to at best an advisory consideration; expand agencies’ power to terminate or suspend grants already underway at any time, whenever a project is deemed to longer serve “agency priorities”; and let agencies weigh an applicant's “institutional practices, affiliates and risk indicators” in funding decisions rather than focusing on financial and technical merit. Such changes will make all research more precarious. These shifts in OMB policy are a direct threat to the health and wellbeing of United States’ citizens, in part because they undermine critical research in the fields of medicine, public health, education, and public policy.

As the executive committee of Harvard University’s chapter of the American Association of University Professors, we have experienced firsthand the overreach of executive power. Over the last year and half, the Trump Administration has regularly targeted our university by terrorizing our international students, withholding funding, demanding our administration halt equity initiatives, and restricting our students’ freedom of expression. This executive overreach has required that we spend countless hours and dollars advocating for our constitutional rights rather than engaging in our core work: advancing scientific research, practice, and policy for the public good. As one of our members wrote in her public comment:

The proposed rule seeks to enshrine in regulation what the federal administration has inflicted upon my university (Harvard University) and me personally this past year: arbitrary termination of grants, at any time in the life of the grant [200.340]; refusal to fund research that does not align ideologically with the politics of the Executive Branch, including research that discovers and documents disparate impacts and addresses health disparities [200.218; 200.300]; impeding the ability of scientists to travel to conferences and pay the costs for open access publication [200.432; 200.461]; rendering it more difficult to have foreign collaborators [200.220]; and empowering the belief that power, not evidence, should determine which research is deemed worthy of funding.

Our members understand firsthand the ways in which arbitrary political decisions about what we research and pass along to the next generation can threaten the health and wellbeing of everyday Americans. The prospect of anytime, abrupt funding terminations is destabilizing to both scientific research and population health. Grant instability, terminations, and censorship in university settings have vast negative impacts, not only on scientific research but also on the health outcomes of people affected by the conditions and diseases for which research provides critical lifelines and life-saving therapies. This is particularly profound in the case of health disparities research, where arbitrary terminations can further deteriorate the health outcomes of vulnerable populations. Furthermore, decades of research illustrate the critical importance of government fundings to civil society – including education, transportation, childcare, food security, libraries and more; when the federal government becomes an unreliable partner to these civic institutions, everyday Americans suffer.

Among our membership are faculty whose research, practice, and advocacy would likely be impacted by:

●      The discretionary termination of grants to agencies such as Medicaid, WIC (Women, Infants and Children), SNAP, Head Start and Early Head Start, school lunch and breakfast programs, Section 8/Housing Choice Vouchers, Children's Health Insurance Program (CHIP), LIHEAP energy assistance, NIH, Community Health Centers (HRSA), Ryan White HIV/AIDS Program, Meals on Wheels/senior nutrition, behavioral health/substance use treatment, TANF, and tribal governments. These grants not only support ongoing research and policymaking, but also directly impact the day-to-day health of millions of Americans, including large populations of elderly Americans and children. (§200.340)

●      The denial of grants not aligned with political priorities, which might impact NIH health disparity/Long COVID/ME/CFS research, CDC public health surveillance, NSF social science and education research, USAID global health research, Department of Education research, Veterans Affairs health research, DOE clean energy/ climate research, SAMHSA mental health research, HHS family planning/reproductive health research, and rural/Appalachian community development research. (§200.202)

●      The denial of grants based on organizational affiliations, which might impact Universities with international research partners, LGBTQ+ health and advocacy organizations, civil rights law clinics/legal aid, environmental justice nonprofits, immigrant services organizations, academic centers on democracy/voting, faith-based social service organizations, HBCUs and tribal colleges, journalism schools/First Amendment centers, and labor unions/worker advocacy orgs. (§200.206)

●      The denial of grants based on DEI and related prohibitions, which would directly affect health disparities research, Title I and IDEA education programs, Head Start, minority-serving institution grants, and women's health research (NIH ORWH). (§200.300)

●      The denial of disparate impact research grants, which would directly affect Long COVID and ME/CFS research, environmental justice research (EPA), public health epidemiology (CDC), education research on achievement gaps, housing discrimination research (HUD), occupational health research (NIOSH), criminal justice reform research (DOJ), child welfare research, climate and health research, and disability employment research (DOL), among others. (§200.218)

●      And, the denial of grants that speak to core issues of public wellbeing, such as grants given to public health organizations, patient advocacy nonprofits, University extension programs, community health workers, science journalism / communication training, environmental nonprofits (EPA grants), legal aid organizations, Native cultural preservation programs, fair housing counselors (HUD grants), and disability rights organizations. (§200.450)

We consider these threats to the health and wellbeing of all Americans, as well as to our core work as university researchers. We strongly urge OMB to withdraw rule OMB-2026-0034 in its entirety.

 

Signed,

The Executive Committee of the Harvard Faculty Chapter of the American Association of University Professors

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On the Termination of the Director of the Harvard FXB Center for Health and Human Rights