
When Political Appointees Outrank Peer Review: How a New Office of Management and Budget Rule Could Reshape Spectroscopy and Scientific Research Funding
Key Takeaways
- Mandatory pre-issuance review by political appointees would subordinate peer-review rankings to alignment with presidential priorities, effectively converting merit review into an advisory input for discretionary awards.
- Introduction of “termination for convenience” authority would enable unilateral cancellation of active grants without appeal, destabilizing multi-year instrumentation, trainee support, and deliverable-driven research timelines.
A rule proposed by the White House Office of Management and Budget (OMB) would give political appointees final authority over discretionary grant decisions ahead of peer reviewers, allow agencies to terminate active grants without a formal right of appeal, and restrict international collaboration and publication funding across federal science agencies. For the optical, molecular, vibrational, and atomic spectroscopy community, the proposal could affect the grants, journal support, and student and postdoctoral positions that sustain the field.
Abstract
On May 29, 2026, OMB published a proposed rule titled "Regulation for Federal Financial Assistance" that would rewrite the government-wide framework governing grants and cooperative agreements codified in Title 2 of the Code of Federal Regulations (2 CFR). The rule would give political appointees pre-issuance authority over discretionary awards, permit agencies to terminate active grants "for convenience," restrict collaboration with researchers affiliated with a defined list of foreign countries, and make journal publication costs and open access fees presumptively unallowable. Scientific societies, universities, and publishers have said these changes would disrupt the merit-based, internationally collaborative research culture that has long supported optics and photonics, including molecular, vibrational, and atomic spectroscopy. This editorial reviews the proposed rule's major provisions, considers their likely effects on spectroscopy-related journal publishing, grant applications and peer review, and student and postdoctoral funding, and outlines funding alternatives that laboratories might pursue should the rule take effect as written.
Introduction
For most of the past eight decades, federal grantmaking in the United States has rested on a fairly stable premise: agency scientists and external peer reviewers evaluate proposals on technical merit, and program officers make award decisions within that framework. On May 29, 2026, OMB proposed to rewrite that framework. Published in the Federal Register as "Regulation for Federal Financial Assistance," the rule would revise 2 CFR, the Uniform Guidance that governs how federal agencies award and administer grants and cooperative agreements.1 SPIE, the International Society for Optics and Photonics, was among the first professional societies to alert its membership, stating that the proposal "would fundamentally reshape how federal research funding is awarded, managed, and enforced across all agencies,"2 with direct consequences for optics and photonics research. The comment period, open for only 45 days, closed on July 13, 2026; a University of North Carolina analysis conducted in partnership with STAT News (statnews.com) found that 496,769 comments had been submitted by the deadline, with roughly 95 percent recorded in opposition and about 1 percent in support.3 This article summarizes what OMB has proposed, examines what it could mean for optical, molecular, vibrational, and atomic spectroscopy research specifically, and considers what funding alternatives might exist if the rule is finalized largely as written.
A Uniform Guidance Overhaul, Compressed into 45 Days
OMB frames the rule as an effort to improve transparency and accountability for taxpayer dollars, clarify OMB's regulatory authority over 2 CFR, and reduce administrative burden on award recipients.1,4 The proposal would apply to new awards and to new incremental funding actions on existing awards beginning October 1, 2026, the start of the federal fiscal year.1 Because 2 CFR governs discretionary and formula grant programs across virtually every federal agency, the rule's reach extends well beyond any single funder.5 It would apply equally to the National Science Foundation (NSF), the Department of Energy (DOE) Office of Science, the National Aeronautics and Space Administration (NASA), the National Institute of Standards and Technology (NIST), and the National Institutes of Health (NIH), the agencies that collectively fund most U.S. spectroscopy research.6 Research-policy analysts have described it as among the most consequential revisions to federal grant-management policy since the current Uniform Guidance framework was established in 2013.6
Peer Review Becomes Advisory
Among the rule's central provisions is a requirement that every discretionary grant undergo "pre-issuance review" by senior political appointees before it can be awarded, rather than being decided by career program officers acting on the recommendations of peer reviewers.7 Under the proposed text, officials conducting that review may not simply accept peer-review rankings as final; each award must instead be shown to "demonstrably advance the President's policy priorities."1,6 In practice, this could convert peer review from a binding determination of scientific merit into an advisory input, since a political appointee would not be required to accept a peer reviewer's assessment. Physical societies have said this change would undermine the merit-based system that has underpinned U.S. scientific leadership for decades.8,9
Grants Without Guarantees
The proposal also introduces a contract-style "termination for convenience" clause: an agency could end an active, already-funded award at any point if it decides the project no longer serves the agency's current goals or the national interest, and the recipient would have no formal right to appeal that decision.6,7 For a multi-year spectroscopy grant supporting an instrument build, a graduate student's dissertation, or a postdoctoral appointment, this would mean that funding already awarded and budgeted for could disappear mid-project, with little recourse for the principal investigator or the institution.
International Collaboration Faces New Restrictions
The rule would also prohibit spending federal funds on direct programmatic activities, research, technical assistance, data-sharing, travel, or indirect costs involving "covered foreign countries" or affiliated entities, unless expressly authorized by statute or a federal agency head. Covered countries include those designated as foreign adversaries or subject to national-security-related restrictions, a list that currently includes China, Russia, Iran, and North Korea.10 Spectroscopy is an intrinsically international field, built on decades of shared instrumentation standards, jointly authored papers, and collaborative facility access; broad restrictions on collaboration with researchers in or affiliated with these countries could complicate co-authorship, joint spectroscopy beamline experiments, and sharing of datasets, even in cases where the underlying science may carry little or no national-security sensitivity.
The Price of Being Published
A separate provision would flip the default on journal publication costs: page charges, article processing charges, and open access fees would shift from allowable to unallowable, unless a federal statute specifically requires them or the funding agency pre-approves the expense on a case-by-case basis.7 Research libraries and scholarly publishers have said this provision sits in tension with existing federal open-access mandates that require publicly funded research to be freely available.11 For spectroscopy researchers, who routinely publish in society and commercial journals that charge processing or open-access fees, the practical effect could be a return to paywalled publication, reduced ability to comply with funder open-access requirements, or costs shifted onto departments and institutions with limited budgets to cover them.12 These changes will surely have an affect on journal joices for researchers.
Who Gets to Apply, and Who Gets to Know
The proposal expands the risk factors an agency may cite to deny an application to include an applicant's organizational affiliations, specifically membership in or affiliation with organizations that agencies determine "advocate for the overthrow of the United States Government" or "undermine public safety or national security."13 Critics have said these terms are not clearly defined, leaving broad discretion in the hands of reviewing officials. A related provision would let an agency head exempt a funding opportunity from the standard requirement to post it publicly on Grants.gov whenever public announcement is deemed a risk to national security or contrary to the national interest, reducing visibility into which competitions exist and who is eligible to apply.14
What This Adds Up to for Spectroscopy Research
Taken together, these provisions touch every stage of the spectroscopy research pipeline. Journal papers could become more expensive to publish openly or harder to make publicly accessible. Grant applications could face an additional layer of political review beyond peer evaluation, and awarded grants could be terminated mid-project regardless of scientific progress. International collaborations that underpin much of modern molecular, vibrational, and atomic spectroscopy, from joint synchrotron experiments to shared spectral databases, could require new compliance review or be curtailed outright. Graduate student and postdoctoral positions, which are typically funded directly off active grants, are especially exposed to the termination-for-convenience provision, since a single mid-year cancellation can end a funded position with little warning. These risks arrive on top of an already constrained funding environment: internal NSF memos reported in June 2026 showed budgets for hundreds of core science programs cut by 20 to 30 percent for the current fiscal year, and NSF had awarded only about one-eighth of its typical number of new grants through mid-June 2026 compared with the same point in the prior year, changes that agency insiders linked to an effort to redirect funding toward a new technology initiative.15,16 Nature has separately reported that NSF is redirecting previously planned funding from several directorates to help finance that initiative,17 and the American Physical Society (APS) has tracked a broader slowdown in NSF grantmaking alongside renewed proposals for deep cuts to the agency's budget.18 NIST's Atomic Spectroscopy Group, a 120-year-old source of reference spectral data used throughout the field, was itself eliminated in 2025 before its scientific team was reconstituted at NASA Goddard Space Flight Center and the University of Maryland.19
Conclusions
OMB has proposed to rewrite the government-wide rules governing federal grants and cooperative agreements, with an effective date of October 1, 2026, for new awards and new funding increments. As written, the rule would place political appointees, rather than peer reviewers, in the final decision-making role for discretionary grants; allow agencies to terminate active awards without a formal right of appeal; restrict collaboration and spending involving researchers connected to a defined list of foreign countries; make publication and open-access costs presumptively unallowable; expand the grounds on which applicants can be denied based on organizational affiliation; and permit some funding competitions to be withheld from public notice. The 45-day comment period closed on July 13, 2026, with 496,769 comments submitted; an analysis by University of North Carolina researchers working with STAT found roughly 95 percent in opposition and about 1 percent in support, though OMB has not yet indicated whether or how the final rule will be revised in response.3 Scientific societies, research universities, and some industry groups also submitted public comments opposing the proposal.20
For spectroscopy researchers concerned about funding continuity, it may be worth considering approaches that do not depend solely on federal discretionary grants. Private foundations, including the Gordon and Betty Moore Foundation, the Alfred P. Sloan Foundation, the John Templeton Foundation, and the Research Corporation for Science Advancement, have long supported early-career and instrumentation-focused physical science research and have shown willingness to expand that support as federal funding has become less predictable.21 Larger philanthropic initiatives, such as the Chan Zuckerberg Initiative and the Gates Foundation, have also substantially increased their science budgets in recent years as federal funding has grown less certain.22 Industry partnerships, particularly with photonics, semiconductor, and instrumentation companies that depend on spectroscopic techniques for their own product development, can offer more flexible and faster-moving support than federal cycles, sometimes in the form of jointly funded graduate fellowships. State-level research funding programs, though modest and variable in scope, can help bridge gaps for regional institutions and early-stage projects. Professional societies such as SPIE and Optica already offer travel grants, student awards, and seed funding, and might expand these programs if federal support contracts. Finally, institutions may find value in pooling indirect-cost savings or forming multi-university consortia to jointly fund shared instrumentation and facility access, reducing reliance on any single award. None of these alternatives fully replaces the scale or stability of federal support, but together they may offer a partial hedge should the OMB rule take effect substantially as proposed. Time will tell.
References
1. Office of Management and Budget. Regulation for Federal Financial Assistance. Federal Register, May 29, 2026.
2. SPIE. Proposed Federal Rule Will Have Detrimental Impacts to the U.S. Research Community; SPIE: Bellingham, WA, 2026.
3. Oza, A.; Parker, J. E. Flood of Comments on White House Grantmaking Overhaul Is Largely Negative, Analysis Shows. STAT, July 15, 2026.
4. Quinn, R. OMB Proposes Rules Establishing Political Oversight of Grants. Inside Higher Ed, May 29, 2026.
5. Hamill, C.; Dalal, R. Breakdown of OMB Proposed Rule: Regulation for Federal Financial Assistance. American Astronomical Society, June 2026.
6. Mosley, B. OMB Proposes Sweeping Overhaul of Federal Grant Rules. CRA GovAffairs Blog, Computing Research Association, June 22, 2026.
7. American Physical Society. OMB Proposed Rule for Federal Financial Assistance. American Physical Society.
8. McKenzie, L. White House Plan to Take Over Federal Grantmaking Draws Criticism from Science Groups. American Physical Society, June 2026.
9. Kovac, A. Scientists Overwhelmingly against Rule Change That Would Give Political Appointees Say over Science Grants. Scientific American, July 14, 2026.
10. Zhang, C. OMB Proposes Broad Restrictions on International Research. AIP FYI, American Institute of Physics, June 18, 2026.
11. LaFlamme, M. Guest Post: Why Research Libraries Oppose the OMB Revisions to the Uniform Guidance. The Scholarly Kitchen, July 9, 2026.
12. AIP Publishing LLC. AIP Publishing's Response to the Proposed OMB Rule. AIP Publishing LLC, July 14, 2026.
13. Quinn, R. Comments Flood OMB Proposal on Political Control of Grants. Inside Higher Ed, July 7, 2026.
14. Barnes, M.; Thornton, L. A.; Caron, M. M.; Sencer, S. D.; Curry, N.; Ravelo, C. A.; Roberts, C. S. OMB Proposed Revisions to the Uniform Guidance: Key Takeaways for Award Recipient Organizations. Ropes & Gray LLP, June 2026.
15. van Deelen, G. NSF Cuts Hundreds of Science Program Budgets by Up to 30%. Eos, June 2026.
16. Mervis, J. Exclusive: NSF Slashes Research Programs to Support New Tech Initiative, Insiders Say. Science, June 23, 2026.
17. Garisto, D. NSF Plans Cuts to Core Science Programmes to Fund White House Initiative. Nature, July 9, 2026.
18. American Physical Society. NSF Lags in Grant Awards and Trump Again Proposes Deep Cuts to Science. American Physical Society, April 2026.
19. Brumfiel, G. Trump Cuts Threaten a Measurement Lab Critical for Advanced Chips and Medical Devices. NPR, March 26, 2025.
20. Lee, B. The New Trump OMB Rule: Organizations and the Public Raise Concerns. Forbes, July 5, 2026.
21. Feder, T. Philanthropy Plays a Growing Role in Funding US Physical Sciences. Phys. Today 2022, 75 (11), 24.
22. Gewin, V. Meeting the Moment: How Scientific Philanthropies Are Expanding Their Reach. Nature, April 22, 2026.




