The United States’ Office of Management and Budget (OMB) recently released a set of proposed revisions to its Regulations for Federal Financial Assistance, also called the Uniform Guidance, that would change the way the federal government administers scientific research awards. Much has been written about this proposal by members of the scientific community; most are highly critical of the suggested revisions believing that they introduce politics and administrative overreach into the country’s research agencies to the detriment of science. There is a public comment period that closes July 13; I encourage all stakeholders to make their voices heard.
The OMB’s proposed revisions are the most recent manifestation of a longstanding national debate regarding the proper framework for American scientific stewardship. Two of OMB’s proposals—the addition of a political review to individual funding decisions for research awards and the allowance of award terminations of currently funded federal research for political reasons—are, in many ways, a science policy redux. Understanding their historical and political context is important to identifying successful solutions.
At the heart of this policy debate is a simple question: Should “scientific merit” or “policy priorities” guide American research stewardship? In this opinion piece, I argue for the primacy of scientific merit and the importance of connecting the life-changing discoveries that meritorious science generates to this stewardship framework.
OMB’s Proposed Revisions Introduce Politics into Science
Among the numerous proposed revisions to the Uniform Guidance that affect federal science agencies are two that would introduce politics and political oversight into the grantmaking process. The first, section 200.205, proposes that agency merit review of research award proposals include “a new pre-issuance review process” to ensure that, among other objectives, “discretionary awards advance the President’s policy priorities.” The second, section 200.340, proposes a new discretionary termination provision that allows for agency termination of a federal research award if it “no longer effectuates program goals, federal agency priorities, or the national interest.”
Together, sections 200.205 and 200.340 would introduce an unprecedented level of political influence over the awarding and ongoing financing of federal research awards. For example, an award proposal ranked highly after scientific review (i.e., an award that was considered highly meritorious by a group of scientists knowledgeable in the proposed field) could be denied funding in favor of a less scientifically meritorious proposal that was more aligned with the policy priorities of the administration. Similarly, a previously funded, scientifically meritorious research award in the middle of its experiments could be terminated for no other reason than shifting policy priorities.
Stated more generally, these two changes would allow policy priorities of the administration to overrule scientific merit in deciding what research the federal government funds and whether to continue funding it.
As I will discuss below, I believe such a framework for research grantmaking would be bad not only for American science but also for society at large. But first it is important to recognize that the question of whether scientific merit or policy priorities should guide American research stewardship is not a new one.
The History of American Science Stewardship
OMB’s proposed changes are best understood in the context of the larger historical debate around American science stewardship that dates to the mid-20th century.
After World War II, there was widespread recognition of the importance and impact of science.1 Antibiotics, radar, and nuclear weapons—among other discoveries—had dramatically changed the world, and there was broad consensus that investment in scientific discovery and innovation would translate to improved wellbeing, safety, and security. There was substantial debate, however, over how best to govern and administer such an investment. Two competing frameworks emerged.
The first framework proposed that federal research priorities and projects be governed by scientists, prioritized based on their potential to generate new knowledge (in other words, their scientific merit).2 This framework was championed by Vannevar Bush, director of the Office of Scientific Research and Development under Presidents Roosevelt and Truman. In his 1945 report to the President, Bush called for investing in research “without thought of practical ends.”
The second framework proposed a more politically accountable governance, prioritizing federal research that directly advanced the nation’s societal needs. West Virginia Senator Harley Kilgore proposed legislation in 1944 to establish a National Science Foundation (NSF) that would oversee and, in many cases, conduct federal research with funding directed toward the policy priorities of the administration.
The policy debate over these two frameworks lasted for five years. In 1950, President Truman finally signed bill S.247, the National Science Foundation Act, a blended approach overall but largely adopting Bush’s scientific merit-based framework. In his statement accompanying the signing of S.247, President Truman referenced the rigorous debate. “I appreciate the fact,” he wrote, “that members of both parties in the Senate and the House of Representatives have worked unselfishly to reconcile divergent views concerning the organization of the foundation and its relationship to the executive and legislative branches of government.” This Act established the paradigm by which most federal research agencies, in particular the National Institutes of Health (NIH) and NSF, still function today.
Scientific Merit, Not Policy Priorities, Should Drive American Science
My perspective on the role of government in the stewardship of American science is closely aligned with that of Bush and the primacy of scientific merit. In moving the federal government’s north star for science away from scientific merit and toward policy priorities, OMB’s proposed revisions to the Uniform Guidance constitute a foundational threat to America’s scientific future. Transformative scientific discoveries simply cannot be predicted by policy priorities. It is often the case that research in an area far removed from societal need (for example, childhood cancers or dementia) has the most profound impact. As Stuart Firestein, biological scientist and chair of Columbia University’s Department of Biological Sciences, wrote, “It’s hard to see what will be and also what will not be.”1 He added, “Predicting or targeting some specific advance is less useful than aiming for deeper understanding.” Our best strategy is to fund the best science without thought of practical ends and trust that this framework will continue to yield unexpected breakthroughs that change the world.
The scientific merit-based framework that Bush promoted, that Congress established, and that we have today reflects a social contract with the American public in need of regular renewal. This renewal has become more challenging over the years as science and society have drifted apart, and the value of investing federal dollars in research has become more difficult for the public to appreciate. Former Congressman and chief executive officer emeritus of the American Association for the Advancement of Science Rush Holt wrote, “In the belief that scientific progress ultimately relies on the freedom of the scientist to pursue basic research without thought of practical ends, [Bush] promoted a system that…has also had the effect of distancing science from the public, and vice versa.”2 The result, Holt said, is that society has lost touch with the impact and value of science, and they have turned away.
I applaud the many individuals and organizations that have recently redoubled their efforts to connect their science to their community. Science saves lives and makes life better for the American public. Its societal impact is enormous. It has always been incumbent on the scientific community to connect their work to the public good through engaging and educating society. As Holt wrote, “Scientists must accept their responsibility to act particularly in the public interest, to be responsible to the citizenry who give them the license to do their work.” As scientists responds to the OMB’s immediate challenge to scientific merit-based funding, the larger political dynamics and discourse require equal attention.
The science policy issues at the heart of the OMB’s current proposed revisions have been debated for close to a century. In my view, this is a debate that is appropriately continued in Congress, not the Executive branch. Congress should exert its lawmaking power and reclaim this discussion through the process of Congressional reauthorization. The scientific community needs to participate and demonstrate to their elected leaders, and the American public, that the nation is best served by continuing the social contract established between the federal government and the scientific community those many years ago. This contract was build on a framework that prioritized and promoted scientific merit-based funding. Scientific merit as determined by scientists, not political appointees. Scientific merit as measured by the advancement of scientific knowledge, not policy priorities.
This opinion piece represents my own personal view and perspective and does not represent the view or perspective of the University of California.
- Firestein S. Ignorance: How it drives science. (Edition if applicable). Oxford University Press; 2012.
- Bush V, Holt RD. Science, the endless frontier. Princeton University Press; 2000.
