July 2026 Update
AFAR's Response to Federal Proposed Scientific Review Changes
AFAR has submitted comments to the Office of Management and Budget regarding proposed revisions to the Guidance for Federal Financial Assistance. While AFAR supports transparency, accountability, and responsible stewardship of federal funds, we are concerned that several provisions, if applied to NIH and other federal science agencies without revision, could weaken scientific peer review, disrupt ongoing research, and create new administrative barriers for biomedical research.
As seen below, AFAR’s comments emphasize the importance of preserving NIH’s expert-driven, merit-based review system; protecting ongoing peer-reviewed research from abrupt termination; avoiding the use of indirect cost rates as a proxy for scientific merit; maintaining legitimate international scientific collaboration; and allowing reasonable costs for publication, conference participation, and scientific dissemination.
Researchers and institutions who wish to comment may submit their own response directly through Regulations.gov. The proposed rule and comment portal are available here.
The comment period closes on July 15.
"To Whom It May Concern:
On behalf of the American Federation for Aging Research (AFAR), thank you for the opportunity to comment on OMB's proposed revisions to the Guidance for Federal Financial Assistance.
AFAR is a nonprofit dedicated to advancing the biology of aging. Since 1981, AFAR has awarded more than $225 million in grants, building the next generation of scientists and accelerating discoveries that extend healthspan and reduce age-related disease.
AFAR strongly supports transparency, accountability, and stewardship of taxpayer dollars. However, several provisions, if applied to NIH without revision, could weaken the expert-driven, merit-based grantmaking system that has made the U.S. the global leader in biomedical discovery.
NIH-funded research is a long-term investment in health and innovation. Many major advances have emerged from investigator-initiated research whose value wasn't obvious at award—especially true in geroscience, which studies the biology of aging underlying Alzheimer's, cancer, cardiovascular disease, and frailty, shifting medicine toward preventing multiple chronic conditions at once rather than treating diseases individually.
AFAR urges OMB to revise the rule to preserve scientific peer review, protect ongoing research, avoid using indirect cost rates as a proxy for merit, and ensure administrative requirements don't impair scientific collaboration and dissemination.
First, AFAR is concerned the merit review provisions could create a parallel process where peer review recommendations are displaced by non-scientific considerations. NIH already has rigorous review including peer review, programmatic review, conflict-of-interest protections, and Institute/Center oversight. Award decisions should remain grounded in scientific merit, public health significance, feasibility, qualifications, innovation, and mission alignment.
AFAR recommends OMB clarify that pre-issuance review for NIH should focus on legal compliance, eligibility, risk management, conflicts, and alignment with the funding opportunity's purpose—not override peer review absent a documented, award-specific basis. Vague terms such as "anti-American values" should be replaced with clear, objective, administrable standards.
Second, AFAR is concerned by the proposal that, "all else being equal," preference be given to institutions with lower indirect cost rates. This should not apply to NIH awards. Indirect cost rates are not a measure of scientific quality or institutional integrity—they reflect negotiated costs for facilities, compliance, animal care, clinical infrastructure, data security, and biosafety essential to rigorous research. Using them as a selection preference could penalize institutions with the infrastructure needed for high-quality science. AFAR recommends OMB remove this provision for research grants or clarify that indirect cost rates may not factor into merit review or award selection unless expressly authorized by statute.
Third, AFAR urges OMB to protect ongoing biomedical research from broad discretionary suspension or termination. Such research often involves longitudinal cohorts, clinical studies, animal models, and multi-year data collection. Sudden disruption wastes prior federal investment, harms participants, compromises irreplaceable datasets, and damages early-career investigators—a particular concern in aging research, where studies of healthspan and resilience require long-term follow-up. Termination should be limited to clearly defined bases: material noncompliance, loss of eligibility, documented integrity concerns, lack of appropriated funds, or scientific infeasibility. A general change in Administration priorities should not, by itself, justify terminating an ongoing peer-reviewed award.
Fourth, AFAR supports strong safeguards for research security and intellectual property but urges OMB to preserve legitimate international scientific collaboration. Aging research often benefits from unique cohorts, population data, and biological samples not available in the U.S. alone. OMB should distinguish between restrictions on countries or activities raising security concerns and ordinary collaboration with trusted partners. NIH should retain the ability to support U.S.-led projects with international components when justified and reviewed.
Finally, AFAR urges OMB to preserve reasonable costs for publication, conference participation, professional memberships, and scientific dissemination—core mechanisms by which findings are validated, replicated, and translated into future discovery and clinical practice.
AFAR shares OMB's interest in accountability and stewardship of federal funds. However, the rule should be revised to ensure these goals do not undermine the merit-based, stable research enterprise that has produced extraordinary returns for the American people.
Thank you for considering these comments.
Sincerely,
Steven N. Austad, PhD
Scientific Director, AFAR"