Johns Hopkins calls for preserving merit-based review in federal research funding

Johns Hopkins University has submitted a formal comment letter urging the U.S. Office of Management and Budget to reconsider proposed changes to federal rules governing all awards, grants, contracts, and other financial assistance across federal agencies, warning that the revisions could undermine the merit-based system that has helped make the United States the world leader in scientific discovery and innovation.

In the letter, Lainie Rutkow, interim provost, and Denis Wirtz, vice provost for research, said the university supports efforts to strengthen transparency, accountability, and responsible stewardship of taxpayer dollars, but expressed serious concerns that the proposed changes could weaken the longstanding partnership between the federal government and America’s research institutions.

“Many of the proposed changes would weaken the merit-based, expert-driven system that has made U.S. research the global standard; they would increase administrative burden for both agencies and research organizations, lead to waste or inefficient use of taxpayer resources, and destabilize the nation’s innovation ecosystem,” they wrote.

“America’s global leadership in research and innovation rests on a simple principle: Qualified experts should evaluate grant submissions to identify the best ideas through a transparent, scientifically rigorous, merit-based process.”

The changes stem from a May 29 notice of proposed rulemaking issued by OMB that would revise the government’s Guidance for Federal Financial Assistance, commonly known as the “Uniform Guidance.” The regulations, contained in 2 C.F.R. Part 200, establish government-wide rules for federal awards, including grants, contracts, and other forms of financial assistance. OMB allowed 45 days for public comments on the more than 400-page set of proposals, which would affect a wide range of processes across all federal agencies, including grantmaking, contract administration, international collaborations, and indirect costs associated with federally funded research.

The university’s concerns center on the critical role federally supported research plays in advancing discoveries that improve lives, strengthen the economy, and keep the United States at the forefront of global innovation. For decades, the partnership between the federal government and research universities has enabled lifesaving research, turning scientific discoveries into new treatments, technologies, and solutions for some of society’s most urgent challenges.

Founded in 1876 as the nation’s first research university, Johns Hopkins has demonstrated the impact of that partnership through generations of discovery. With support from federal research funding, Johns Hopkins researchers have developed new approaches to treating spinal injuries, harnessed artificial intelligence to help clinicians identify sepsis before it becomes deadly, and advanced promising discoveries targeting pancreatic cancer, Alzheimer’s disease, diabetes, and other life-threatening conditions.

In its comment letter, the university noted that Johns Hopkins faculty, students, residents, and alumni—including 29 Nobel Prize winners—have helped bring the benefits of scientific discovery to the world. Many of these breakthroughs have resulted from research supported by federal grants and contracts awarded through the competitive, merit-based peer review system that has guided federal research investments for more than 80 years.

“We are concerned that the proposed revisions could substantially alter the federal-university partnership and compromise the public benefits that flow from federally funded science, creating lasting adverse impacts on our institution and the nation,” Rutkow and Wirtz wrote.

A central concern outlined in the university’s letter is the potential minimization of the merit review process that federal agencies have relied on for decades to evaluate research proposals and direct taxpayer investments toward the most promising ideas. The proposed revisions would allow senior political appointees to conduct additional reviews of grant proposals and potentially depart from recommendations made by scientific and technical experts. Johns Hopkins warned that such a shift could replace an evidence-based process with one that is more subjective and less predictable.

“America’s global leadership in research and innovation rests on a simple principle: Qualified experts should evaluate grant submissions to identify the best ideas through a transparent, scientifically rigorous, merit-based process,” Rutkow and Wirtz wrote.

The letter emphasizes that a merit-review process driven by subject-matter experts helps ensure that federal dollars are invested in research with the greatest potential impact.

“A transparent expert-driven process ensures that federal investments are directed to the most scientifically rigorous and impactful projects,” Rutkow and Wirtz wrote.

The university also raised concerns that additional layers of review could significantly slow the distribution of research funding and create new burdens for federal agencies and research organizations. Federal agencies already manage a large and complex research enterprise, the letter noted, supporting hundreds of thousands of researchers across thousands of institutions. Adding new required reviews could delay critical research and create uncertainty for scientists working to address pressing challenges.

The university also objected to proposed changes that would expand the authority of federal agencies to suspend or terminate existing awards. Johns Hopkins warned that allowing grants to be ended without clear scientific or programmatic justification could disrupt research that has already undergone rigorous review and received federal support.

“A transparent expert-driven process ensures that federal investments are directed to the most scientifically rigorous and impactful projects.”

“Stable and predictable funding is essential to producing high-quality scientific outcomes,” the authors wrote.

Research institutions often commit significant resources alongside federal investments to support complex, long-term projects, including clinical trials and studies that take years to complete. Increased uncertainty, the letter said, could discourage ambitious research efforts and slow the development of new discoveries, diagnostics, and treatments.

Two prominent higher education consortiums that Hopkins belongs to—the Association of American Universities (AAU) and the Association of American Medical Colleges (AAMC)—also submitted formal letters objecting to the proposed changes.

Johns Hopkins said it welcomes continued dialogue with OMB on ways to strengthen oversight and ensure federal research funding delivers maximum benefit to the public. But the university urged the agency to withdraw or substantially revise the proposed rule.

“Taken together, the rule’s proposed changes would substantially weaken the American innovation ecosystem by eroding the government-university research partnership, reducing transparency, increasing burden, and fundamentally undermining merit-driven policies governing federal grant administration, to the detriment of federal research and institutions nationwide,” the authors wrote. “We strongly urge OMB to reconsider, withdraw, or substantially revise the proposed rule due to the serious concerns raised by its central provisions.”