Political Veto: How OMB's Grant Rule Puts EHE at Risk

In February 2025, this blog documented how the Trump administration was using language screens and funding restrictions to make health equity research professionally toxic. At the time, the mechanisms were informal: terms flagged for review, grants quietly pulled, researchers left to guess where the new boundaries lay. That ambiguity is ending. On May 29, 2026, the White House Office of Management and Budget (OMB) published a 412-page proposed rule in the Federal Register that converts informal pressure into binding, government-wide law. Holden Thorp, editor of Science, wrote that the administration "seems as determined as ever to mortally wound the nation's scientific enterprise," noting that research enjoys bipartisan support and that public trust in science sits above 75 percent. Within days of publication, more than 3,000 public comments had been filed, almost all in opposition. The comment period closes July 13, 2026.

The pattern is familiar. As we noted last year, the Dickey Amendment showed how funding restrictions can suppress an entire field without an explicit ban. This rule removes the need for subtlety.

How We Got Here

The proposed rule is the endpoint of a deliberate sequence. On May 23, 2025, President Trump signed Executive Order 14303, "Restoring Gold Standard Science," which introduced an undefined "Gold Standard Science" standard that agencies would later be required to enforce. On August 7, 2025, EO 14332, "Improving Oversight of Federal Grantmaking," directed agency heads to designate senior political appointees to review all discretionary awards for whether they "demonstrably advance the President's policy priorities." Representative Zoe Lofgren (D-CA) called the order "nothing short of obscene," objecting that unelected appointees would decide what science gets funded.

During the administration's first year, courts found its abrupt termination of thousands of grants to be illegal. The OMB rule is built to insulate that same conduct from future legal challenge by establishing a formal process for it. As the American Council on Education's Sarah Spreitzer observed, the rule attempts to lock in administratively what the administration has spent eighteen months trying to accomplish.

What the Rule Actually Does

Three structural changes matter most for people working in public health.

First, the rule requires senior political appointees to conduct a "pre-issuance review" of every discretionary grant before it is awarded, and explicitly forbids them from deferring to peer reviewers. The criteria they must apply include blocking awards that touch on denial of "the sex binary in humans" and requiring that awards demonstrably advance the President's policy priorities.

Second, the rule downgrades peer review itself. Recommendations from scientific experts "remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding." This dismantles the post-World War II system in which independent expert review served as the primary measure of scientific merit at the National Institutes of Health (NIH), the National Science Foundation (NSF), and nearly every science agency. Neal Lane, who led the NSF under President Clinton, warned that replacing merit review "with top-down decision-making will destroy that process and result in bad science being funded."

Third, the rule lets agencies terminate active grants at any point, for being "inconsistent with program goals or agency priorities," with only a brief written rationale and no finding of misconduct or fraud required. Multi-year projects that researchers and institutions have built programs around can be ended mid-stream. Elizabeth Ginexi, a former NIH program official of 22 years, described the rule as "a complete political control apparatus layered over every stage of the federal science funding lifecycle."

The Infectious Diseases Society of America stated that, if finalized, the rule would compromise "medical research, public health, and healthcare access for vulnerable populations."

The Collateral Damage

The rule reaches past the award decision into the daily machinery of science. Publication costs, including the article-processing and open-access fees that average more than $3,000 per paper, would become presumptively unallowable, conflicting with the 2022 federal mandate requiring publicly funded research to be publicly available. Conference attendance would require express agency pre-approval written into the award at the time it is issued, and subscriptions to professional journals would be made categorically unallowable. A separate "issue advocacy" prohibition could bar federally funded researchers from speaking publicly about their own findings on contested subjects.

For HIV and viral hepatitis work, these provisions constrain the channels through which prevention and care evidence reaches the field: peer-reviewed publication, conference presentation, and public communication.

Why This Lands Hardest on People Living with HIV

The rule's prohibitions on diversity, equity, and inclusion research, "gender ideology," and disparate-impact analysis target the precise body of evidence that explains HIV transmission and care outcomes. Social determinants of health are the drivers of the epidemic, and we have the data to prove it.

The CDC's 2025 SDOH update found that, of the 38,416 adults diagnosed with HIV in 2023, 82.7 percent were linked to medical care within one month and 70.7 percent achieved viral suppression within six months. The lowest linkage and suppression rates concentrated in counties with the highest poverty, lowest income, lowest insurance coverage, and heaviest housing cost burden. The relationship is dose-dependent. In a 2021 study published in Open Forum Infectious Diseases, Menza and colleagues reported that 83 percent of people with HIV experienced at least one adverse social determinant, and those facing four or more were 3.6 times as likely to miss a medical appointment and 20 percent less likely to achieve durable viral suppression than those facing none.

County-level analysis confirms the pattern. A 2025 study in AIDS and Behavior by Lockhart and colleagues found that uninsurance, rent burden, medically underserved status, and overcrowded housing were associated with higher HIV diagnosis rates across 344 U.S. counties. Ending the HIV Epidemic (EHE) priority jurisdictions averaged 83.16 diagnoses per 100,000 people, compared with 13.76 in non-EHE counties, and carried higher income inequality and larger Black populations.

This is the research the rule puts at risk. Disparate-impact analysis is the method used to determine whether prevention and treatment reach the Black, Latino, and transgender communities most affected by HIV. A study framed around structural barriers to care could now be vetoed by a political appointee before it begins or terminated after it starts. When we lose the ability to document where the epidemic concentrates and why, we lose the map that EHE depends on.

What We Can Do

The comment period is the most direct point of leverage available, and OMB is legally required to respond to every comment it receives. Researchers, clinicians, universities, patient-advocacy organizations, and state health departments can file comments at regulations.gov under Docket OMB-2026-0034 before July 13, 2026. The strongest comments document concrete harm: how termination-for-convenience destabilizes a multi-year research program, or how the disparate-impact ban prevents evaluating whether PrEP outreach is reaching the communities EHE prioritizes. Stand Up for Science and the Infectious Diseases Society of America are organizing structured comment campaigns. Advocates can also press members of Congress, who appropriated these funds expecting merit-based administration, to prepare oversight.

The cost of this rule will be measured in slowed progress and lost capacity. Researchers and manuscripts are already shifting abroad, and the rule's restrictions on international collaboration will accelerate that drift, handing other countries an opening the United States built its scientific leadership to prevent. For people living with HIV, a documented and studyable understanding of social determinants is the foundation of any credible path to Ending the HIV Epidemic. We protect that foundation by populating the comment record before July 13.