An Urgent Message from IAPHS Leadership

Dear IAPHS members:

We want to alert you to proposed changes to Federal agencies, such as the NIH, that, if enacted, would have potentially catastrophic consequences on science and population health. Because the changes would also impede IAPHS’s mission to “provide a forum that will connect population health scientists across disciplines and sectors, advance the development of population health science, and promote its application,” the IAPHS officers are preparing a public comment on behalf of the organization.

This post provides information in three sections (1) a summary of the proposed changes, (2) how IAPHS members can formally respond to the changes, and (3) how to write and submit public comments by the July 13 deadline.

SECTION 1: THE PROPOSED CHANGES

The Office of Management and Budget (OMB) released a proposed rule titled “Regulation for Federal Financial Assistance” on May 29, 2026. The Consortium of Social Science Associations provides a summary of the proposed changes:

• Requiring that every new grant program explicitly aligns with the Administration’s policies and priorities, as opposed to scientific need, statutory mandate, or scientific community advice.
• Requiring that political appointees (not career scientists or program officers) within federal agencies sign off on grants before they are awarded to ensure that the funding will “demonstrably advance the President’s policy priorities.”
• Allowing for the termination of grants at any time if an agency determines they no longer “effectuate program goals, Federal agency priorities, or the national interest” — standards the agency may apply based on its priorities as they exist at the moment of termination.
• Restricting the use of federal funds to “fund, promote, encourage, subsidize, or facilitate” DEI or DEIA “policies, principles, or practices that violate any applicable Federal anti-discrimination laws” — a qualifier the rule leaves undefined, creating significant uncertainty about what research and programming would be permitted.
• Prohibiting the use of federal awards to “promote or support theories of disparate-impact liability,” with an exception so narrow it excludes published research — directly threatening the documentation of differential health outcomes across groups that is foundational to population health science.
• Significantly limiting international research collaborations.
• Allowing agencies to restrict eligibility among different types of nonprofit organizations, and to weigh an applicant’s “memberships and affiliations” when assessing the risk of funding them.
• Prohibiting the use of grant funds for articles’ open access costs — in tension with public-access expectations for publicly funded health research — and requiring prior approval for professional memberships and conference attendance.

These changes strike at the core of population health science. Our field is defined by interdisciplinary, community-engaged research that documents how health outcomes differ across populations — precisely the work these provisions would constrain. The burdens will fall especially hard on the students and early-career scientists among us, for whom unstable multi-year funding, politicized review, and new limits on conference travel and professional membership pose real barriers to building a career.

A terrific outline of the proposed changes is available in this post from Elizabeth Ginexi, a former NIH Program Official. It is a highly-regarded and illuminating post.Other summaries are available, such as here and here and this Nature article (paywalled).

SECTION 2: WHAT WE ASK IAPHS MEMBERS TO DO

• Contact your Congressional representatives, regardless of political party. Phone calls are better than emails but do what you can. You can find phone numbers at https://5calls.org/.
• ​Submit a comment BY JULY 13. You may find these guidelines helpful on how to write comments. They also explain why individual comments are essential:
  • “Under the Administrative Procedure Act, OMB must respond to every significant comment before finalizing the rule. A large volume of substantive comments serves three purposes:
    • It creates a record of opposition that courts can review if the rule is challenged
    • It forces OMB to defend each provision individually, potentially causing them to drop or narrow the most indefensible ones
    • It signals to Congress that the rule is controversial enough to warrant legislative action or appropriations riders
  • A form letter campaign is far less effective than individual substantive comments. OMB can dismiss 100,000 identical comments as a single comment. A single well-argued comment from a scientist, university, or professional society explaining exactly how a specific provision would harm a specific type of research carries far more weight.”

SECTION 3: HOW TO WRITE AND SUBMIT YOUR COMMENT

When preparing your comment, we encourage you to refer this post, which provides clear, step-by-step guidance on writing comments. In that post, there is a section called “How to Submit a Public Comment on the OMB Grant Rule: A Step-by-Step Guide for First-Time Commenters.” It is a particularly useful resource for all of us to follow.

Comments must be submitted by 11:59pm EST on July 13, 2026.

We will share the IAPHS’s public comment with its members in the coming weeks.

​Sincerely,

Jennifer Karas Montez, IAPHS President
Marino Bruce, IAPHS President-Elect
Philip M. Alberti, IAPHS Past President
Suzanne Bevan, IAPHS Executive Director