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Friday, August 15, 2025

The Research Grant Filter

It should be noted that even if there is some kind of deal reached between UC/UCLA and the feds, future federal funding (grant renewals, new grants) will still be conditional on general filtering rules that would apply to any university and that have been recently adopted:

From a White House news release:

...Sec. 3.  Strengthening Accountability for Agency Grantmaking.  (a)  Each agency head shall promptly designate a senior appointee who shall be responsible for creating a process to review new funding opportunity announcements and to review discretionary grants to ensure that they are consistent with agency priorities and the national interest. For the avoidance of doubt, this process shall not guarantee any particular level of review or consideration to funding applicants except as consistent with applicable law.  As consistent with applicable law, this review process shall incorporate, at a minimum:

(i)    review and approval of agency funding opportunity announcements by one or more senior appointees or their designees;

(ii)   continuation of existing coordination with OMB;

(iii)  to the extent appropriate to the subject matter of the announcements, review by designated subject-matter experts as identified by the agency head or the agency head’s designee; 

(iv)   review of funding opportunity announcements and related forms to ensure that they include only such requirements as are necessary for an adequate evaluation of the application and are written in plain language with a goal of minimizing the need for legal or technical expertise in drafting an application;

(v)    interagency coordination to determine whether the subject matter of a particular funding opportunity announcement has already been addressed by another agency announcement and, if so, whether one of the announcements should be modified or withdrawn to promote consistency and eliminate redundancy;

(vi)   for scientific research discretionary grants, review by at least one subject matter expert in the field of the application, who may be a member of the grant review panel, the program officer, or an outside expert; and

(vii)  pre-issuance review of discretionary awards to ensure that the awards are consistent with applicable law, agency priorities, and the national interest, which shall involve in-person or virtual discussion of applications by grant review panels or program offices with a senior appointee or that appointee’s designee. 

(b)  Agency heads shall designate one or more senior appointees to review discretionary awards on an annual basis for consistency with agency priorities and substantial progress.  Such review shall include an accountability mechanism for officials responsible for selection and granting of the awards.

(c)  Until such time as the process specified in subsection (a) of this section is in place, agencies shall not issue any new funding opportunity announcements without prior approval from the senior appointee designated under subsection (a) of this section, except as required by law.

Sec. 4.  Considerations for Discretionary Awards.  (a)  Senior appointees and their designees shall not ministerially ratify or routinely defer to the recommendations of others in reviewing funding opportunity announcements or discretionary awards, but shall instead use their independent judgment.

(b)  In reviewing and approving funding opportunity announcements and discretionary awards, as well as in designing the review process described in section 3(a) of this order, senior appointees and their designees shall, as relevant and to the extent consistent with applicable law, apply the following principles, including in any scoring rubrics used to assess grant proposals:

(i)    Discretionary awards must, where applicable, demonstrably advance the President’s policy priorities. 

(ii)   Discretionary awards shall not be used to fund, promote, encourage, subsidize, or facilitate:

(A)  racial preferences or other forms of racial discrimination by the grant recipient, including activities where race or intentional proxies for race will be used as a selection criterion for employment or program participation;

(B)  denial by the grant recipient of the sex binary in humans or the notion that sex is a chosen or mutable characteristic;

(C)  illegal immigration; or

(D)  any other initiatives that compromise public safety or promote anti-American values.

(iii)  All else being equal, preference for discretionary awards should be given to institutions with lower indirect cost rates.*

(iv)   Discretionary grants should be given to a broad range of recipients rather than to a select group of repeat players.** Research grants should be awarded to a mix of recipients likely to produce immediately demonstrable results and recipients with the potential for potentially longer-term, breakthrough results, in a manner consistent with the funding opportunity announcement.

(v)    Applicants should commit to complying with administration policies, procedures, and guidance respecting Gold Standard Science.

(vi)   Discretionary awards should include clear benchmarks for measuring success and progress towards relevant goals and, as relevant for awards pertaining to scientific research, a commitment to achieving Gold Standard Science.

(vii)  To the extent institutional affiliation is considered in making discretionary awards, agencies should prioritize an institution’s commitment to rigorous, reproducible scholarship over its historical reputation or perceived prestige. As to science grants, agencies should prioritize institutions that have demonstrated success in implementing Gold Standard Science.

(c)  Nothing in this order shall be construed to discourage or prevent the use of peer review methods to evaluate proposals for discretionary awards or otherwise inform agency decision making, provided that peer review recommendations remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding by senior appointees or their designees. Further, nothing in this order shall be construed to create any rights to any particular level of review or consideration for any funding applicant except as consistent with applicable law...

Full release at https://www.whitehouse.gov/presidential-actions/2025/08/improving-oversight-of-federal-grantmaking/.

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*Note the implication. Even if eventually there is no numerical cap on indirect costs, the higher the percentage proposed; the lower the probability of an award.

**Note the implication. Grant renewals for continuing research on a topic would seem to be discouraged. Ongoing "relationships" between the granting agency and a university or research group within a university would seem to be discouraged.

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