June 16, 2026
In late May, the US Office of Management and Budget (OMB) released a proposed rule, Regulation for Federal Financial Assistance, that would likely have a significant effect on federally supported research across the scientific spectrum, including medicine and surgery.
There are several provisions worth noting in the proposed rule, but the following could be particularly impactful for surgeons involved in research:
Section 200.205—Federal Agency Review of Merit of Proposals
Per this provision, senior political appointees—not career scientists or program officers—would be required to conduct a “pre-issuance review” of every discretionary grant before it is awarded, and they would be barred from deferring to peer reviewers or ratifying recommendations.
Section §200.205(d), Use of peer review
Per this provision, peer review recommendations would “remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding.” Rather than relying on peer review as the basis for assessing scientific merit, a senior political appointee could override the consensus of the subject-matter experts for any reason.
Section §200.340—Termination and Suspension
Per this provision, agencies, including the National Institutes of Health, could cancel any federal grant, even in the middle of a multi-year research program, for any reason, at any time, with only a brief written rationale.
There are several other provisions that could affect surgeon-scientists and, eventually, the health of patients by curtailing international collaboration, increasing indirect costs for research, and restricting new projects to those that strictly align with the Administration’s priorities.
The ACS has been a proponent of the value of surgeon expertise as a basis for healthcare and medical guidance for more than a century. In response to the Centers for Medicare & Medicaid Services Relative Value Unit reimbursement reductions for surgeons that were enacted earlier this year, the ACS noted that the cuts “devalue surgeon services.”
This proposed OMB rule also threatens to devalue surgeons’ scientific expertise at a time when the burden of surgical disease is quickly increasing.
The OMB Regulation for Federal Financial Assistance proposed rule is open to public comment until July 13. The ACS will submit detailed comments before the deadline. Those comments will be available in the ACS Brief, Advocacy Brief, and other ACS publications.