Public Comment on OMB Proposed Rule, Regulation for Federal Financial Assistance
(Docket OMB-2026-0034)
To the Office of Management and Budget,
To the Office of Management and Budget,
On behalf of the undersigned organizations, representing innovators, patient advocates, researchers, entrepreneurs, investors, and stakeholders committed to advancing biomedical innovation and affordability for American patients, we respectfully urge the Office of Management and Budget (OMB) to withdraw or substantially revise its proposed overhaul of the Uniform Guidance governing federal grants, cooperative agreements, and other monetary awards to nonprofits, state and local governments, and other grantees.
No Patient Left Behind was founded on a simple belief: patients deserve both affordable medicines and a future in which new medicines continue to be discovered. Those goals depend on an innovation ecosystem built upon scientific excellence, predictable institutions, and public trust. The proposed rule risks undermining the very foundation that has made the United States the global leader in biomedical research.
America's scientific leadership must continue to rest on a commitment to allowing the best science to compete on the merits, not partisan ideology.
For decades, the United States has built an internationally respected research enterprise by empowering expert peer review, encouraging collaboration across institutions and disciplines, and providing researchers with the stability needed to pursue difficult scientific questions whose answers may take years to emerge. This system is not perfect and appropriately has built-in levers during the annual appropriations process that allow for accountability, but what we must not overlook is that it has produced extraordinary benefits for patients, taxpayers, and the American economy.
The proposed rule would fundamentally alter that model.
i. Biomedical innovation depends on predictability.
Developing a new medicine often requires more than a decade of research and billions of dollars in private investment. Federal grants frequently support the early scientific discoveries that make future private investment possible. Scientific research cannot flourish in an environment where awards may be terminated because they are later determined not to align with evolving political priorities. Long-term research programs require long-term confidence.
Diseases do not recognize election cycles. Cancer, Alzheimer's disease, ALS, rare diseases, and countless other conditions demand sustained scientific investment regardless of who is in office.
The uncertainty created by the proposed rule extends beyond those conducting basic research. It also affects biotechnology startups, academic medical centers, nonprofit research organizations, and the investors who finance the translation of scientific discoveries into treatments for patients. When uncertainty increases, investment in drug discovery decreases. The result is not simply fewer research grants. It is fewer investors funding early-stage innovation, leading to fewer clinical trials, fewer startup companies, fewer high-quality American jobs, and ultimately, fewer life-saving medicines reaching patients.
ii. America's scientific leadership is a strategic national asset.
The United States leads the world in biomedical innovation because it has built independent institutions that attract the world's best scientists and entrepreneurs. Those institutions have become engines of economic growth, national security, and medical progress. At a time when geopolitical competitors are making unprecedented investments in science and biotechnology, weakening confidence in America's research enterprise sends exactly the wrong signal.
If America wants to remain the most trusted place in the world to conduct scientific research, policies must increase predictability to encourage scientific talent, investment, and future breakthroughs to remain here.
iii. Patients have the most to lose.
Every delayed discovery represents patients who continue waiting for treatments that may never arrive. The greatest cost of weakened scientific institutions is not measured in grant dollars. It is measured in breakthroughs that never happen, diseases that remain uncured, and families who are left waiting for cures. America's research enterprise exists because previous generations invested in discoveries whose benefits they would never personally experience. We owe future patients that same commitment.
In conclusion, the United States has built the world's most productive biomedical innovation ecosystem because it has protected scientific independence while demanding accountability. OMB can pursue greater efficiency and better grant administration without fundamentally changing the principle that scientific expertise should remain the primary basis for evaluating scientific research.
Future patients, who could be any of us, are depending on decisions being made today. We therefore respectfully urge OMB to withdraw or substantially revise the proposal to preserve independent, merit-based scientific review — for innovation, for American biopharmaceutical competitiveness, and, most importantly, for patients.
Sincerely,
No Patient Left Behind
On behalf of the undersigned organizations
To join us in signing this statement, click here.
"For decades, the United States has built an internationally respected research enterprise by empowering expert peer review, encouraging collaboration across institutions and disciplines, and providing researchers with the stability needed to pursue difficult scientific questions whose answers may take years to emerge. This system is not perfect and appropriately has built-in levers during the annual appropriations process that allow for accountability, but what we must not overlook is that it has produced extraordinary benefits for patients, taxpayers, and the American economy.
The proposed rule would fundamentally alter that model.”