The Research Policy Dispatch

Photo by Susanne Jutzeler

Welcome to the Research Policy Dispatch—a free weekly newsletter for research managers and administrators, research development professionals, and PIs. Each issue delivers a clear, concise roundup of federal funding and research policy developments, with the context you need to understand what matters and why.

The Dispatch is a companion to the Research Policy Atlas—a searchable, user-friendly database that tracks executive orders, legislative actions, agency notices, court rulings, and much more. The Atlas gives you one place to find the policies that affect research funding, compliance, and operations. In an era of tight budgets, it pays for itself in time saved—if you spend even an hour a month searching for policies or context, you’ll quickly see the return.

The goal is simple: make federal research policy easier to follow, anticipate, and act on—so your unit can focus on advancing research, not chasing updates.

A tactical shift: from defunding to directing NIH dollars

With the end of the federal shutdown, the administration has resumed its push to exert greater control over medical research funding, but with a meaningful shift in tactics. Directly defunding the NIH has proven politically unpopular, so the strategy has moved toward influencing how federal dollars are distributed. The clearest example is NIH’s recent decision to abandon long-established grant-ranking formulas tied to peer-review scores as explained in a recent Extramural Nexus post. In practice, paylines and standardized score-to-award conversions will no longer anchor funding decisions. This shift follows An August directive instructing NIH staff to weigh political and strategic priorities alongside - and at times ahead of - peer-review assessments, raising concerns about transparency and the degree to which scientific merit will remain the primary driver of award decisions.

What changed (documented actions)

Recent executive and agency-level actions have focused on expanding central oversight of federal grantmaking. Executive Order 14322 “Improving Oversight of Federal Grantmaking,” issued in August, lays the administrative groundwork for broader intervention in award decisions across agencies. In November, NIH announced a “unified funding strategy” intended to standardize decision-making across Institutes and Centers. Under this new framework, which takes effect with the January 2026 Council round, Institutes will no longer rely primarily on paylines to translate peer-review scores into funding outcomes.

What staff and reporting have revealed

Independent reporting from KFF Health News and Science including interviews with NIH staff describe internal guidance encouraging program leaders and political appointees to treat peer-review scores as one of several factors but not the decisive one. Appointees now have expanded authority to delay or override awards, even when applications received top scores from study sections. Reports also detail operational fallout: slowed award processing, increased layers of managerial review, and growing reluctance among some peer reviewers who feel their work no longer meaningfully influences funding decisions.

Why this matters

Predictability and transparency:
Paylines offered a clear understanding of how scores translated into funding outcomes. Removing them without publishing fully articulated reasoning makes the process less predictable for investigators and removes important information signals on fundability.

Risk of politicized alignment:
When funding decisions turn heavily on “alignment” with administrative priorities, scientific merit can become secondary. Reporting indicates that projects have already been flagged or stalled based on keywords or thematic content rather than scientific evaluation.

Impact on peer review and workforce stability:
If reviewers perceive that high-quality evaluations are routinely bypassed for political reasons, participation in peer review may decline, leading to a weakening of the very system NIH relies on to assess scientific rigor.

What to watch next

  • Institute-level policy updates: NIH has indicated that Institutes and Centers will publish clearer funding-policy language to accompany the new unified strategy. How specific these policies are, and whether they reveal meaningful constraints on discretion will shape transparency going forward.

  • Operational indicators: Shifts in award patterns, declines in reviewer participation, changes in the frequency of “programmatic alignment” justifications in summary statements or award letters, and FOIA-revealed internal guidance will be early signals of how the new system is functioning.

Takeaway

This is not a procedural adjustment on the margins. It represents a structural reorientation of how discretion is exercised over billions in federal research dollars. The longer-term effects will hinge on how clearly NIH documents its new decision-making criteria, and whether scientific merit retains its place at the center of the system.

For Research Administrators

What NOT-OD-26-007 Really Means for Your Awards

NIH’s new notice, NOT-OD-26-007, is worth paying close attention to. It clarifies but significantly strengthens NIH’s authority to renegotiate the scope of a funded project after peer review and Council, but before or during the award period.

What NIH is asserting

  • NIH program and grants management staff may negotiate and revise key project elements — including aims, objectives, title, and abstract.

  • When NIH and your institution’s AOR agree to revised scope, those revisions become binding terms and conditions of the award.

  • Drawing down any funds = institutional acceptance of those revised terms. There is no separate acceptance step.

  • Non-compliance can trigger immediate enforcement actions, including restricted drawdowns, corrective action plans, or termination.

In other words, NIH is formalizing its ability to realign (there’s that word again) projects with agency priorities, and the institution becomes fully bound once funds are spent. PIs cannot revert to the originally reviewed scope unless NIH approves it in writing.

Implications for your RA practice

  • Greater post-award volatility. NIH has reinforced its latitude to shift direction after the notice of award, even when changes alter core scientific intent.

  • No room for later disputes. If your AOR accepts revised terms (including via drawdown), institutions cannot contest the scope change after the fact.

  • Heightened monitoring obligations. Teams must document, track, and enforce the revised scope as diligently as the original one.

  • Potential PI friction. Scope changes driven by NIH, rather than by investigators, will require more careful communication and expectation-setting.

This is a moment to reinforce internal processes: involve Research Administrators early when scope negotiations begin, document all NIH communications, and ensure faculty understand that spending funds equals acceptance of the new terms.

Also noteworthy: NOT-OD-26-009

Paired with 26-007, NOT-OD-26-009 updates NIH’s expectations around prior approval and change-in-scope requests. Key points:

  • NIH will now require more explicit documentation when investigators propose changes that alter the project’s direction, approach, or objectives.

  • The notice tightens NIH’s definition of what constitutes a change in scope — especially for aims, human subjects protections, and significant methodological shifts.

  • Institutions should expect closer scrutiny and slower processing for post-award scientific changes that could intersect with 26-007’s new enforcement posture.

Together, these notices mark a clear trend: NIH is asserting more control over scientific direction during the award, and institutions need stronger internal controls to keep up.

The greatest danger in times of turbulence is not the turbulence; it is to act with yesterday’s logic.

Peter Drucker

You got to the end! Thanks for reading along. I look forward to sharing future editions with you—and to navigating the “spirit of the time” together.

Until next time,

Sarah Trimmer, MPH
The Research Policy Dispatch

Federal policy is complex and constantly changing, but the Research Policy Atlas tracks it so you can focus on research.

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