The Technical Society of Knoxville: Charter, Purpose and Request

The Technical Society of Knoxville has committed as stated in its charter to the advancement of science and technology in the service of society through the advancement and support of professional development, education and publications. The Society’s role is to stay abreast of scientific and technical advances, assess their worth and application, and offer comments where appropriate. 

In this case, the Society’s comment is a warning. The direction of the proposed change in legislation will significantly chill research and threaten scientific enterprise that is cutting edge. In changing “guidance” to “regulation,” the Federal government would usurp the role of scientists in a free society. It would “grow Big Government” while diminishing the benefits of scientific growth. We urge the OMB to abandon sections of these proposed rules, specifically, §200.202, 200.204, 200.205, 200.206, 200.211, 200.218, 220.20, 200.300, 200.303, 200.340, 200.421, 20.432, 200.432, 200.450, 200.454, and 200.461. 

Our Members

The Technical Society of Knoxville comprises highly skilled and experienced professionals in science, engineering, and technology. We understand science and its application, and we are committed to preserving high standards of research and engineering to maintain the preeminence of the United States in these areas. 

Our members own technical companies, hold teaching positions in universities, work for research institutions and public utilities, hold multiple degrees in associated professions, meet regularly to develop knowledge and skill, counsel local government on technical questions, mentor students and new professionals, sponsor scholarships, and participate in all areas of civic responsibility.

From our unique vantage point, we can predict the consequences that several sections of the proposed revisions will have in reversing America’s preeminence in science and technology, and, indeed, undercutting our competitive edge in attracting highly skilled and educated people in these critical areas, directly affecting our quality of life and our economy. We will regress under the burden of government oversight and over-regulation.

Background: Government’s and Science’s Differing Modus Operandi and the Unintended Effects of Government Oversight

The Office of Management and Budget (OMB) in OMB–2026–0034 proposes revisions to the Guidance for Federal Financial Assistance intended to 

improve government-wide policies and requirements related to the management of grants, cooperative agreements, and other forms of assistance. OMB is proposing revisions that would improve transparency, accountability, and oversight for Federal awards across the Federal Government.

Ostensibly, that goal is worthy. In practice, however, proposed sections will negatively affect the pursuit of basic scientific research in the United States, which underlies applied sciences, engineering, and technology. It will undo the investment the American people made after World War II in supporting research and development through government grants. This support made progress widely available rather than limited tobusinesses, whose interests would be self-directed. We understand that reversing years of scientific progress is not the intended purpose of the proposed law, but it is a clear consequence of those changes. 

In addition, such legislation has long-term effects: Implementingit would encumber the government and the population with continuous litigation, given the contentiousness nature of the proposed legislation and its upending decades of successful collaboration among universities, businesses, government agencies, and international partners. Other options are less deleterious and give society the flexibility to shift directions when a law proves untenable: e.g., an executive order is easily reversed by the next president; agency guidance can be withdrawn. A finalized regulation under 2 CFR, however, carries the force of law, applies to every federal science agency (NIH, NSF, DOE, NASA, DOD, ARPA-H), and can only be undone through a new rulemaking process or congressional action. This law is too sweeping, too extreme, and too detrimental to society. It stymies the scientific process.

This section presents the conceptual framework for our comments on specific sections, which follow. We find this legislation ill-advised because it overlooks the essence of scientific work, which is to pursue reality in the physical world unrestrained by non-scientific boundaries, including political objectives and constraints, religious biases, and human hubris.

Politics and Science: Politics in the United States shifts regularly with elections and with social movements and norms. In contrast, science moves in a continuous stream, relying on a collective, continuous, and uninterrupted pursuit of data that can be analyzed, interpreted, and applied by skilled, knowledgeable, and ethical people regardless of location, age, or circumstances. 

When that stream of knowledge-building is interrupted for any reason—an earthquake destroying a laboratory, a fire that turns specimens to dust, a funding stream that is prematurely cut before results can be realized, double checked, peer reviewed, and published—that field is set back for years or maybe permanently lost.

What non-scientists mistake for waste or nonchalance is essential to any true scientific pursuit—a tolerance for risk. Pursuing knowledge always involves risk—some directions do not succeed. Some moonshots drop in the ocean before they gain 100 feet. Some perceived effects of a drug might be limited to only certain physiologies. When study disproves a hypothesis, the time and money invested is well spent because the researcher has cleared the ground for studying new hypotheses. 

Science has to be a collaborative, iterative, and reiterative process. Identifying a dead-end in research is valuable; one can eliminate that direction, just like driving on an unmarked and unfamiliar street that is not a thoroughfare but a cul-de-sac. The driver now knows to look for another route. Such is science; there are no road signs, only a reliance on one’s training, colleagues, and published collective wisdom. Knowledge cannot be held to the business model of delivering a quarterly report upon which to base a momentous decision. Nor can it be limited by a political preference. Scientists strive for clarity and certainty, neither of which can be legislated or scheduled.  

“Scientific method” is the term that captures this approach: In the scientific method, the researcher first—without bias—observes physical phenomena, gathers data, then formulates a hypothesis, which is a testable explanation of the data. Peers also test the hypothesis to see if the data was correctly gathered, the experiments well designed through replication, and the conclusions appropriately drawn. No guesswork; no bias; no preconceived elimination of any part of the method. 

The thrust of this response to the proposed legislation is not political. Reason lives with both parties. Our membership subscribes to both parties. Our critique of selected sections derives from our understanding of how one pursues science—the scientific method—and how government-funded research has benefited us in ways most citizens do not realize, just as many citizens do not know who grows their food and how it reaches their table. We take our quality of life for granted—until something happens that tarnishes or damages what we have or expect. They do not have the history of how the United States government used tax dollars to grow science in America after WWII. Again, that was through the Federal government underwriting research that science itself defined as necessary and correctly executed.

If the proposed changes become a standard as professed, changing “guidance” to “regulation,” the progress in scientific and technical areas as we have enjoyed and profited from to date would experience unrecoverable effects. There would be unintended consequences of judgements made from a political rather than a science-based approach, from administrative policies and preconceptions rather than rigorous peer review and self-evaluation within each field of inquiry. 

The Proper Role of Government in Addressing Waste: Granted, the Federal government cannot fund every request and should have guidelines for what to fund. This guidance should derive from experts in pertinent fields, not policy makers who do not know the science and are not familiar with the canon of literature that supports continuing progress in a scientific field. 

The government should, once the funding has been granted, audit the books and the results of a project, relying on peer experts in the field for assessment of success. The question, “Was it successful,” should be based on the quality of the research plan, execution, results, peer review, and publication as assessed by others in the field, not government administrators.

Based on this rationale, we are prepared to offer comments on sections of the proposed rule changes, beginning with the Summary. 

Response to the Summary

Specificity of definitions: The Summary states a general goal of the proposed legislation that needs definition. One would not contest to “ensuring that American tax dollars are not wasted or misused.” However, the following statement is too broad and open to whimsical application: “activities performed under Federal awards are consistent with law and policy, and recipients are held accountable when they fail to meet relevant standards.” To be clear, whose “policy” and what “relevant standards”? Are they government policies and standards, which could change with administrations, or do they derive from a relevant scientific or professional body that publishes policies and standards? This vagueness leaves too much room for misinterpretation and misuse. 

Discrimination: We are puzzled by the statement that the award-making process has permitted “unlawful discrimination.” That certainly would not be tenable, and we support that statement. We would like to know, however, who has experienced discrimination and how. 

Fairness and needs: The Summary also says that the administration is committed to “transparency, accountability, and proper oversight for the Federal grantmaking process. The proposed regulations seek to ensure that American tax dollars are ultimately used to serve the needs of the American public.” The first part of this statement suggests clear, consistent award procedures and, later, correct accounting procedures—all requisite. We would question, however, who determines what the needs of the American public are as manifested in the pursuit of science? A scientist who studies and publishes the attributes of a jellyfish, for example, might not have in mind a potential application to a treatment for MS because that is, perhaps, step seven in the progression from fact to application. That is, in fact, a real inquiry that is offering insights into medical treatments. Scientists need to explore and ask, “What if?” before they can ask “Would it work here?” 

Proper oversight: The Summary also states, “It is essential for the Federal Government to provide more oversight over the design and implementation of Federal programs to prevent wasteful spending and misuse or mismanagement of Federal funds.” This statement positions administrators, not researchers, deciding the design and implementation of research programs.The parallel today is the practice of insurance companies dictating health coverage, not doctors. This approach compounds confusion, overlap of responsibilities, and more waste. 

“Woke”: A final point we would like to address in the Summary references “woke” agendas in research. First, the term woke has no agreed-upon, published definition. It connotes controversy in the political, not the scientific arena. An area of science could be misconstrued as having a political agenda when, in fact, it does not. The gathering of consensus data itself could be construed as having a political agenda in that it might locate persons of color in various conditions or sections of society that reflect higher rates of illnesses or incarceration and correlate those numbers to social patterns. That is data, that is recorded observation, not a political statement. One must be careful not to construe a number with its meaning. Data needs interpretation. Interpretations can differ. It is the interpretation that leads to application in a social setting, but that application is not the science itself. How we use data parallels how we use the bible—it is what passage we select and how we ascribe meaning. Use of data is not the production of data. One can produce a car. How one chooses to drive it has nothing to do with its production.

Sections of OMB–2026–0034 with Discussion and Recommendations

We offer below our recommendations to reject sections of the proposed legislation and our reasons why.

1. [§200.202] Program Goals Must Align with Administration Priorities

We ask that this section be deleted. We object to the ability of the Federal government to deny a funding request for a project based on an organization’s or an applicant’s affiliations and recommend deleting this section. Requests should succeed or fail based on their intrinsic scientific merits. 

In addition, the proposed project must align with, or appear to align with, the President’s policy priorities. The President’s goals are not stated in a granular enough fashion for administrators to select without bias, misinterpretation, or misrepresentation. The potential grantee has no recourse were the request so misinterpreted. 

In establishing “a government-wide policy governing eligibility and the use of international elements in Federal research and development awards,” we caution against misconstruing how one advances “the interests of the United States” as adverse to scientific inquiry that includes international information exchange. We fear government overreach in making an arbitrary decision based on international relationships rather than universal scientific inquiry. Such a mandate would eliminate international researchers collaborating with American researchers. 

2. [§200.204] Notices of Funding Opportunities

Our objection to this section is that grant competitions can be hidden from public view because Federal agencies can exempt them from funding opportunities. If agencies can exempt funding opportunities from public posting on Grants.gov under a broad national interest exception, left undefined, entities may not even know a competition exists until it is over. How is this not “waste, misuse, or mismanagement” if a competitive process is bypassed? We request deleting this section. 

3. [§200.205] Federal Agency Review of Merit of Proposals

This section should be deleted. Our chief objection is that the Federal funding would be approved by a political process, replacing traditional scientific criteria. Science functions well only in a politically free environment. Funding could be denied because of an objection to an institution, not the individual researcher’s proposal.

We note that the term Gold Standard Science has no meaning for the independent entity required for solid science. It offers no concrete criteria for assessing a project’s funding viability and no specific “benchmarks” that would apply to all scientific pursuits. The term appears to be subjective rather than objective.

Peer review should not be just advisory; peers should be integral to the decision-making process. A government administrator has no qualifications or time for such determinations, which take peer consultation, discussion, and evaluation. Strong science is a team sport, not a solo pronouncement from a desk.

Further, this section suggests that the government could award funding to an entity that has not received a Notice of Funding Opportunity (NOFO). The government could arbitrarily award an entity on the basis of political orientation. First-hand stories of Russian and Chinese researchers recount “state-approved” research and results, stunting intellectual growth in those countries, which, only now, are beginning to match the United States in competence. In addition, the pernicious effects of following “what the boss thinks” in one Austria university, as an example, again, a first-hand account, limits what a researcher can study and publish.

Science occurs in groups of highly knowledgeable and trained people who know the history of their limited inquiry and can review each other’s work. Other scientists would not be able to review their work properly because they have not spent the same time in that area of study and practice. This requirement reduces the pursuit of funding to rhetoric, not scientific merit. Whoever can make the political case and avoids wording that indicates a politically rejected line of inquiry would get funded, regardless of benefit. Scientific merit could be ignored. We ask that this section be deleted.

4. [§200.206] Federal Agency Review of Risk Posed by Applicants 

We support deleting this section because it would deny funding based on perception, bias, political ideology, and preference, not the structured research of a scientific area. Any community-based organization with an agenda that speaks to civil rights, environment, sector advocacy, public health, and community-organizing entities for any purpose would be suspect and disqualified. Given how expansively the rule’s preamble defines “anti-American activity,” we see an open invitation to reestablish the havoc of the McCarthy era, and we reject that trajectory. 

5. [§200.211] Information Contained in the Federal Award

We caution against this provision because informing an entity of funding termination does not imply explaining the termination. Again, a funded entity has no recourse. This provision is ambiguous. We recommend deleting it.

6. [§200.218] Disparate Impact Research and Programming Banned 

This provision should be deleted. It works against the social and economic sciences that have contributed to our country’s strength. It has no counterpart in the proposed regulations. Disparate-impact analysis is a foundational tool of civil rights law, public health research, environmental justice, housing policy, and labor economics. The loss of evidence-based research in these areas would be catastrophic for decades.

7. [§200.220] Prohibition of Using Federal Funds for Covered Foreign Collaborations

We vigorously reject this section and recommend its deletion,given the shifting definitions of what country is “covered” as a threat based on shifting interactions with and reactions to other governments. To enact legislation affecting science that requires definition based on political change in the world is bad policy. The Wolf Amendment is currently limited to China. This provision would expand Wolf and open the door to any perceived adversary of the day. Any day, another country could be defined as “covered,” and collaboration with international colleagues would be terminated or prohibited. Science needs to work independently of politics.

8. [§200.300] Diversity, Equity, and Inclusion—DEI and Related Prohibitions

This provision is unacceptable and should be deleted. It relies on the undefined term DEI. The government would discriminate against entities that seek to understand—not promote—gender ideology. Understanding a reality decreases descension; it does not promote it. In addition, religious entities would be treated equally as secular entities seeking funding, violating the separation of church and state. We object to the potential for a negative effect on Medicaid-funded health systems, health centers, and social service agencies. In addition, this prohibition applies to Title I, Individuals with Disabilities Education Act (IDEA), Head Start, and workforce training grants, creating direct conflict with the statutory purposes of those programs. The entire purpose of these statutes, already passed by Congress, would be challenged, creating the appearance of a conflict with the Separation of Powers. 

9. [§200.303] Internal Controls

We recommend deleting this section because we object to the onus it places on entities to check immigration status. That is the purview of Immigration and Homeland Security. In addition, many research grants rely on the expertise of international researchers who come to the US on a temporary basis. Given the recent errors in identification and the lack of due process, we object to being forced to be a party to a process over which we have no control or even advisory status.

10. [§200.340] Discretionary Termination

We request that this section be deleted because it states specifically that Federal grants can be terminated at any time, for any reason, which allows for too much interpretation and assessment based on unclear and arbitrary criteria. One can easily conjure up a situation in which research is curtailed based on a social-media-driven conspiracy that posits unethical procedures. Science follows a code of ethics, which a reviewer might not know or consider. Further, once a chain in data-gathering is broken, scientific talent loses employment in specific areas, science is set back in that area, and valuable data is lost, possibly permanently. This provision will contribute to, not reduce, “waste, misuse, or mismanagement.” It could do significant and permanent damage.

11. [§200.421] Advertising and public relations 

This section provides an opportunity for arbitrary withdrawal of funds, given a reviewer’s interpretation of the description of how advertising and public relations does or does not further the goals of the award. Reviewers would not be conversant enough to make this detailed a determination. We recommend that it not be included in the proposed statute but be offered as supplementary guidance. 

12. [§200.432] Conferences

This requirement implies that research professionals attend irrelevant conferences. Such an ascription indicates a lack of understanding of how professional conferences serve attendees. Attendees participate in lectures, demonstrations, poster sessions, and informal discussions. The advantage of attending a conference is not predetermined. Often, the breakthrough comes through cross-fertilization of expertise in multiple fields. Research, like business, is built on trusted relationships. Denying conference travel is inappropriate based on an administrator’s assumption about value. Grantees would work within the funds given and not squander them on anything that does not serve project purposes. In addition, when would “pre-approval” occur? Conferences might not be announced before one completes an application for funding. This section needs to be deleted. 

13. [§200.450] Issue Advocacy Prohibition

This provision should be deleted because it could restrict grantees from communicating findings on projects related to social matters, advocating for students before state agencies, or engaging in routine community education work deemed “divisive policy matters or issue advocacy.” We can identify many worthy initiatives that could be misconstrued as such and have funding arbitrarily withdrawn. The very act of an elected official attending a meeting of the group receiving a grant could be misconstrued as the group attempting to “affect State agency policymaking, rulemaking, or administrative action” when that official participates as any other citizen in the area. 

14. [§200.454] Memberships, Subscriptions, and Professional Activity Costs

This proposed section assumes that those proposing a project can see in advance every potential opportunity related to memberships, subscriptions, and professional activity costs. Even professional memberships would need preapproval by staff who are unqualified to assess the value of a researcher’s choices. We recommend striking this requirement and offering it as a guideline, not law. 

15. [§200.461] Publication and Printing Costs

This provision is onerous in that pre-approval is required for anything printed for a research project. To examine a project “on a case-by-case basis” puts a heavy onus on the granting agency as well. The proposed revision states, “Publication costs are not inherently necessary to carry out the core programmatic objectives of most Federal awards. In many cases, such activities are discretionary, vary widely in scope and costs, and may serve institutional, professional, or reputational interests rather than the specific objectives of the Federal program.” This is a blatantly incorrect statement that overly generalizes the purposes of printing and publication. Without publication, research cannot exist. If no one reads results and discusses the merit of the work, that work, in essence, never happened. This section needs to be deleted. 

Our Request

We respectfully request that the OMB withdraw its proposals in 2026-0034 as described in this document: §200.202, 200.204, 200.205, 200.206, 200.211, 200.218, 200.220, 200.300, 200.303, 200.340, 200.421, 200.432, 200.450, 200.454, and 200.461. 

Enactment of the proposed changes will skew scientific endeavors by forcing a political agenda that has no bearing on scientific research. We urge your strong consideration of our request.