I submitted a public comment on the OMB’s proposed changes to federal grant-making procedures, indicating my agreement with the warnings of the American Historical Association about the revisions. Here’s what I said:

As a professional historian, I have direct, personal experience with the federal grant-making process for humanities research, and I have observed how vital independent peer review is to that process. I am commenting on these regulations because I agree with professional non-profit organizations like the American Historical Association and the Organization of American Historians that the proposed changes (particularly to §200.205 and §200.340) will substantially weaken a system that is already working well.

I have been the recipient of a grant from the National Endowment for the Humanities (NEH); I have also had an application to another grant from the NEH rejected. But in both cases, I requested and received detailed feedback from scholars in my field whose anonymous input had been solicited by the NEH. What made the feedback valuable was the knowledge that the reviewers had closely read all of my submitted materials (as opposed only to the title or short description of the project) and also could draw on their broader reading of scholarship and the range of arguments in my field. That equipped them to rigorously evaluate the merits of my proposed research and advise me on how to improve my proposal.

I have subsequently served on multiple review panels for NEH open calls. I have also written letters of support for proposals, some of which were funded and some of which were not. This experience has confirmed my respect for the merits of peer review as it was traditionally practiced by the NEH for many years. Especially valuable, when serving on the review panels, was the chance to hear the diverse viewpoints of other panelists and program officers, which sometimes persuaded me to change an initial evaluation. This is how a substantive review process in a scholarly context should work.

Yet it is precisely these virtues of peer review that will be threatened by the proposed changes to §200.205 and §200.340, which allows agencies to overturn the recommendations of peer review for political reasons. The problem, I want to be clear, is not the idea of pre-issuance clearance by agency leaders; that has always been standard practice and makes sense from the perspective of financial stewardship and bureaucratic process. There will always be more good projects than can be funded, and so hard decisions must be made on the basis of peer reviewer recommendations. The problem is the proposed rule’s explicit direction to agency leaders to assess whether a grant furthers a particular President’s objectives, which subordinates the objective review of proposals' scholarly merits and feasibility to the political preferences of the moment. This is a recipe for favoritism and politically motivated research, rather than merit-based, rigorous funding review.

The proposed change is clearly motivated by the assertion in Executive Order 14332 that past awards have been politically motivated. Yet if that is the objection to the status quo, I fail to see how explicitly building political motivation into the uniform guidance fixes the purported problem. Rather, it invites future administrations to swing research their own way. If the goal is to ensure that taxpayer dollars are well-spent on rigorous empirical research without fear or favor, then what is needed is more merit-based peer review, not less, and more reviewers, not fewer. I can easily predict, however, what will be the result of these changes: federal agencies will not be able to recruit scholarly peer reviewers, who will rightly wonder why they should spend their time and labor evaluating proposals that might be thrown out at the directive or whim of a politician.

This is not mere speculation. In early 2025, I was serving on a review panel for the NEH whose operations were disrupted by the arrival of DOGE agents and mass firing of career public servants at the NEH. Our review panel was still in an early round of review, which meant that we were submitting initial scores based on our holistic review of materials. Had things proceeded as usual, we would have had a second round where we could view other panelists' feedback and, if warranted, adjust our scores based on the discussion. That second round never even happened, and it was subsequently revealed that DOGE agents arbitrarily canceled grants on the basis of project titles and short descriptions fed into ChatGPT, with ludicrous results like the canceling of a grant for museum HVAC repairs due to alleged DEI.

The idea that this sham of a process is better for ensuring that meritorious projects are funded than the process I know first-hand, in which scholars spend many hours combing over proposals with care, is wrong on its face and bad for our national interest. Yet it is the sort of process clearly invited by this revision and the Executive Order that prompts it. I therefore respectfully urge the OMB not to adopt these revisions and will be contacting my Congressional representatives to express my concerns.

The deadline for making comments is July 13. Thanks to the AHA and Scholarly Kitchen for alerting me to the issue.