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Open-access publishing is built on a promise: research funded by the public should be freely available to the public. A sweeping new proposal from the White House Office of Management and Budget (OMB) threatens to break that promise by fundamentally rewriting how federal grants are awarded, managed, and published.
Key Takeaways |
| The Funding Paradox: The proposed rule creates an impossible contradiction by mandating open-access research while simultaneously banning the primary grant funding used to pay for it. |
| Politics Over Peer Review: The guidance threatens academic freedom by allowing political appointees to override expert peer-review panels and terminate active grants mid-study. |
| A Looming July 13 Deadline: The research community must take action and submit personalized comments to the Federal Register before July 13, 2026, to protect scientific independence. |
The proposed revisions to the Uniform Guidance (2 CFR Part 200) introduce unprecedented changes that will restrict how research is communicated and who gets to decide what is funded. Three major issues stand out for the digital health research community:
- Defunding Open Access (§200.461): The rule would make article processing charges (APCs) unallowable as grant expenses. This creates an impossible contradiction: the government is mandating immediate public access to research via the 2022 OSTP memo, while simultaneously banning the primary funding mechanism researchers use to provide it. Whether you agree with the APC model or not, the costs of disseminating validated research do not disappear; they simply shift. This will disproportionately hurt researchers at smaller institutions and threaten independent, fully open-access publishers, while leaving large legacy subscription publishers largely unaffected.
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Political Interference over Peer Review (§200.205): In alignment with concerns raised by the STM Association, this rule subordinates independent, expert-driven peer review to political appointees. If finalized, political officials could override expert panels to deny funding or terminate multi-year grants mid-study (§200.340) if the research does not align with the current administration's priorities. A government-led system where political appointees evaluate scientific results is a direct threat to academic freedom, research integrity, and global trust in U.S. science.
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Broad new restrictions on international collaboration (§200.220) risk isolating U.S. researchers and breaking the global networks required to solve complex health challenges. Science is inherently international. Vague prohibitions on foreign collaboration will chill lawful, productive scientific exchange, including the international peer review networks, data sharing, and global co-authorship that journals rely on to maintain quality and identify errors.
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Grant Termination and Uncertainty (§200.340): In digital health and medical informatics, research often involves multi-year clinical or longitudinal studies. Discretionary termination wastes taxpayer investments, forces researchers to abandon participants mid-study, and disrupts the trusted systems that ensure research is validated and preserved.
Your Voice Matters: How to Comment Before July 13, 2026
We at JMIR Publications have submitted a formal comment opposing these measures and advocating for quality-based alternatives to protect open access. However, individual, personalized comments from researchers carry the most weight with regulators.
We strongly urge all federally funded researchers, clinicians, librarians, policy makers and patient advocates to submit a comment to the Federal Register (Docket: OMB-2026-0034) before July 13, 2026.
Based on guidelines from the STM Association and policy experts, here's how to make your comment effective:
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Tell your personal story: Form letters are often ignored. Instead write 3-4 paragraphs explaining exactly how these rules would harm your specific multi-year projects, your ability to publish, or your international collaborations.
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Cite specific sections: Explicitly reference §200.461 (making publication costs unallowable), §200.205 (political appointee review overriding peer review), §200.340 (grant termination), and §200.220 (foreign collaboration bans).
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Highlight the broader impact: Note how this undermines U.S. scientific leadership and isolates American researchers on the global stage.
Science must be driven by independent evidence, not political interference, and knowledge should belong to everyone. Let’s stand together to protect it.
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