Advocacy - Comment Letter
Dear Chairs Cole and Collins and Ranking Members DeLauro and Murray:
The undersigned not-for-profit scientific, medical, and scholarly societies write to express serious concern about proposed OMB regulations and provisions in the President’s Budget Request that would prohibit or restrict the use of federal research grants to support high-quality, peer reviewed scientific publications. As community-led publishers of peer reviewed journals and books, we are deeply concerned these proposals would undermine the impact of federal research investments, weaken U.S. competitiveness, and threaten independent scientific inquiry and debate. We urge Congress to reject policies that would prohibit or condition the eligibility of publication costs for federally funded research.
Our organizations advance knowledge in service of the public good by reviewing and disseminating research driving discovery, innovation, and public benefit. Through our publishing programs, we uphold research integrity and enhance the impact of federally funded research through a validated and vetted research record. Any publishing revenue is reinvested into education, workforce development, standards setting, and other programs to advance the U.S. research enterprise. Society publishers also strengthen the marketplace of ideas by sustaining independent, mission-driven outlets for scientific exchange.
Allowing publication costs as a standard component of research funding is essential to maximizing the return on federal research dollars. Research serves its public purpose only when results are reviewed, disseminated, and integrated into the scientific record, and publication costs – which are only about 1% of the overall research investment – support the necessary infrastructure and expert labor to make that possible. Peer reviewed scholarly communication is indispensable to scientific progress, economic growth, national security, and public benefit.
As Office of Science and Technology Policy Director Michael Kratsios noted in a June 23, 2025 memorandum, peer review is “critical for generating trustworthy new knowledge that minimizes bias, ensures methodological rigor, and upholds scientific standards through objective scrutiny.” Publishers provide that scrutiny, along with editorial and ethical oversight, fraud and plagiarism detection, corrections, preservation, accessibility, transparency, metadata, and the platforms necessary to allow researchers, educators, policymakers, and the public to reliably use the research record. These are not incidental services; they are essential components of the scientific enterprise.
U.S. leadership in science and technology depends not only on strong federal research funding, but also on a trusted, independent system for communicating results. Weakening publication infrastructure by limiting the ability of U.S. researchers to publish federally funded work would erode American competitiveness at a critical moment of global scientific and technological competition.
The proposed OMB regulation and the President’s FY2027 Budget Request would bar payment for publication expenses while still expecting public access to research results. This creates a fundamental contradiction: researchers are expected to publish while being denied access to the systems to make publication possible. Proposals that condition publication cost allowability on agency approval also raise concerns about politicization, administrative burden, delay, and diminished trust in U.S. research.
Publishers make essential investments in research integrity and in maintaining a diverse, independent marketplace of ideas. A prohibition on publication expenses would weaken both, undermining confidence in the scientific record and the skeptical inquiry on which research depends.
Not-for-profit scientific and medical societies support high-quality publishing and reinvest publishing revenue directly into the research community and the next generation of innovators. Restrictions on publication cost recovery would disproportionately harm our mission-driven organizations, accelerate consolidation, and reduce independent alternatives in scientific publishing. Without the ability to recoup reasonable publication costs, societies would have fewer resources to support the communities and fields they serve.
We respectfully urge Congress to consider language in Appropriations legislation that preserves researchers’ ability to recover reasonable, grant-related publication expenses and rejects policies prohibiting or conditioning the eligibility of publication costs for federally funded research. We stand ready to work constructively with Congress to advance public access goals while protecting scientific integrity, economic competitiveness, and U.S. leadership in science.
Sincerely,
The Undersigned Societies