Editors’ note: Today’s post is by Karin Wulf and Sarah Weicksel. Karin is an Alumni Chef, and Director and Librarian at the John Carter Brown Library and Professor of History, Brown University. Sarah is the Executive Director of the American Historical Association.
It is always also about the humanities.
The public conversation about the OMB proposal to revise its guidance on federal grants and more has been focused on science, but make no mistake: this proposed revision is about research — and humanities research is just as vulnerable as STEM. The proposed rule to overhaul 2 C.F.R Part 200 (Uniform Guidance) takes aim at many features of grant-funded research but three sections in particular undermine the foundation of historical work in expert, peer reviewed research and scholarship.
All disciplines rely on peer review as the essential mechanism for evaluating applications for funding and publication. For professional historians, peer review is undertaken both informally and formally. We circulate written work for feedback among colleagues, at seminars and workshops, and we present our work in conference presentations for comments. When we submit scholarship for publication, typically double-anonymous peer review is substantial; it is not uncommon to receive several evaluations comprised of multiple pages of feedback. Peer reviewers are selected for their experience and expertise in the specific field of history. Their background and training gives them the depth of perspective to understand fresh, valuable contributions to knowledge, and to identify those projects that are infeasible or do not meet professional standards.
Experts are equally essential to reviewing applications for funding historical research. Peer reviewers ensure that funding across our sector, whether at private research centers or from government agencies, meets high standards. Specific funding opportunities ask for specific information and qualifications, but in general, the value to the discipline of the proposed research and the suitability of the applicant to undertake it require assessment by experts in the discipline and particular field. This is not news to anyone who is an expert, but it is important to reassert for the humanities, which is not only routinely sidelined in discussions about research more generally, but in which the importance of expertise is often under-estimated.
The expertise that historians (and all experts) bring to the grantmaking process would be severely diminished by the proposed revisions. Instead, the Uniform Guidance would require a senior political appointee to conduct a review of every discretionary grant award before it is issued to ensure that awards advance the president’s “policy priorities” and comply with applicable prohibitions and the national interest (Page 15 – Section 200.205, Federal Agency Review of Merit of Proposals). The revisions also allow for termination of grants midstream (Page 28 – Section 200.340, Termination and Suspension).
When designing research programs and evaluating applications, federal agencies would be required to “apply a domestic-first framework, under which international elements may be included only if the Federal agency determines that such elements are justified, consistent with program objectives, and in the national interest of the United States” (Page 201 – Section 200.202, Program Planning and Design). Yet the revision offers no definition of these requirements, nor does it make clear the criteria an applicant would need to meet in order to justify an international collaboration.
For expert history, which is under intensifying threat from federal government intervention, this all amounts to a further degradation of the public benefit that accrues from our professional work. Whether working in academia, museums, libraries, in government service, or other types of institutions, historians have a professional obligation to engage in rigorous, evidence-based work. These proposed revisions violate our professional standards by weakening our ability to vet and promote the best historical work. They also erode our ability to meaningfully serve the public interest – which is always best served by the most complete and fully researched historical accounts. The proposed revisions would shift federal grant administration away from the merit-based, expert-driven framework that sustains historical research, programs, and teaching.
The American Historical Association has submitted a public comment on the proposed revision and has encouraged our members to do the same. We urge our colleagues across disciplines to respond to the proposed guidance with comments that recognize this threat to all research.
