Jay Bhattacharya’s “plan to drive Gold Standard Science”: A Trojan horse for “Lysenko-izing” the NIH

No matter how hard I try to find other topics to write about, I always keep coming back to the the extinction-level threat that the current administration poses to federal programs and infrastructure public health, medicine, and biomedical research. Some weeks, it’s vaccines, and the antivaccine policies of our Secretary of Health and Human Services Robert F. Kennedy Jr. designed to eliminate access to all vaccines over the course of the second Trump administration, the decimation of the CDC (not to mention the demonization of its scientists and workers that led to a deranged antivax gunman spraying the CDC campus with hundreds of rounds and killing a police officer in the process). Other weeks, it’s turmoil at the Food and Drug Administration as a result of the evidence-based medicine methodolatry weaponized against vaccines colliding with right-to-try, the overarching deregulatory agenda of this administration, and anything having to do with the “make America healthy again” (MAHA) movement. This week, it happens to be the continued dismantling of the crown jewel of US biomedical research, the National Institutes of Health, fronted by the utterly unqualified COVID-19 contrarian turned antivax-friendly useful idiot for RFK Jr. and Office of Management and Budget Director Russell Vought, NIH Director Dr. Jay Bhattacharya, or, as both Angela Rassmussen and I like to call him, the new Trofim Lysenko.

You might ask: What fresh hell is this, hot on the heels of President Donald Trump’s executive order putting political appointees firmly in charge of deciding who gets NIH grants? Simple. This week it’s a hidden blueprint for how such power will be exercised. On Friday, Dr. Bhattacharya announced the new NIH “plan to drive Gold Standard Research“:

The first thing you’ll note is that, on the surface at least, all of these bullet points sound totally unobjectionable and obvious. Those of us who have applied for and participated in writing NIH grants for submission for many years, as well as served on study sections, will immediately note that pretty much all of these bullet points describe pre-existing NIH initiatives going back decades designed to encourage more scientific rigor, generalizability, and reproducibility in research projects funded by the NIH. You might therefore ask: What’s the big deal? The answer is, of course, in the details, where, as we all know, the Devil resides, as anyone who undertakes a critical reading of the 16-page PDF of the document will note. Much of this new plan is, as I said, relatively unobjectionable. It’s what is buried in this plan that leads me to view it primarily as a Trojan horse designed to turn NIH-funded research into Lysenkoism 2.0, at least in any area in which right-wing politics leads to science denial, particularly vaccine research, anything related to the MAHA agenda, pandemic preparedness, and public health. That’s why I won’t spend a lot of time discussing the OK bits. Instead, because I love mixing metaphors ironically, I will use my usual manner of breaking such documents down, taking advantage of one of my favorite movies of all time, The Good, the Bad, and the Ugly, except that it’ll probably be just two divisions: The Good, followed by The Bad and The Ugly.

But first, an overview.

“Gold Standard Science”: A meaningless platitude

After the title page, anyone reading this plan will be immediately faced with…platitudes:

While Dr. Bhattacharya is correct to point out that the NIH has long championed rigorous science, the immediate question anyone reading this document should ask is: What is Dr. Bhattacharya proposing under the administration buzzword of “Gold Standard Science” that is different from what the NIH had long been doing to improve the scientific rigor and reproducibility of the research it funds dating back to decades before Dr. Bhattacharya had emerged from the primordial soup of COVID-19 contrarian narratives to proclaim himself a free speech martyr, just because the “let ‘er rip” natural herd immunity approach to the pandemic codified in his “Great Barrington Declaration” was correctly and roundly criticized by real public health physicians and scientists? Reading this document, my feeling was a lot like what the late great Harriet Hall used to say about naturopathy, and I’ll paraphrase a bit to make the analogy fit: What is good about this plan is not unique (or new) to the administration’s “Gold Standard Science,” and what is new or unique in this plan is not good.

The first tell that this document is explicitly based on President Trump’s executive orders on “Gold Standard Science.” In the first paragraph, we read:

In 2025, the Executive Order (EO) on Restoring Gold Standard Science and Agency Guidance for Implementing Gold Standard Science in the Conduct and Management of Scientific Activities directed NIH and other federal agencies to implement principles of gold standard science in the conduct and management of all aspects of their scientific activities. NIH strives for scientific excellence and welcomes the opportunity to reaffirm its continued commitment to this goal. In response to the EO and guidance, and in accordance with its continued commitment to promoting the highest standards of scientific integrity, NIH has developed this inaugural plan to highlight success and provide a roadmap for the future. What follows is a description of exemplary policies, activities, and initiatives across NIH that demonstrate the agency’s commitment to the tenets of gold standard science.a

Again, let’s peruse the nine supposed characteristics of “Gold Standard Science”:

1. Reproducible
2. Transparent
3. Communicative of Error and Uncertainty
4. Collaborative and Interdisciplinary
5. Skeptical of Its Findings and Assumptions
6. Structured for Falsifiability of Hypotheses
7. Subject to Unbiased Peer Review
8. Accepting of Negative Results as Positive Outcomes
9. Without Conflicts of Interest

Let’s see if you can spot the problematic characteristics. The thing to remember, of course, is that all of these characteristics can only be unobjectionable if you ignore everything that the administration has been doing since President Trump took office again in January. If you keep in mind the cancelation of grants that the administration finds ideologically objectionable due to “DEI,” Dr. Bhattacharya’s appeals to “academic freedom” to attack his science-based critics (even labeling yours truly as a “threat to science” in the process), the ideology-based cancellation of $500 million for mRNA vaccine research, and everything else that led me (and others) to label this administration’s science policies as “Lysenkoism 2.0,” then certain of these characteristics (e.g., #3, #4, #5, #7, and #9) start sounding, to varying degrees, more ominous.

However, before we get to the ominous parts of this plan, which can be viewed as the Greeks within the Trojan Horse, let’s look at the actual Trojan Horse itself hiding the invading force.

“Gold Standard Science”: The “good” (sort of)

Perhaps the best example of the unobjectionable bits of the plan appear in the first point, that science be reproducible. The plan correctly points out that reproducibility and replicability are not the same thing. In brief, reproducibility means that multiple investigators using different methodology can test a hypothesis and reliably come to the same conclusions, either refuting or supporting the hypothesis, while replicability means that different researchers using the same methods produce the same results. Over a page of this 14-page document—which is the actual page count if you remove the title page and the splash page reproduced above—is devoted to describing past efforts of the NIH to improve reproducibility in the research that it funds, and describes what the NIH already does today:

Importantly, NIH believes that making the results of NIH-funded research available is key to advancing transparent, rigorous, and reproducible research, as illustrated by its Data Management and Sharing Policy, Genomic Data Sharing Policy, Public Access Policy, Dissemination of NIH-Funded Clinical Trial Information Policy, and other sharing policies. To ensure NIH supported data are generated in accordance with the highest standards, NIH trains and supports researchers in their gold-standard data sharing efforts, such as advancing FAIR (findability, accessibility, interoperability, and reusability) data principles. NIH also maintains a robust modern data resource ecosystem made up of biomedical data repositories and knowledge bases, including a repository of common data elements (CDEs) to standardize the way data is collected and make data from different studies more interoperable. NIH also funds databases of standard data elements for specific areas of biomedical research, such as genomics. Moreover, TRUST (Transparency, Responsibility, User Focus, Sustainability, and Technology) principles are emphasized in the data resource ecosystem to build trustworthiness and ensure long-term accessibility. Maintaining scientific data in publicly accessible repositories facilitates replication and supports reproducibility.

Sounds pretty good, right? So what will Dr. Bhattacharya add to these efforts? This:

NIH continuously seeks new strategies for advancing reproducible and replicable biomedical approaches, and is planning to develop new, targeted funding mechanisms and programs that foster culture change across the research enterprise. NIH is planning new efforts to support reproducing and replicating data and research results, including those focused on sharing negative or null results. NIH is also identifying areas in which more tools are needed to deliver replicable, translatable, and efficient results such as human-based research technologies and expansion of efforts of the Interagency Coordinating Committee on the Validation of Alternative Methods (ICCVAM).

Programs throughout NIH are also working to incorporate research specific priorities focused on rigor to strengthen translatability of research outcomes. For example, NIH is developing Reproducibility and Integrity Guidance to Optimize Research (RIGOR) for Dietary Supplements to strengthen the experimental design and methodological rigor applied in NIH-funded dietary supplement and related nutrition research. A current challenge in this area of research is limitations in research comparability and translatability when the information characterizing a natural product is incomplete. The RIGOR for Dietary Supplements activities may include creating best practice guidance and training resources, prioritizing research funding opportunities, or enhancing the review of NIH grant applications.

Again, the Devil resides in the details. The first paragraph lists fairly unobjectionable ideas—and, make no mistake—these are just ideas and outlines, rather than anything resembling an actual specific plan—to improve reproducibility and replicability. Of course, one problem with this is that the current NIH budget is very much a zero-sum game, given the proposed massive cut (40%) in the administration’s budget request; so any resources shifted to just reproducing past work will harm efforts to forge ahead with new research.

The second paragraph gives away the game. We at SBM have long discussed how lacking the evidence is for most supplements and how the DSHEA of 1994 basically allowed supplement manufacturers close to free rein to make bogus health claims for supplements. If the people in charge of applying the RIGOR activities to NIH funding decisions were science-based investigators, rather than what is more likely, MAHA aficionados appointed by RFK Jr. to promote the non-evidence-based and non-science-based use of supplements, I’d have no problem with this. However, having watched RFK Jr. for over two decades, I am under no illusions that those in charge will actually make sure that actual rigorous science is applied to supplements research. It’s also pretty telling that the one specific example that Dr. Bhattacharya chose is supplement research. I’d love to be proven wrong but, sadly, don’t think that I will be.

As for the metrics to determine success? The plan includes a sample evaluation planning table for this “tenet.” Amusingly, it includes as outcomes tracked:

NIH funded studies have clear, standardized, and justifiable protocols; comprehensive documentation; robust statistical methods; adequate sample sizes; validated methodologies; and appropriate controls.

Presumably Dr. Bhattacharya already has these metrics for NIH grants funded over the last, say, two or three years, right? No? Then how does he know it’s a problem? Moreover, the outcomes listed above are criteria for peer review; if there’s a problem with NIH grants not meeting the standards above, then it’s the peer review system that’s the problem. Personally, though, having served on NIH study sections, I’ve never seen a grant garnering a fundable score that lacks in any of the “outcomes” that Dr. Bhattacharya wants to track. I realize this is just anecdotal experience, but if this were really a problem I do think that I’d have seen at least one grant garner a fundable score while lacking in one or more of the criteria listed above.

Similarly, the section on transparency is mostly unobjectionable. Once again, the plan spends a lot of verbiage discussing what the NIH already does to promote transparency in research funding decisions, including funding the National Library of Medicine and PubMed, RePORTer (a searchable database of all NIH-funded research dating back to 1985), as well as ClinicalTrials.gov, all programs that have been around for many years. So what can Dr. Bhattacharya add? Not much. Dr. Bhattacharya touts “”the development of a Common Form “”working with its federal partners to provide consistency in reporting research and financial disclosures through the adoption of a Common Form” and requiring the adoption of Animal Research: Reporting of In Vivo Experiments (ARRIVE) guidelines, which basically just require more rigorous statistics to be used in animal experiments. In other words, this is all pretty incremental and unremarkable.

I’m going to skip ahead to #6, “structured for falsifiability of hypotheses, because, as you will see, #3 and #4 are problematic. The plan first notes prior efforts, of which anyone who’s ever written an NIH grant application in the last decade or two will already be aware:

As stated in the Reproducible section, NIH updated its grant application and review processes to enhance the reproducibility of research findings through increased scientific rigor and transparency. This policy requires grant applications to clearly outline, and be evaluated on, 1) the rigor of the prior research, 2) rigorous experimental design for robust and unbiased results, 3) consideration of relevant biological variables, and 4) authentication of key biological and/or chemical resources. Increasing emphasis on these areas clarified NIH’s long-standing commitment to funding the best and most rigorous science and ensured that all grant applications were held to the same gold science standard. NIH resources and training on rigor and reproducibility help researchers design research questions, hypotheses, and experiments to 1) allow for rejection after thorough testing and evidence generation, and 2) support reviewers in their fair and consistent evaluation of grant applications.

In addition to NIH’s FY23 updates to its Guidelines and Policies for the Conduct of Research in the IRP—which emphasizes the importance of research records documenting the entire research process from formulating research questions and hypotheses to interpreting data—NIH also provides training on the Responsible Conduct of Research (RCR). To bolster the significance of RCR principles in the next generation of scientists, all NIH intramural researchers are required to participate in ongoing RCR training, and all NIH research training programs are required to consider including instruction on RCR.

Again, all of this is old hat. So what does Dr. Bhattacharya add? Not much:

In FY25, FDA and NIH launched the Modernizing Research and Evidence (MoRE) Glossary for more than 40 clinical research terms and definitions used to describe design, methods, analysis, and interpretation of innovative clinical study designs, including studies using real-world data for FDA-regulated medical products (i.e., drug, device, or biologic). The goal of this collaboration is to facilitate efficient, rigorously-designed clinical studies of drugs, devices, and biological products. By providing consensus for terms and definitions, this glossary promotes communication and the use of specific terms allowing for more effective falsifiability of hypotheses. FDA and NIH will continue to collaborate and explore opportunities to build out this effort and develop additional consensus definitions for clinical research terms to aid in the innovation of clinical study designs that support scientific, patient, clinical, and regulatory decision-making.

That’s all very…nice. Basically, MoRE is a glossary of terms. Admittedly, it’s a highly useful glossary of terms, but it’s basically a glossary of terms. How, exactly, this will contribute to more rigorous science is not entirely clear to me. Sure, having a common dictionary can facilitate communication between FDA and NIH, but will that necessarily lead to more rigorously designed and conducted clinical trials? I don’t know. I do know, however, that it depends on how the glossary is used and operationalized, and I have little faith in Dr. Bhattacharya and the other RFK Jr. sycophants, toadies, and lackeys who are increasingly running the NIH.

Another issue is that the NIH doesn’t usually fund clinical trials used by companies and sponsors in their applications for FDA approval; rather, the NIH tends to fund preclinical research and earlier stage clinical trials that provide the evidence base for the larger phase 3 clinical trials used for FDA approval. More importantly, this program was developed before Bhattacharya took over. It’s something that the NIH was already doing. It’s all well and good that Dr. Bhattacharya has adopted it, but I can’t help but get the feeling that he’s trying to claim ownership of something that he had nothing to do with developing.

Now let’s move on to #8, “Accepting of Negative Results as Positive Outcomes.”

This is by far the shortest section of the plan and is, from my reading, quite the nothingburger. All Dr. Bhattacharya does is to mention existing efforts started before his tenure to put raw data into data repositories to be shared and analyzed by other scientists, to encourage the reporting of negative results, and the NIH PrePrint Pilot program, which is designed to encourage the sharing of NIH-supported research as preprints by indexing preprints in PubMed and including them in PubMed Central (PMC). What does Dr. Bhattacharya add to this?

Not much:

In FY24, NIH released a Request for Information on Potential Solutions for Reducing Publication Bias Against Null Studies to solicit public input on the barriers and solutions to reducing publication bias (i.e., the preferential dissemination of statistically significant or otherwise exciting studies) in biomedical research. After reviewing the responses received, NIH plans to launch new, ground-breaking initiatives to solve this multi-faceted issue

That’s right. Dr. Bhattacharya is just going to analyze the answers solicited as part of an initiative started under the previous administration. Outstanding, particularly the way that he appears to be claiming the initiative as his own.

That’s it for the “Good.” As you can see, these initiatives were all started under prior regimes running the NIH, represent nothing new or groundbreaking, and are incremental. There’s nothing wrong with incremental improvements and tinkering with existing regulations and procedures in order to develop systems that encourage more rigorous science. That is actually a good thing! The problem is that, like President Trump, Dr. Bhattacharya is representing this stuff as though it were “new” and “groundbreaking.” It’s not. Unfortunately, what might be “new” and “groundbreaking” is not good.

“Gold Standard Science” The Bad and The Ugly

It didn’t take me long to note that five out of the nine characteristics of “Gold Standard Science” (#3, #4, #5, #7, and #9) have…problems. Unsurprisingly, those problems involve clear hints of ideological capture of the science that the NIH will fund, and it isn’t even subtle. In other words, the shell of the Trojan Horse consisting of incremental building upon efforts to improve scientific rigor started during previous administrations hides a whole bunch of invaders patterned after Lysenkoism.

Let’s start with #3, “Communicative of Error and Uncertainty,” which contains the first big “tell” of the document. After an introduction that, once again, discusses prior efforts by the NIH to ensure scientific rigor and communicate uncertainty in results, Dr. Bhattacharya’s plan goes where I always knew it would go:

NIH policies have always supported the public dissemination of research. However, academic freedom matters most in cases where scientists are pursuing evidence that may be perceived as inconvenient or objectionable. By prioritizing academic freedom across the agency, NIH is working to strengthen public trust.

NIH is drafting a new chapter on gold standard science for the 2025 revision of the comprehensive collection of Guidelines and Policies for the Conduct of Research in the IRP. NIH is also embarking on a review of policies and practices within its IRP to further promote academic freedom to ensure NIH scientists are guaranteed the freedom to engage in open, academic discourse without fear of official interference, professional disadvantage, or workplace retaliation. Critical evaluation of evidence and a willingness to challenge the conventional thinking are essential for ensuring scientific rigor, meaningful results, and communication of those results. NIH continues to encourage scientists to freely communicate their scientific findings to the public and through scientific journal publications, reports, and conferences. NIH is exploring plans to shift its process for scholarly works from approving scientific content or findings to reviewing exclusively for policy and regulatory compliance. Processes around media engagement are also being modified to ensure preservation of academic freedom.

The very same sort of language appears in #5, “Skeptical of Its Findings and Assumptions”:

Critical to this tenet and referenced previously, NIH has announced a new, comprehensive review of policies and practices within its IRP to ensure that academic freedom is the rule, and not the exception. Academic freedom allows scientists to freely express skepticism of findings and propose alternate views and methods. NIH will also ask scientists to evaluate and critique the efficacy of agency policies through a new Pilot NIH Science of Science Scholars Program. This program provides the opportunity for experienced “science of science” researchers to analyze internal NIH administrative data to evaluate NIH’s contributions and impact to biomedical research, optimize NIH’s investments, and ensure scientific quality, rigor, and reproducibility.

Longtime readers of this blog and anyone who’s paid attention to ideological science probably saw a whole bunch of red flags in the passage above. After all, “academic freedom” in the parlance of people like Dr. Bhattacharya became a tactic to deflect legitimate scientific criticism of bad science favored by the right. If you correctly criticized, for instance, the Great Barrington Declaration, the manifesto backed by the right wing “free market” think tank American Institute for Economic Research (AIER) that advocated a “let ‘er rip” approach to the pandemic in 2020 in order to reach “natural herd immunity”—with a poorly thought out suggestion for the “focused protection” of high risk groups—a plan not based in science that would lead to more death and disability than necessary and never would have worked, you were framed as attacking the “academic freedom” of COVID contrarians like Dr. Bhattacharya, one of its co-authors. If you criticized Dr. Bhattacharya too harshly, you were to him a “threat to science” and were trying to “cancel” or “silence” him, rather than a scientist criticizing what he viewed as bad science. Of course, my being in any way a “threat” to Dr. Bhattacharya or ever having had the power to “silence” him is rather belied by the simple fact that he is now the NIH Director and I am just a lowly professor of surgery at a solid mid-tier medical school and the managing editor of a popular, but not COVID-19 contrarian Substack-level popular, blog.

This framing had the advantage of allowing Dr. Bhattacharya to falsely portray himself as a persecuted hero of intellectual and academic freedom, while, now that he’s in charge, behaving more like Trofim Lysenko and purging the NIH of any science related to COVID-19 vaccines, “DEI,” transgender medicine, or anything else that the administration doesn’t like and encouraging research into any old pseudoscience that RFK Jr. wants in the name of MAHA. Let’s just put it this way. What sort of reaction do I expect if and when scientists who actually know what they are talking about criticize research being done at NIH regarding antivax priorities, such as investigating the nonexistent “link” between vaccines and autism. Color me…skeptical…that Dr. Bhattacharya will react well to that or protect those who voice their concerns about the NIH agenda being hijacked by MAHA pseudoscience. After all, his history of anger and whining in response to criticism of his failed predictions that we’ll have “natural herd immunity” in 3-6 months tell us how he will react to criticism now that he is no longer an insurgent contrarian but is now solidly a leader of the medical establishment.

But, hey, Jay might prove me wrong, and I’d be happy to be proven wrong. I just don’t expect it, because it’s incredibly unlikely.

Think I’m being too harsh? Let’s look at #4, “Collaborative and Interdisciplinary.” Who could object to that? Also, the NIH has long favored grant applications that propose research that involves multiple disciplines and collaborations. this is nothing new. The actual agenda can be gleaned very easily from the actual proposal of what Dr. Bhattacharya is doing now:

To further maximize the opportunity for cross-agency collaboration, NIH plans to launch new collaborative initiatives that directly address urgent research and health issues of today. In May 2025, NIH announced a landmark partnership between NIH and the Centers for Medicaid and Medicare Services (CMS) to enable research around the root causes of autism spectrum disorder. In collaboration with the HHS Office of the Chief Data Officer and partner agencies including CMS, ARPA-H, CDC, and FDA, NIH is building a Real World Data Network that will support initiatives to study autism, chronic disease, and other key public health concerns. NIH will also join the U.S. Food and Drug Administration (FDA) to form the Nutrition Regulatory Science Program, a joint innovative research initiative to implement and accelerate a comprehensive nutrition research agenda to inform effective food and nutrition policies to help make Americans’ food and diets healthier. NIH also intends to prioritize and fund human-based research technologies and expand the efforts of the multi-agency ICCVAM.

Yes, the document is referring to the initiative announced by RFK Jr. in April in which he promised to investigate the “environmental” causes of autism and have a report out by September, which is—yikes!—next month. True, he has fudged the promised date a bit, and I don’t know if there will actually be a report in September, but I do know this: Given that the initiative is headed by David Geier, a longtime antivax “researcher” best known for working with his late father Mark as part of a father-son antivax team promoting the use of puberty blocking drugs and chelation therapy to treat “vaccine-induced autism” and playing a major role in developing the antivax playbook for “proving” falsely that vaccines “cause autism,” there is no doubt in my mind that whatever report comes out whenever, it will conclude that the main autism is vaccines, all the evidence showing that vaccines are not associated with increased autism risk be damned. Moreover, I’m not even discussing the parts that are clear MAHA involving diet, exercise, and chronic disease. Basically, “collaborative and interdisciplinary” in this context appears to involve collaborating with cranks in other disciplines who have no relevant expertise in the topic of the research grant, as long as this “collaboration” occurs in research efforts designed to prove whatever RFK Jr. wants proven.

Let’s move on to #7, “Unbiased Peer Review.” One is tempted here to ask what Dr. Bhattacharya means by “unbiased.” I like to point out that in any human endeavor involving evaluation of a proposal, there is no such thing as “unbiased.” As human beings, we all have biases; all we can do is to construct systems that minimize the effects of the preexisting biases of reviewers. Unfortunately, for all the appeals to “unbiased peer review” and “gold standard research,” I remain unconvinced that this is really what Dr. Bhattacharya is about because it is clear that coming as close as possible to truly “unbiased peer review” is not what the administration or RFK Jr. is about. For example, the plan states:

Peer review at NIH proceeds via a two-tiered system involving initial peer review for scientific and technical merit and subsequent review by National Advisory Councils or Boards that recommend applications for funding, with consideration of the funding ICO mission and research priorities. Both levels of the NIH peer review process involve the consistent application of standards and procedures that produce fair, equitable, informed, and unbiased examinations of grant and cooperative agreement applications to NIH (see section 492 of 42 U.S.C 289a (Public Health Service Act) and Federal regulations).

This is basically true. There are two levels of evaluation of grant applications before funding decisions are made. There is the study section level, in which committees known as study sections review grants and assign them a priority score based on scientific merit. Then there is the council review, where the actual funding decisions are made. Before Trump, RFK Jr., and Bhattacharya, these decisions by the Advisory Councils were mostly a rubber stamp of what the peer reviewers in the study sections did. Basically, funds from each Institute or Center would be allocated starting with grants with the very best scores and then the next best, all the way down until the money ran out. Given the current funding levels at NIH, in recent years that tended to mean that the top 10% or so of grant applications would be funded.

So what is Dr. Bhattacharya going to add to this? Not much, but it is nonetheless disturbing if you know some background. I’ll simply quote first, to see if you can detect the problem, and then I’ll give you that background that leads me to be very worried:

In March 2025, NIH announced a new plan to centralize the initial peer review process for all applications for grants, cooperative agreements, and research and development contracts solely within CSR. Centralizing peer review will make NIH review more efficient and minimizes appearance of preferential treatment depending on which IC manages review.

NIH is also developing a Conflict of Interest (COI) tool for NIH staff charged with screening potential reviewers that gathers publicly available information such as authors on publications and patent holders in combination with data already in NIH systems. This tool will allow staff to more thoroughly vet reviewers for potential COIs before making assignments to specific applications. In addition, NIH has an active Review Integrity Committee which will host interactive workshops on specific review integrity topics tailored to address current issues.

CSR is the Center for Scientific Review and is the part of the NIH that runs the study sections that review incoming grant applications. You might reasonably ask: What the heck does that even mean. For that you have to look at the actual March proposal:

The new centralization effort will apply to the first stage of the review process. NIH’s CSR, which was established in 1946 to manage the scientific review of NIH grant applications and to ensure independent, expert review free from inappropriate influence, currently manages the peer review process for more than 78% of NIH grants. The remaining 22% are reviewed in study sections within 23 ICs, each operating separately with its own administrative and support overhead. The proposed consolidation would eliminate the IC-based study sections so that CSR conducts all first-level review.  

According to an analysis of FY24 data, CSR uses 0.3% of the NIH budget to review more than 66,000 applications annually. In comparison, review costs in the ICs average about 300% of CSR’s costs. 

On the surface, that sounds reasonable. On the surface. Again, you have to remember what’s been happening at NIH. Last month, the NIH “disinvited” a large number of scientists who had been invited to serve as Advisory Council members by the last administration and had been selected using a process in place for decades.

Worse:

NIH staff members have been instructed to nominate replacements who are aligned with the priorities of the administration of US President Donald Trump — and have been warned that political appointees might still override their suggestions and hand-pick alternative reviewers.

You see where I’m going, right? If not, let me just bring it home a bit more, quoting the same story:

Nature has learnt that, as a result, some staff members are screening candidates’ social-media presences to check whether they have expressed negative views about the Trump administration or been involved in diversity, equity and inclusion (DEI) efforts — a topic targeted by the president — at their institutions.

Now, do you get it?

If not, let me quote from a recent executive order that I discussed two weeks ago in which President Trump, in essence, put the final control of NIH grant funding decisions in the hands of political appointees, something that’s never been done before. Political appointees have been in charge of NIH before, but there is a longstanding practice that grant review and grant funding decisions be as apolitical as possible. Not anymore:

Nothing in this order shall be construed to discourage or prevent the use of peer review methods to evaluate proposals for discretionary awards or otherwise inform agency decision making, provided that peer review recommendations remain advisory and are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding by senior appointees or their designees.  Further, nothing in this order shall be construed to create any rights to any particular level of review or consideration for any funding applicant except as consistent with applicable law.

As I wrote when I first saw this EO, while it is possible to read this EO in a way that doesn’t sound too horrible (with difficulty), to me such a view is whistling past the graveyard of US science. This EO is basically the formalization of what I’ve been calling the science and medical policies of this administration: Lysenkoism 2.0. Taken in the context of this recent EO and the “disinvitation” of scientists “not aligned with administration priorities” to serve on Advisory Councils, I find it very difficult not to view this “plan” from Dr. Bhattacharya to centralize peer review to eliminate the 22% of grants not reviewed in CSR as cut from the same cloth, designed to bring all peer review and grant disbursement completely under the control of political appointees. (Old NIH hands, please, tell me I’m wrong here. Tell me I’m misunderstanding and why. I don’t think I am, though.)

In fairness, there have been proposals to centralize all peer review at CSR that have been batted around going back a long time and this plan appears to date back to 2024, but I find it rather interesting that NIH announced its plan to do so before Dr. Bhattacharya even assumed the position of NIH Director. Indeed, the section justifying this policy is almost verbatim from a press release dated March 6, 2025. In other words, this was a policy implemented by then-Acting Director Matthew Memoli, not Dr. Bhattacharya, and it was done primarily to save money rather than actually improve peer review.

Finally, let’s look at #9, “Without Conflicts of Interest.” Again, this proposal sounds pretty innocuous on the surface. However, if you consider RFK Jr.’s ranting about “conflicts of interest” in which anyone who disagrees with him must be in the thrall of Big Pharma (a.k.a. the “pharma shill” gambit), it’s not difficult to see this particular requirement being used selectively deny NIH funding to scientists it doesn’t like. For example, one can easily see any COI involving a pharmaceutical company as being a negative, while, again in the spirit of MAHA, a COI involving supplements, “functional medicine,” or any other pseudoscience that RFK Jr. likes would be overlooked.

Lysenkoism 2.0 is here

As I come to the end of my discussion, I keep wondering whether Dr. Bhattacharya really believes that what he is proposing will genuinely improve the scientific rigor of the research projects funded by the NIH (e.g., he’s a useful idiot for the Trump administration, RFK Jr., and OMB Director Russell Vought whose sense of grievance and desire for retribution against the critics whom he views as enemies who unjustifiably “canceled” him has led him to destroy what’s left of his reputation by signing on to be the face of the Lysenkoization of the NIH. The other possibility is that his sense of grievance at what he views as unfair criticism and his self-image as a free speech martyr led him to sign on enthusiastically; i.e., that he is down with the entire Trumpian project with respect to US science. I don’t know

Whatever the case, there is no longer any doubt that Lysenkoism 2.0 is here in the US with a vengeance (literally). The characteristics are undeniable, and Dr. Bhattacharya appears to have little or no problem with any of them, although he does appear to have just enough shame left to try to disguise what is really going on. In any case, in the new NIH, just as occurred in the USSR under Lysenko for three decades, ideology trumps science, scientists not buying into the new scientific dogma lose favor and funding and even risk being fired, while scientists who toe the line and do research that produces results “aligned with administration priorities) will be rewarded. As before, I can’t help but think that I predict that RFK Jr., acting as the willing tool of President Trump and aided by useful idiots like Dr. Bhattacharya, will change the process by which research grants are issued by the NIH to resemble less scientific peer review and more political patronage, in which political appointees pull the strings and peer review is just “advisory.”

There is a longstanding view among science-denying conspiracy theorists that the NIH decides on the scientists to whom it wards grants based not on rigorous peer review, but more through a process of patronage, a corrupt process that resembles something out of The Godfather, in which the leader doles out favors as a reward for services and loyalty, rather than an unbiased process that rewards merit in science. Of course, as I said two weeks ago, every accusation is a confession, and it is therefore not surprising that the new administration appears intent on turning the NIH grant process into a form of Lysenkoism that, like the old Lysenkoism, rewards political correctness over science and punishes dissent, Dr. Bhattacharya’s performative claims to want to promote “academic freedom” notwithstanding. I’m also sure that, RFK Jr. being RFK Jr., and Donald Trump being Donald Trump, there will be a lot of grift added, making the comparison to The Godfather even more appropriate.

I fear that the damage already done in a mere six months is so great that I will not live long enough to see it repaired, and what’s left of my science career certainly won’t last long enough to have any hope of its correction.