The NIH Restructuring Congress Rejected Is Happening Anyway

(I used Gemini Nano Banana 2 to create this fictional image.)

Multiple proposals to restructure the National Institutes of Health have been debated over the past two years. The White House’s fiscal year 2026 budget proposed consolidating NIH’s 27 Institutes and Centers into eight. A congressional report suggested reducing them to 15. Think tanks floated regional models and block grants to states.

Congress rejected them all. The votes weren’t there. The political support didn’t materialize. The proposals failed to advance through the legislative process that major institutional changes to federal agencies traditionally require.

The restructuring is happening anyway. It proceeds through administrative action, executive authority, and bureaucratic maneuvering that bypasses congressional oversight entirely.

This is not routine executive discretion over agency operations. This is systematic dismantling of an agency’s structure, mission, and capacity without the legislative approval that such changes have historically required. And it is accelerating.

The Proposals Congress Rejected

The most radical proposal came from the Heritage Foundation’s Project 2025: replace much of NIH’s competitive grant-making authority with block grants to states. Federal funds would be distributed to states, which would then allocate research dollars according to their own priorities and processes. This would fragment the national coordination that makes large-scale biomedical research possible.

The White House’s budget proposed consolidating the 27 Institutes and Centers (ICOs) into eight, eliminating several units entirely including the National Institutes for Nursing Research, National Center for Complementary and Integrative Health, Fogarty International Center, and National Institute on Minority Health and Health Disparities. A House Energy and Commerce Committee report suggested a more modest consolidation to 15 institutes. Another blueprint recommended replacing the national structure with four regional entities (Northeast, South, Midwest, and West), each with its own director.

These proposals varied in specifics but shared common elements: fewer institutes, less autonomy for scientific program staff, more centralized political control, and reduction of the coordination mechanisms that enable research at national scale.

None secured congressional support. The most recent budget negotiations resulted in full funding for all 27 institutes, centers and offices. No consolidation language made it into appropriations bills. The legislative branch declined to authorize the restructuring that executive branch officials and their think tank allies had proposed.

That should have settled the matter. It didn’t.

Restructuring Without Votes

When these proposals failed to advance legislatively, a different strategy emerged: implement the restructuring administratively. Offices could be closed without congressional hearings. Review panels could be eliminated through internal reorganization. Funding mechanisms could be centralized through executive policy changes. Institute autonomy could be stripped through bureaucratic directives. Approved budgets could be restricted through executive discretion.

No legislation required. No floor debate. No recorded votes. Just administrative action, presented as routine management decisions.

The following examples illustrate how major institutional restructuring is being accomplished at NIH without the congressional approval it would traditionally require.

Closing Offices Without Hearings

In March 2025, seven employees who had worked at NIH’s Sexual & Gender Minority Research Office were placed on administrative leave without warning or explanation. The office, established in 2015, was created to coordinate research and activities for SGM populations across the NIH. It focused on health disparities in LGBTQ populations: higher rates of certain cancers, mental health challenges, and barriers to care. Its creation was prompted by a 2011 Institute of Medicine (IOM) report and subsequently strengthened by the 21st Century Cures Act signed into law December 2016, which officially mandated the inclusion of SGM populations in NIH research.

In December 2024, all seven staff were preemptively reassigned to other offices in anticipation that the incoming administration would dismantle their unit. They were given little choice in the reassignment. Three months later, they were placed on indefinite administrative leave. The research portfolio they built (peer-reviewed grants, multi-year studies, collaborative networks) was left in limbo.

No formal announcement explained the decision. The office simply stopped functioning. No congressional committee held hearings. No appropriations language authorized the closure. It happened through administrative action alone.

Eliminating Specialized Review Panels

The NIH’s Center for Scientific Review (CSR) had historically reviewed 78% of grant applications, about 66,000 per year. The remaining 22% were reviewed by panels run by NIH’s individual institutes and centers, which brought specialized expertise to particular research areas.

In 2025, the administration eliminated all institute- and center-run review panels. Many of the scientists overseeing them were laid off. NIH leadership framed the change as improving efficiency by consolidating review. But researchers and remaining NIH staff understood it differently: as centralization of control that removes specialized scientific judgment from funding decisions.

When review authority is consolidated, it becomes easier to impose uniform priorities from above. Specialized panels had provided a buffer. They brought deep expertise to narrow fields and maintained some autonomy for institutes to steward their scientific domains. That buffer is gone.

Congress was not consulted. No legislation authorized the elimination of these panels. The restructuring of NIH’s peer review system (a core function of the agency) happened through administrative directive.

Redirecting Institute Missions

The National Institute of Allergy and Infectious Diseases (NIAID), historically central to infectious disease research and pandemic preparedness, has undergone significant reorientation without congressional input.

Staff were directed to remove references to “biodefense” and “pandemic preparedness” from institute materials. An infectious disease research group that had participated in outbreak modeling and early-detection collaborations for years was advised to pivot toward projects with more immediate clinical endpoints. Long-term surveillance modeling, once supported under preparedness funding lines, was no longer prioritized.

When researchers asked how the networks and analytic tools they had built over years of federal investment would be sustained, the answer was uncertain. They were encouraged to explore “alternative partnerships,” which, in many cases, do not exist. Alternative partnerships don’t fund decade-long surveillance infrastructure or maintain expertise during quiet periods between outbreaks.

Preparedness research rarely produces visible returns in quiet years. Its value becomes evident only when a crisis emerges. When such work is deprioritized administratively, institutional memory and technical capacity dissipate gradually. By the time the next pandemic arrives, the networks will be gone. The expertise will have moved to other fields. The surveillance systems will have lapsed.

Congress appropriated NIAID’s budget with the expectation that infectious disease preparedness would remain a priority. The mission redirection is happening without legislative authorization.

Centralizing Control Over Research Priorities

The NIH is eliminating the individual websites of its 27 Institutes, Centers, and Offices. Each one currently maintains a public-facing website explaining its unique scientific mission, research priorities, and funding opportunities. These will be replaced by a single centralized page offering minimal information.

Simultaneously, the institutes are losing authority to issue specialized funding announcements targeted at specific research gaps. The NIH central leadership will now vet all such proposals and has stated its intention to reduce specialized funding opportunities by at least 50%.

This may sound like administrative tidying. It is not. When an institute identifies an emerging scientific need (a gap in antibiotic resistance research, a cluster of unexplained pediatric cancers, a promising but underfunded area of Alzheimer’s biology), it previously had authority to issue a targeted funding announcement, convene expert reviewers, and direct resources toward that gap quickly. This specialized funding mechanism allowed scientific program staff to actively steward their fields rather than passively wait for whatever applications happen to arrive.

Eliminating this capacity serves two purposes. First, it removes scientific decision-making authority from civil servant scientists and concentrates it in political leadership. Second, by erasing the visible distinctions between institutes (their unique missions, their specialized expertise, their targeted priorities), it makes the case for consolidation easier to justify. If all 27 institutes are just processing generic applications through the same centralized review, why maintain 27 separate entities?

The answer is that they weren’t just processing generic applications. They were actively identifying gaps, directing resources toward neglected areas, and exercising scientific judgment about emerging needs. That stewardship function is being systematically dismantled through administrative directive, not legislative reform.

Withholding Congressionally Approved Funding

Perhaps the most brazen example involves funding that Congress has already appropriated and the President has already signed into law.

Weeks after Congress rejected the Trump administration’s proposed cuts to NIH and passed a full-year budget on February 3, 2026, the White House Office of Management and Budget (OMB) has refused to authorize release of the funds. The NIH has not received approval to spend any of the research funding that Congress allocated and the President signed.

Normally, after a budget bill becomes law, agencies automatically receive permission to spend a 30-day portion of their annual funding immediately. This permission is renewed every 30 days until OMB approves the agency’s spending plan, which unlocks the full appropriation.

But the OMB changed those rules. Last August, it revised a document known as Circular A-11 to restrict automatic 30-day portions to cover only essential expenses such as employee salaries. Research grants (the core of NIH’s mission) were excluded from this automatic release.

Until its newly appropriated budget is released, NIH can issue new research awards only using leftover money from stopgap funds approved in November 2025. New grant awards have therefore slowed to a trickle.

A similar situation occurred last year, and the NIH issued about 24% fewer new grants than the ten-year average. This year could be worse than last year if the funding blockade continues.

The mechanism is procedural. The effect is substantive. Congress appropriated the funds. The President signed the law. The money exists. The OMB is simply refusing to release it. This is not budget management. It is nullification of congressional appropriations through executive obstruction.

Compounding this obstruction is the implementation of a new “Unified NIH Funding Strategy” that eliminates paylines as the primary mechanism for grant funding decisions. Under the new policy, NIH staff must now justify each funding decision using multiple, sometimes competing criteria.

All ICOs must ensure their grant funding policies align with NIH’s mission, prioritize scientific merit, consider peer review information in its entirety, integrate topics and approaches relevant to their priorities, promote investigator career development and workforce sustainability, promote broad distribution and geographic balance of funding, consider the total amount and type of NIH funding already available to each investigator, and align with the availability of funds. NIH staff who manage R&D contracts have additional requirements as they must get Presidential appointee approvals for every single action.

Interpreting what these requirements mean individually is challenging. Figuring out how to combine all of these elements into justifiable funding decisions that will satisfy the administration is where the system gums up. NIH staff are navigating this new policy while also managing the funding obstruction, the elimination of specialized review panels, and the loss of institute autonomy over research priorities. The cumulative effect is paralysis masked as process reform.

What’s Being Dismantled

From outside the system, these changes may appear as routine portfolio management: efficiency measures, administrative reorganization, budget discipline. From inside, they represent systematic dismantling of institutional capacity and scientific autonomy without congressional authorization or public debate.

What is being lost is not merely funding or staffing. It is the architecture that makes American biomedical research work at national scale. The coordination mechanisms that pool rare patients across state lines. The specialized review systems that bring deep expertise to narrow fields. The surveillance infrastructure maintained between crises. The institutional autonomy that allows scientific program staff to identify emerging needs and direct resources quickly through targeted funding announcements. The early career training pipelines that build expertise over decades.

These systems were built over 75 years through sustained bipartisan investment and congressional oversight. They function invisibly when they work well. Most people don’t know they exist. That invisibility is precisely what makes them vulnerable to administrative dismantling. By the time the consequences become visible (the missing treatment for a rare disease, the delayed response to an emerging pathogen, the clinical trial that cannot recruit enough patients), it will be difficult to trace the connection back to decisions made in 2025 and 2026.

But the damage will be real. And irreversible. Surveillance networks take years to establish. Clinical trial infrastructure and basic science laboratories require sustained institutional relationships. Expertise, once scattered, does not spontaneously reassemble when political winds shift.

A Precedent That Extends Beyond Science

The restructuring of the NIH through administrative action rather than legislative authorization matters beyond science policy. It establishes a precedent for how any federal agency can be systematically dismantled when an administration cannot secure congressional approval for the changes it seeks.

The pattern is clear: When legislation fails, proceed administratively. Close offices through personnel actions. Eliminate review structures through internal reorganization. Redirect missions through policy directives. Strip institutional autonomy through bureaucratic centralization. Withhold appropriated funds through procedural obstruction. Frame it all as routine management.

This approach threatens any federal agency whose mission or structure protects functions that are politically inconvenient or ideologically disfavored. The NIH is not unique in this vulnerability. It is simply a current target. The environmental agencies, the regulatory bodies, the research institutions, the oversight mechanisms. All are vulnerable to the same pattern of administrative dismantling when legislative authorization cannot be secured.

The question is not whether one supports or opposes any particular restructuring of the NIH. The question is whether major institutional changes to federal agencies should require congressional approval or can be accomplished through unilateral executive action.

Historically, the answer has been clear. Major reorganizations require legislation. That constraint exists not to preserve bureaucratic inertia but to ensure that changes to agencies funded by taxpayers and serving public missions are debated, authorized, and reversible through democratic processes.

When that constraint is bypassed (when Congress says no and the restructuring happens anyway), we are in different institutional territory. The implications extend far beyond any single agency.

Breaking the Silence

In my previous essay, I wrote about why NIH staff cannot speak publicly about what is being lost. They remain silent not from indifference but from risk management. Speaking carries consequences, and staying inside is the only way many believe they can still protect what remains.

This essay is about what they would say if they could.

They would say that Congress rejected these restructuring proposals for reasons: concerns about fragmentation, loss of coordination, elimination of specialized expertise, risk to pandemic preparedness. They would say that implementing the restructuring administratively after legislative rejection is not routine executive discretion. They would say that the coordination mechanisms being dismantled cannot be quickly rebuilt when political conditions change.

They would say that institutional architecture is invisible when it functions well, which is why it can be dismantled without immediate public outcry. And they would say that by the time the damage becomes undeniable (by the time the rare disease goes unstudied, the pandemic spreads unchecked, the clinical trial cannot recruit patients, the cell biology laboratory shuts down), the connection to administrative decisions made without congressional authorization will be difficult to trace.

But they cannot say these things without risking their positions and their ability to protect what institutional capacity still remains. That silence is what I am trying to break. Because what is happening to the NIH matters not only for biomedical research but for the principle that major changes to federal agencies require congressional authorization rather than unilateral executive action.

Congress rejected these proposals. They are happening anyway. That is the story that needs to be told.

This essay is part of an ongoing series reflecting on what I learned over more than two decades working inside the U.S. biomedical research enterprise. Each piece stands alone, but together they examine how science is shaped not only by ideas and funding, but by the structures that support or constrain them.

Sources

The Heritage Foundation. (2025). Mandate for Leadership: The Conservative Promise (Project 2025). https://static.heritage.org/project2025/2025_MandateForLeadership_FULL.pdf

House Committee on Energy and Commerce. (2025, June). Reforming the National Institutes of Health: Framework for Discussion. https://d1dth6e84htgma.cloudfront.net/NIH_Reform_Report_f6bbdca821.pdf

Kulldorff, M. (2025, March 26). A Blueprint for NIH Reform. RCJL Journal of the Academy of Public Health. https://doi.org/10.70542/rcj-japh-art-1prfdvs

Gaffney, T. (2025, March 6). NIH puts former Sexual & Gender Minority Office employees on administrative leave. STAT. https://www.statnews.com/2025/03/06/nih-puts-former-sexual-and-gender-minority-office-employees-on-administrative-leave/

Kaiser, J. (2025, March 7). NIH will eliminate many peer-review panels and lay off some scientists overseeing them. Science. https://www.science.org/content/article/nih-will-eliminate-many-peer-review-panels-and-lay-some-scientists-overseeing-them

Taubenberger, J. K., Powers, J. H., & Bhattacharya, J. (2026). The new vision from the National Institute of Allergy and Infectious Diseases (NIAID). Nature Medicine. https://doi.org/10.1038/s41591-025-04160-1

National Institutes of Health. (2026, January 6). NIH institutes, centers, and offices. U.S. Department of Health and Human Services. https://grants.nih.gov/funding/find-a-fit-for-your-research/nih-institutes-centers-offices

Kozlov, M., Witze, A., & Garisto, D. (2026, February 27). White House stalls release of approved US science budgets. Nature. https://www.nature.com/articles/d41586-026-00601-0

National Institutes of Health. (2025, November 21). Implementing a unified NIH funding strategy to guide consistent and clearer award decisions. https://grants.nih.gov/news-events/nih-extramural-nexus-news/2025/11/implementing-a-unified-nih-funding-strategy-to-guide-consistent-and-clearer-award-decisions