NIH Funding Policy Frequently Criticized by Republicans for "Lack of Oversight," is Based on HHS Framework Created by Trump Administration
What's odd is that shares of two independent vaccine makers would gradually recover, and eventually peak on Febuary 25th, while shares of a third vaccine maker would fall 5.5% during after-market hours, only to make headline news the morning of Febuary 26th.
Trump's department of Health and Human Services (HHS) alarmed millions of Americans on February 26, announcing it was considering pulling funding granted to Moderna to develop an H5N1 avian flu mRNA vaccine based on the flu strains currently circulating in cows and birds.
The funding was granted under the Biden administration in January, and would allow Moderna to expand clinical data supporting the use of mRNA vaccines, against other pathogen strains with pandemic potential.
The threat to vaccine funding was only one of several moves which have left Americans anxiously questioning how the administration might handle another pandemic, including Trump's decision to withdraw the U.S. from the World Health Organization (W.H.O.), and the anti-vax rhetoric of current HHS Secretary Robert F. Kennedy (RFK).
Trump's war on the National Institute of Health (NIH) funding has been relentless since taking office in January, but not entirely surprising. Verbal attacks and accusations against the NIH became Trump's rallying cry after frequent clashes with NIH physician Anthony Fauci during the height of the COVID pandemic. However, it's less clear why he would threaten funding granted to a private company like Moderna.
The funds were awarded to Moderna just three days before Trump took office, and followed by Biden granting a full pardon to Fauci just hours before departing office. While there has been no acknowledgement of any connection between the two events, Biden may have been aware that some of Trump's earliest policy plans would target federal vaccine funding.
In fact, when asked about the decision to weigh cutting funding for Moderna, an HHS spokesperson is quoted as saying, "While it is crucial that the U.S. Department of Health and Human Services support pandemic preparedness, four years of the Biden administration's failed oversight have made it necessary to review agreements for vaccine production."
On February 26th, the same day the Trump administration threatened Moderna funding, a Republican senator re-introduced legislation to halt federal funding for "dangerous" viral gain-of-function (GOF) research. The same senator had attempted to pass similar legislation last summer following House Oversight Select Subcommitee hearings. The focus of the hearings included investigation into NIH funding policy for GOF research. Specifically, the investigation targeted funding granted to the U.S. nonprofit EcoHealth Alliance, and allegations of funding being used to support GOF research at the Wuhan Institute of Virology (WIV).
Roger Marshall's senate bill has been circulated on social media by many virologists who worry the language of the bill was left intentionally vague, and if passed into legislation, could be used to end federal funding for all virology and vaccine research in the United States.
Senator Marshall's webpage provides background information for the bill, stating that in 2014, the Obama administration ordered a pause on all gain-of-function research, and "in 2017 – with key cabinet appointments vacant or pending Senate confirmations – the NIH successfully advocated for lifting the moratorium."
While there is some truth to this information, that is a very deceptive way of describing the reality of the situation. I'll explain why, but to do so, I need to mention a slightly different rabbit hole.
On February 25th, the day before Marshall re-introduced his bill, Senate confirmation hearings quietly began for Trump's Science Advisor/director of Office of Science and Technology Policy (OSTP), Michael Kratsios. If Kratsios' name seems familiar, it may be because he also served as Deputy Chief Technology Officer for OSTP during Trump's first administration, back when those key cabinet appointments were vacant. During his first term, Trump actually broke a record with his vacant cabinet positions that had previously been held by G.W. Bush.
October of 2017 marked the longest term of any president in modern history to wait to nominate a science advisor/director of OSTP. Kratsios filled the vacancy, serving as Trump's acting director of OSTP until Trump eventually appointed meteorologist Kelvin Droegemeier for the position in August of 2018. Kratsios' OSTP leadership role was often questioned by the media at the time.
Kratsios previously worked in technology under Peter Thiel, who helped Trump select several members of his health staff during his first administration. Kratsios holds a degree in political science, but lacks any hard science experience typically expected to qualify an individual for OSTP leadership.
Kratsios was serving as acting director when the NIH moratorium on GOF funding was lifted. This took place nearly a year into Trump's first term, so suggesting that the NIH somehow took advantage of cabinet vacancies to advocate for a dangerous science policy would not only ignore the fact that the science advisor vacancy was due to Trump's own failure to nominate anyone, it would also indicate that concerns about Mr. Kratsios' inability to make important decisions regarding science policy may have been correct.
If that were the case, why would Trump select him for the role of science advisor in 2025 with the threat of another pandemic on the horizon?
Trump's HHS secretary position was also vacant because HHS secretary, Tom Price had recently left the administration following a scandal. However, deputy secretary Eric Hargen served as Trump's acting HHS secretary until the role was permanently filled by Alex Azar for the remainder of Trump's first term. Hargen had previously served as acting HHS secretary under G.W. Bush, suggesting he should have been somewhat familiar with what the job entailed.
It is important to keep all of these individuals in mind when discussing who would have been aware the NIH funding moratorium was being lifted, because the official NIH notice lifting the funding pause cites framework provided by HHS in December of 2017.
While it's unclear who in Trump's administration actually put together the HHS framework, it was created "in response to and in accordance with," recommended guidelines provided by Obama's OSTP before Trump took office. So, why is the role of Trump's administration downplayed in Marshall's bill?
Many Republicans, including the Select Subcommitee members involved in last summer's hearings have frequently claimed that NIH funding of "dangerous" GOF research at WIV, is to blame for the origin of the COVID pandemic. While this theory has never been proven, it has become the "official" explanation of many high ranking individuals. Therefore, it seems important to clarify that the framework guiding GOF research funding decisions was actually created under Trump just two years shy of the pandemic.
The role Trump's own administration played in this 2017 policy is actually relevant to several pending 2025 policies:
- Legislation aimed at GOF research funding. Marshall's Senate bill cites safety concerns and a lack of transparency and oversight. However, new funding policy plans were announced last summer, and are set to replace the old 2017 policy by May 2025.
- Kratsios' science advisor nomination
- Trump's own plans for an executive order banning GOF research, which have been publicly praised by the Heritage Foundation
- The Trump administration's announcement threatening to remove Moderna's federal funding for the development of an mRNA bird flu vaccine
Here is a timeline some of the events this post will cover: The post is broken down into 5 sections including the current introduction. The main focus of this post is GOF policy, and will be covered in sections 2 and 3. Sections 4 and 5 will be covered in more detail in two individual follow up posts.
- Introduction
- Gain of Function
- HHS Framework
- House Oversight Subcommittee Hearings
- Vaccine Privatization and Shareholdings
The second section will focus on the 2014 NIH GOF research funding pause and background. This led to the creation of recommended policy guidelines for the care and oversight for pathogens with pandemic potential (P3CO).
The third section will cover what the Trump administration chose to include or omit while using the Obama recommendations to create their own 2017 HHS framework. This framework lifted the NIH funding pause.
The fourth section covers last summer's COVID-19 Select Subcommitee hearings and focused on NIH funding for GOF research.
The fifth section will briefly examine why privatization of vaccine research would be of great financial interest to pharmaceutical companies, shareholders, and members of the Trump administration. This section includes the current legal battle between Pfizer and Moderna for the use of mRNA vaccine technology, a provisional approval for a bird flu vaccine granted to a Pfizer subsidiary, and a dinner anti-vax HHS secretary RFK had with the CEO of Pfizer prior to his Senate confirmation.
I'm not a virologist, but I'll do my best to explain terminology and techniques involved in some of these events. All of my sources can be found at the bottom of this post, and I will gladly acknowledge and correct anything that I may have misunderstood.
Gain-of-Function
Obama's Deliberative Process and the NIH Funding Pause (2014-2017)
The HHS policy framework released under Trump was the final step in a series of science policy decisions which began under the previous administration's OSTP to ensure the risks inherently involved in certain types of biomedical research were addressed.
On October 16, 2014, the NIH released an official notice of funding pause for certain types of Gain-of-Function (GOF) research. The notice cites the deliberative process launched by Obama's OSTP, to re-evaluate risks and benefits associated with certain GOF experiments which have potential to increase pathogenicity of influenza, MERS, or SARS.
On January 9, 2017, Obama's OSTP released the recommended guidelines for Potential Pandemic Pathogen Care and Oversight (P3CO), just under two weeks before Trump began his first term as POTUS. The recommendations were based on information gathered during the three-year deliberative process that began in 2014.
Potential pandemic pathogens (PPPs) are bacteria, viruses and other microorganisms that have the potential to easily and uncontrollably spread throughout human populations. In addition to increased transmissibility, the ability to cause damage to the body, or virulence, of PPPs is also greater compared to the virulence of other pathogens. This also significantly increases the risk of mortality in human populations compared to other pathogens. Examples of well known PPP would be H5N1 (avian/bird flu), SARS-CoV (SARS), and SARS-CoV-2 (COVID-19).
Genetic mutations of pathogens, especially viruses, are frequent occurrences in nature, and some mutations may enhance the ability of a virus to spread. For example, natural mutations that allow a virus to evade the body's immune system are what lead to variants, or new strains of a virus, spreading throughout a population. The ability of new variants to evade the immune system can make vaccines designed to protect against previously circulating variants less effective, and Obama's P3CO defines an enhanced PPP (ePPP) as a pathogen resulting from a mutation that produces enhanced transmissibility or virulence.
It's important to note that the original GOF funding pause was meant to apply only to experiments which involved the creation of new viruses that are more virulent or contagious. When the NIH first released the notice of pause to GOF funding in 2014, many virologists were concerned about the decision to use a fairly broad term like “gain-of-function” to describe the limited type of experiments and even smaller number of projects meant to be addressed by the funding notice.
Virology research often relies on experiments that alternate or manipulate selective genes of a virus to study a desired outcome, for example, alternating select genes to increase yields for vaccine strains.
However, any selection process involving the alteration of genotypes and their resulting phenotypes is by definition, GOF research. Even the production of newer mRNA vaccines requires GOF steps during production. However, unlike traditional vaccines, mRNA vaccines do not rely on an inactive or weakened virus for their creation. So while ePPP research is a type of GOF, most GOF research does not involve ePPP as defined by the recommended P3CO.
The recommendations for P3CO define clear exceptions to what is considered ePPP. These are not exceptions for the safety requirements necessary for conducting virology research, but exceptions for considerations that should be made regarding funding decisions.
For example, if the goal of a GOF project is to study a virus already circulating in nature and create a vaccine, there is a clear life saving benefit that outweighs the risk of the GOF research. On the other hand, if a project relies on GOF research to study how predicted mutations may arise and infect new species, creation of a new pathogen for this purpose would be considered ePPP, because the benefit of studying predicted mutations is not as clear as the risk involved in creating a pathogen with the mutations.
However, there may be compelling arguments for cases where ePPP research risk might be outweighed by public health benefit. If a pandemic was believed to be imminent, studying predicted mutations of a variant circulating in one species before it mutates to humans, for instance, this very moment in history, would enable the creation of a vaccine.
Bird Flu is increasingly circulating in livestock, and has already infected several humans working closely with animals. While hospitalizations and at least one death from animal to human transmission have occured, as of now, there have not been any reported cases of human to human transmission. However, the question seems to be not "if" we will see human to human transmission of bird flu, but "when?" Developing a vaccine in preparation of this mutation before it is circulating in humans could save countless lives in the very near future.
There is no doubt this research carries risk, and requires strict safety and oversight, but with the COVID pandemic still so fresh in human memory, it's hard to ignore how different the world might look today if a vaccine had been made available for wide scale distribution before the pandemic began.*
*(This is already a long post, and I want to try to keep things focused on GOF policy. However, vaccine roll-out, access, and affordability is an issue I will cover in more detail in a follow up post)
The idea of a "100 year pandemic" is often used to explain how pandemics occur in human populations. This has never been meant to suggest that literally every 100 years a pandemic is guaranteed, as though disease suddenly gains sentience, and extracts it's revenge before going back into hibernation. It's meant to relate how emerging disease is often seen following large scale change in human populations.
For example, many aspects of daily life in a developed country would look very different if you compared 1825 to 1925 and then 1925 to 2025, simply because of changes in technology, increased global communication, and shifts in human migration. These changes often result in increases in pathogen transmission due to novel environments and ecosystems unfamiliar to a developed immune system.
Climate change is also associated with changes in ecosystems that have proceeded changes in pathogen transmission, and many biologists have warned as we continue to see more frequent large scale impacts of climate change, the "100 year" pandemic window could shorten considerably.
Given that mRNA vaccines can also be updated relatively quickly compared to older vaccine development methods, this may have been an important consideration of the Biden administration when granting the funding to Moderna. In the HHS statement regarding Moderna funding, Biden's Assistant Secretary for Preparedness and Response said "mRNA technology will complement existing vaccine technology, allowing us to move faster and better target emerging viruses to protect Americans’ against future pandemics."
To secure funding for anything that classifies as ePPP research, researchers seeking funding would be required to complete an additional review process to prove that the project is justified by compelling public health need. While the increasing threat of bird flu might actually be a convincing enough justification, mRNA vaccine technology may completely negate the need to create an ePPP before the mutation has emerged in nature.
mRNA vaccines can teach the immune system to recognize and respond to a single piece of a viral protein rather than a weakened or inactive pathogen. Because the spike protein of COVID-19 is a feature found in all coronaviruses, mRNA vaccine design exploited this feature, using the spike protein as the piece of the virus that would trigger the immune system.
"Promising strategy for developing mRNA-based universal influenza virus vaccine for human population, poultry, and pigs– focus on the bigger picture," is a fantastic review article written in 2022, by Rcheulishvili et al. It explains how a similar strategy could be used to create a universal flu vaccine which could be used across species to prevent future flu pandemics, such as bird flu.
I'll do my best to explain some of the information, but the NIH has made this information free and publicly available for a reason. It summarizes what has been accomplished from decades of research (most of it publicly funded), and how all of this information may hold the key to saving humans and animals from future pandemics.
I highly encourage everyone to use the link in the references and give the article a view, if only to see the staggering amount of hard work, ingenuity, and collaboration that has allowed us to achieve this technology (hint, hint, it was not due to the innovation of any technocratic elite, or even due to someone purchasing the work, or giant corporations cutting red tape to make the research more efficient).
Similar to the spike protein shared by coronaviruses, influenza viruses share several common features, as shown in the image below. While influenza A virus circulates in both animals and humans, influenza B only circulates among humans. However, exploitation of the common features could allow the creation of an mRNA universal flu vaccine.
This same review provides a timeline of how different flu strains have emerged since 1918 as mutations and created endemic outbreaks. The timeline shows why the threat of a bird flu pandemic in humans has always been a question of "when?" not "if?"
The knowledge provided by decades of research is exactly why virologists continue to do sometimes risky, but incredibly important, research to monitor circulating strains and study how mutations may arise to create new pandemics.
When P3CO was released under Obama in 2017, there was no knowledge that in less than a decade there would be an abundance of clinical evidence supporting mRNA vaccine technology due to a pandemic. What was known was that the future of public health, would depend on finding a balance that allowed support to scientists to continue to study some of the greatest disease threats to humanity, while ensuring there were safety oversight and transparency measures in place. This is why the deliberative process began in 2014, and why the P3CO provided recommendations on how to achieve that balance was released 3 years later.
Here is an archived summary statement the Obama White House provided for P3CO when it was released: https://obamawhitehouse.archives.gov/blog/2017/01/09/recommended-policy-guidance-potential-pandemic-pathogen-care-and-oversight
The summary states "Policy development in this important area of research will be ongoing. OSTP and HHS will continue to examine implementation of the policies and procedures that are developed to provide oversight of enhanced PPP, and they will continue to engage the public along the way."
Obama provided these recommendations hoping that the incoming administration would take into consideration all of the evidence carefully gathered during the 3 years of the deliberative process, and use it to make their own policy. The next section will cover the policy framework created by Trump's administration in December of 2017, and what the authors of the framework chose to include or omit.
Trump HHS Framework
NIH Funding Pause Lifted (2017)
On December 19, 2017, eleven months after Obama released P3CO, the NIH released another official notice announcing that the funding pause for GOF research was being lifted. This notice cites HHS Framework for Guiding Funding Decisions for Research Involving Enhanced Potential Pandemic Pathogens (HHS P3CO Framework) issued under Trump's administration in December 2017.
Oddly, as of February, the Trump HHS framework provided was not available using the link in the NIH notice. Instead, it redirected to a forbidden 403 webpage for the HHR agency Administration for Strategic Preparedness and Response (ASPR)
However, I was able to retrieve the original framework released in December of 2017 via archive.org. Screenshots of the full PDF are included below:
Much of the framework seems to be abbreviated from information contained in the original Obama P3CO.
Section I states that the HHS framework is intended to provide guidance on HHS funding decisions for proposed research reasonably anticipated to create, transfer, or use enhanced PPPs.
Section II of the framework keeps the original definitions of an enhanced pathogen, as well as the same exceptions for naturally occurring enhanced pathogens obtained from nature, and those created during vaccine development.
Similar to section 2.6 of the original P3CO, section IIE of the HHS framework states that a pathogen previously considered to be a PPP should no longer be considered so if HHS and White House OSTP in consultation with Departments of Defense, Agriculture, and Justice, generally acting through the FBI jointly agree on the basis of additional information indicating the risks or benefits of the pathogen outlined in the framework is no longer appropriate. However, it may be worth noting the HHS framework removes a sentence indicating the outcome of the decision should be made transparent to other agencies and the public.
The rest of the framework laid out by HHS under Trump is nearly identical to recommendations provided by Obama's P3CO all the way through section section 4. While there appears to be nothing in the HHS framework conflicting with any P3CO recommendations, the information omitted from the HHS framework is what really stands out when comparing the documents.
Obama's P3CO section 5 details risk mitigation and project oversight while section 6 provides suggestions for reporting ePPP project funding to the public. Why are there are no similar sections in the HHS framework?
Section 5 of the original P3CO suggests funding oversight that draws from, but is not limited to a list of policy items adapted from the U.S. Government Policy for the Oversight of Life Sciences Dual Use Research of Concern (DURC). DURC includes life sciences research that could be misused to pose a significant threat with broad potential consequences.
The "lack of oversight," into "dangerous" GOF research is the entire justification for Marshall's Senate bill and Trump's proposed EO, but Trump's own administration was responsible for failing to integrate the recommended DURC policy or any alternative oversight policy into the framework for federal funding decisions.
Last summer the NIH was repeatedly attacked by Republican members of the House Oversight COVID-19 Select Subcommitee for their alleged lack of transparency, indicating public trust is something these Republicans greatly value. So why has Trump's own role in creating this policy been ignored?
In May of 2024, the NIH announced it would be updating the 7-year old policy for federally funded GOF studies, and overhauling rules for dual use pathogens. The announcement to tighten federal oversight came in response to the concerns regarding funding subcontracted to the Wuhan Institute of Virology (WIV) during a collaboration with NIH funded nonprofit EcoHealth Alliance.
Concerns about this collaboration were the focus of the Oversight subcommittee investigations, hearings, and calls for public testimony led by House Republicans.
Given Trump's direct involvement creating the current policy, why are accusations about the lack of oversight and transparency being directed at Biden?
The originals recommendations on reporting ePPP research (which were also omitted from Trump's framework) state that any agency decisions to fund an ePPP project should be reported to the director of OSTP, and OSTP should then share this information when applicable among other agencies to promote transparency. Trump's current nominee for Science Advisor was the acting director of OSTP when the HHS framework was created.
The original P3CO recommendations were made publicly available 11 months prior to the HHS framework for the incoming administration. The office Kratsios served as deputy director and the role he served as acting director, are repeatedly mentioned throughout the original P3CO document. How can Republican senators confirm his nomination to serve as Trump's science advisor when the policy being vilified in the Senate and by Trump's own EO for it's lack of safety oversight and public transparency, was put into place under Kratsios' OSTP leadership?
House Oversight COVID-19 Select Subcommittee Hearings
(2022-2024)
In December of 2024, the U.S. House Oversight COVID-19 Select Subcommittee concluded a two year investigation led by House Republicans. Although the subcommitee was originally formed in 2020 to create oversight for Trump during the COVID-19 pandemic, it was redirected after Republicans gained control of the House to focus on mask and vaccine mandates, GOF research, and the origins of COVID.
During the investigation, evidence was presented which subcommittee members claim exposed high-level corruption in America’s public health system, and implied the committee had proven a lab leak was responsible for the origin of COVID.
I am planning a follow up post that focuses on these investigations, COVID origin theories, and the lab leak theory in more detail, but it is important to note that there has never been any evidence proving the virus escaped from a lab. Using this language to wrap up oversight committee investigations while claiming the investigations were necessary to re-gain public trust is reprehensible and extremely dishonest.
Last summer, the committee requested an investigation into the NIH funds provided to Peter Daszak, a scientist with the nonprofit EcoHealth Alliance who received funding while collaborating with the Wuhan Institute of Virology (WIV) to study coronaviruses in bats. Daszak and several members of the NIH were asked to provided testimony about the investigations.
•April 2020: After a feud begins between Trump and China regarding the origins of COVID, the Trump administration demanded the NIH terminate Daszak's grant.
•2020: Scientists call the politicized cancellation unfair and demand an investigation.
•May 2023: NIH determines the grant was cancelled without justification and renews Daszak's grant at a reduced amount
•May 2024: Select subcommitee hearings target Daszak and NIH funding. Daszak maintains his research did not meet the definition of risky GOF research
•Evidence is presented during the hearings that WIV was late submitting a progress report and did not hand over lab notebooks in a timely manner
•May 7th NIH announces they are updating 2017 policy and tightening GOF oversight
•May 15 HHS cancels all funding for Daszak
•May 16: Confusion over definition of GOF research leads subcommittee to suggest testimony of NIH Deputy Director Lawrence Tabak contradicts previous testimony Anthony Fauci provided, when he said the NIH did not find GOF research.
As noted in the second section of this post, the NIH notice of funding pause originally used the term GOF, but it was in specific regard to pathogens with enhanced pandemic potential (ePPP), which was clarified by the Obama 2017 P3CO. While ePPP research is a type of GOF research, most GOF research does not involve ePPP. It seems as though Fauci and Tabak were using different, but both accurate definitions for the same term.
Here is a partial transcript of the testimony given by Tabak:
Rep. Lesko: “Dr. Tabak, did NIH fund gain-of-function research at the Wuhan Institute of Virology through EcoHealth?”
Dr. Tabak: “It depends on your definition of gain-of-function research. If you’re speaking about the generic term, yes, we did…the generic term is research that goes on in many, many labs around the country. It is not regulated. And the reason it’s not regulated is it poses no threat or harm to anybody.”
Subcommitee members claimed this contradiction in testimony was evidence that Fauci intentionally misled the American public. These accusations may explain why Biden granted Fauci a pardon backdated to 2014 (the date when the initial NIH pause to GOF was released), and why a letter sent to Speaker Mike Johnson in February indicates Attorneys General in multiple red states are hoping to investigate state crimes they could hold Fauci accountable for based on the allegedly misleading testimony.
•May 17: Subcommittee concludes federal grant procedures are in need of serious reform
The audit of Daszak's funding from 2014-2021 by an inspector general did not find any evidence that Daszak's collaboration with WIV resulted in the creation of any dangerous pathogens.
However, it did raise concerns regarding late submission of progress reports, lab notebooks, and the substandard safety levels of the WIV lab.
The final conclusion from these hearings is that the WIV failed to meet the "utmost standards of transparency and accountability," and that "NIH’s procedures for funding and overseeing potentially dangerous research are deficient, unreliable, and pose a serious threat to both public health and national security."
Senator Marshall first proposed his GOF research moratorium bill in June following these hearings before Trump announced his own plans for an EO to halt federal funding for GOF research shortly after taking office for his second term. The Heritage Foundation publicly backed the proposed EO in February, stating that Trump is right to take urgent action, and citing risks to public health due to substandard safety conditions in labs and threats to national security.
The article posted on the Heritage Foundation's website is titled, "President Trump Should Reinstate President Obama's Moratorium on Risky Biological Research." Kind of hard to argue with that bipartisan logic, right? Except that it completely ignores the fact that Trump's EO is:
- In response to policy framework created by his own administration in 2017
- Issued to allegedly address concerns about safety. However, the policy concerns are already set to be updated by May 2025 by the federal agencies Trump is trying to actively dismantle.
- Likely to end all publicly funded vaccine research, resulting in complete privatization of vaccine research
Vaccine Privatization and Shareholders
Who really benefits from these legislative moves? Hint: It's not the public.
Security and safety concerns are frequently cited as the motivation to end federal funding for GOF research, but privatization of this research would actually result in the removal of any oversight or public transparency. Some of the U.S. federal agencies the Trump administration is dismantling, such as the NIH, CDC, and OSHA, create and work together to enforce the safety standards which were not present in the labs at WIV.
Extending P3CO beyond Federal Funding is actually the focus of section 8 of Obama's P3CO. This section suggests creating safety measures that can be applied and enforced to all federally funded research. The recommendations would have also included any subcontracted labs such as the WIV. Further, the recommendations suggest OSTP and other agencies look into ways to extend these measures and suggests oversight and accountability should eventually be established for any company or corporation conducting this research in the U.S.
Anyone who is truly concerned about the biosafety and security risks inherent to this research should be questioning why Trump's 2017 administration failed to include any oversight and reporting mechanisms in the HHS framework.
Attempts to dismantle the Federal agencies that work together to create and enforce safety and oversight for this research while trying to pass legislation that allows only private companies to conduct the research seems to be in complete contradiction to any concerns for health and safety of the American public.
In other words, a moratorium on all federally funded virology and vaccine research under the guise of safety concerns seems to be a blatant abuse of power. While it's impossible to say what the motivation behind such a move would be, it is worth noting that at this moment, privatization of vaccine research would seem to be of the greatest benefit to pharmaceutical companies and their shareholders.
Moderna has actually been in a legal battle with other pharmaceutical companies, including their main competitor, Pfizer, for mRNA vaccine technology patent rights. Interestingly, during hearings for RFK's HHS secretary nomination, the CEO of Pfizer mentioned having recently had dinner with RFK while he was on an earnings call with shareholders.
More detail will be covered in a followup posts, but as a preview I want to end with some potentially important pieces of information that didn't get a lot of attention when released by the press. Probably because on their own they might not seem relevant, but taken with all of the information in this post, it's kind of hard to just pretend there's zero connection.
•On Febuary 14, shortly before the threat to pull Moderna funding was announced, Trump's HHS granted a provisionary approval for a bird flu vaccine in livestock to Zoetis, the veterinarian pharmaceutical company.
•Moderna received funding from HHS under the Biden administration, 3 days before Trump took office. The funding was awarded to Moderna for the creation of a human mRNA bird flu vaccine, based on the strains currently circulating in livestock.
•The 2022 review article, "Promising strategy for developing mRNA-based universal influenza virus vaccine for human population, poultry, and pigs– focus on the bigger picture," explains a research strategy to create an mRNA universal flu vaccine based on a feature of the viral protein that is conserved across species.
Using this strategy, mRNA vaccines technology could be used to create a universal vaccine for animals and humans. That would mean that the Zoetis vaccine, which received provisionary approval, could be used as a vaccine in both humans and livestock.
•Moderna and Pfizer have been battling for legal patent rights to mRNA vaccine technology (which would be necessary to create the vaccine) in U.S. and German courts.
•Although RFK has become famous for his strong anti-vax ideology, the CEO of Pfizer announced on an earnings call in early February, that he had recently had dinner with RFK. The call took place while RFK's confirmation hearings were still on going, and the CEO is quoted as saying:
"I focus more not on the things that we clearly disagree, like the vaccines, but on the things that we can agree and we can do things together… I’m cautiously optimistic.”
•While Veterinarian Pharmaceutical company Zoetis now claims to be a fully independent company, it was originally a Pfizer spinoff and subsidiary.
•This last point is just something odd I noticed, but feel the need to include here. I'm by no means a stock market expert, so this may just be me seeing something where there is nothing.
On the day Zoetis made the official announcement of receiving HHS provisional approval for their bird flu vaccine in livestock, their share value appears to have already been in a downward slope from some kind of drop just before the announcement. Pfizer shares were also down, but in a more gradual pattern rather than a sudden drop.
What's odd is that shares of the two independent vaccine makers would gradually recover, and eventually peak on Febuary 25th, while shares of a third vaccine maker would fall 5.5% during after-market hours, only to make headline news the morning of Febuary 26th.
Like I said, I don't know anything about stocks. I just enjoy researching an interesting pattern. The only reason I noticed this stock market pattern was because of a news headline that caught my attention on Febuary 26th, which happened to mention shares of the third company falling.
That headline sent me down an entire series of rabbit holes. One of which led me to discover a Republican Senator also released a bill aimed at removing funding for vaccine research on February 26th. This led me to learn about the funding policy behind the vaccine research. Which then led me to learn about the policy framework guiding funding for vaccine research. Which then led me to discover that on Febuary 25th, Senate hearings began for the president's director of science policy. I then discovered that the nominee had also been acting director of science policy at the time the policy framework guiding federal funding was written.
From there it gets a little complicated, but over two weeks later it led me to finally put all of this information together and allowed me to end this post where it began.
References
•Trump 2025 Moderna funding
https://www.reuters.com/business/healthcare-pharmaceuticals/trump-administration-weighs-pulling-funding-moderna-bird-flu-vaccine-bloomberg-2025-02-27/
https://www.axios.com/2025/02/27/moderna-bird-flu-vaccine-funding-review
•Biden Moderna funding
https://www.cidrap.umn.edu/avian-influenza-bird-flu/hhs-awards-590-million-moderna-develop-mrna-vaccines-against-pandemic-flu
•Trump W.H.O. Withdrawal
https://www.whitehouse.gov/presidential-actions/2025/01/withdrawing-the-united-states-from-the-worldhealth-organization/
•Marshall's GOF Senate Bill https://www.marshall.senate.gov/newsroom/press-releases/senator-marshall-again-calls-for-the-immediate-halt-of-deadly-gain-of-function-research/
•Trump GOF EO and Heritage Foundation support
https://www.wsj.com/health/trump-administration-seeks-to-stop-virus-research-republicans-have-blamed-for-covid-19-pandemic-337cec1b
https://www.heritage.org/public-health/commentary/president-trump-should-reinstate-president-obamas-moratorium-risky
•Kratsios acting director and Senate hearings
2017:https://www.statnews.com/2017/08/07/white-house-ostp-obama-trump/
•Trump Breaks Science Advisor Record
https://climate.law.columbia.edu/content/cdc-public-health-position-eliminated
•NIH GOF/ePP
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-15-011.html
https://grants.nih.gov/grants/guide/notice-files/NOT-OD-17-071.html
•Planned policy updates to address concerns for GOF research
Max Kozlov
https://www.nih.gov/news-events/research-involving-potential-pandemic-pathogens
https://www.science.org/content/article/white-house-overhauls-rules-risky-pathogen-studies
•Strategy for universal Bird Flu mRNA vaccine for both animals and humans
Nino Rcheulishvili
•House COVID-19 subcommitee
https://oversight.house.gov/release/final-report-covid-select-concludes-2-year-investigation-issues-500-page-final-report-on-lessons-learned-and-the-path-forward/
https://oversight.house.gov/release/hearing-wrap-up-nih-repeatedly-refutes-ecohealth-alliance-president-dr-peter-daszaks-testimony-tabak-testimony-reveals-federal-grant-procedures-in-need-of-serious-reform/
•HHS IG report EcoHealth
https://oig.hhs.gov/reports/all/2023/the-national-institutes-of-health-and-ecohealth-alliance-did-not-effectively-monitor-awards-and-subawards-resulting-in-missed-opportunities-to-oversee-research-and-other-deficiencies/
•AG letter to Mike Johnson
https://1819news.com/news/item/marshall-16-ags-demand-anthony-fauci-be-held-accountable-for-covid-19-response
•Recent big pharma mRNA vaccines patent legal battle
https://www.fiercepharma.com/pharma/pfizer-biontech-notch-us-win-and-loss-germany-amid-high-stakes-patent-fight-moderna
•Zoetis provisional approval
https://news.zoetis.com/press-releases/press-release-details/2025/Zoetis-Receives-Conditional-License-from-USDA-for-Avian-Influenza-Vaccine-H5N2-Subtype-Killed-Virus/default.aspx
•RFK Pfizer CEO dinner
https://fortune.com/well/2025/02/04/pfizer-ceo-had-dinner-with-rfk-jr-cautiously-optimistic-despite-vaccine-controversy/
•History of Pfizer and Zoetis subsidiary
https://www.lifescienceleader.com/doc/how-pfizer-and-zoetis-launched-one-of-the-most-successful-spinoffs-ever-0001
