Guns, Butter, and the Uniqueness of the FDA

As described in last week’s Analysis and Commentary, there are really only two ways to pay for a defense build-up: take the monies from non-defense programs (mandatory or discretionary) or (very unlikely) increase the federal deficit. Thus, we are likely into a “guns vs. butter” fight this year, with strong policymaker sentiment in both directions and most Members of Congress yearning for a way to avoid choosing. Congress thought it settled this question (through FY 2023) when it passed the Budget Control Act of 2011, creating a decade’s worth of budget caps specific to defense and non-defense spending. While the Alliance will not be taking sides in this larger battle, the downward pressure on all non-defense programs will be enormous. There is no question that FDA is at risk.What the President must decide -- in his budget outline (before mid-March), then reinforce or modify in the full budget request (late April-May) -- is into which of three buckets to assign every non-defense federal program. The first bucket will contain programs slated for larger cuts based on policy or ideology. EPA is clearly going to be in this bucket, as will foreign aid programs and support for the arts and humanities. The second bucket will contain programs slated for an average cut (think 10-15%, probably across-the-board) in order to generate the monies necessary to pay for defense and for which the Administration sees no justification for giving special treatment. The bulk of federal programs will be in this second bucket.The third bucket will be a select group of programs for which the Administration will be advocating for a smaller cut, level funding, or possibly an increase. I anticipate this bucket will include the FBI, border security, veteran’s programs, and maybe air traffic controllers. Relative to the Trump Administration, the Alliance’s primary goal will be to advocate and show the justification for FDA being placed in this third bucket. This would not only benefit us in having a higher baseline in the President’s request, but would also send a strong message to Congress that FDA is a priority, whose portfolio of activities represent core functions of government.Getting into the third bucket is going to be a tough sell with a new Administration that hasn’t yet figured out what it thinks about FDA. Further, the process makes such advocacy almost impossible. The initial budget guidances were sent by OMB to departments only this week. It is unclear whether HHS is following the traditional pattern of sending allocations to agencies and entertaining appeals. Even if so, there will not be a lot of time for back-and-forth discussions with agencies, given the apparent time constraints (initial budget to Congress within 2 weeks of today). FDA’s fate in the Trump budget will truly be in HHS’s hands. While Congress will have the final say, it would be invaluable if the Administration would lead the way in recognizing FDA “exceptionalism.”Regardless of where Congress ultimately nets out on a defense increases vs. non-defense cuts, the environment for funding increases for non-defense programs is going to be difficult. We need to be steadfast in our message that individualized, policy-driven consideration of agency missions and responsibilities should be the key to appropriations, rather than across-the-board decisions. We hope the current process, Congressional and Executive Branch, will allow for this. If it does, we believe that FDA is a unique agency with unique responsibilities and can justify its current funding level or even the small increase that the Alliance is requesting.Editoral note: The Analysis and Commentary section is written by Steven Grossman, Deputy Executive Director of the Alliance for a Stronger FDA.