The President's Budget Request: Separating the Wheat from the Chaff

When the President’s Budget Request is released on February 12 (next Monday), it will be the twelfth time the Alliance will be doing an analysis of FDA’s prospects. Repetition does not make it much easier. There is always the chaos of 300 (or more) pages of text on FDA, along with dozens of charts, and countless numbers … and the imperative to make sense of it, pronto.What makes quick analysis so difficult is the complexity of the FDA budget request. NIH is more than six times larger than the FDA, but I would argue that the FDA request is easily six times more difficult to understand.It is guaranteed that OMB will make the FDA request sound much better than it really is.  For example, a claim of a $200 million increase may well mask a substantial decrease being proposed for FDA funding. This is not a partisan thing. Every year, OMB tries to put the President’s request in the best light.  As a result, the meaningful numbers are in the budget tables,* not in the summaries.The OMB “headline numbers” are an amalgamation of real numbers and legislative proposals for user fees that are not likely to become law. For example, in many recent years, the President has asked for food user fees that would replace BA dollars. Typically, a billion dollars for food safety (all BA dollars) might become a request for $800 million in BA and $250 million in proposed food user fees. OMB would say its proposal is a $50 million increase ... while we would say that it has the effect of a $200 million cut. Proposed user fees, no matter how OMB counts them, are not likely to turn into dollars that the agency can spend.Adding BA appropriations and user fees together also provides an inaccurate picture of the President’s budget request. User fee monies are collected for very specific purposes and, while very valuable to the agency, cannot be used to pay for new priorities and evolving needs. In addition, more than $650 million of the user fees are for the tobacco center and not available for FDA’s traditional responsibilities for safe foods and safe and effective medical products. (For an in-depth analysis of how tobacco fees distort the FDA’s budget, go to The FDA Budget for FY 18: Where Does the Money Come From?)So, Monday is a big day with powerful implications. Whether Congress accepts or rejects the President’s proposals, they will be used as a baseline when the subcommittees marks-up. With regard to federal departments and agencies, the President’s budget request is NOT dead on arrival.As soon as we have a firm grasp on what the President is proposing, we will be back to the Alliance membership with details.Editorial note: The Analysis and Commentary section is written by Steven Grossman, Deputy Executive Director of the Alliance for a Stronger FDA.--------* Once text of the President’s request and supporting justification become available, I immediately search for the All-Purpose Table and the Summary of Changes, then start comparing them to the Budget Authority Crosswalk and Budget Authority by Activity.