The Ninety-Day Window

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This issue is the companion to "The Memo Never Says 'Veteran,'" published this week. The public piece reads the governance gap. This one works the window: which of the six action plans to read first and what to look for in each, how the classification guidance inside HHS reshapes the applied-research market through FY2028, the verification category and who is already circling it, how to position when past performance is your main asset and the memo is routing around past performance, the DHA transition dates that open services-layer competition, and the three questions to put to a program office before October closes.

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1. The window at a glance

Field	Detail
Trigger	FY2028 R&D Priorities Memorandum (NSTM-5 / M-26-16), issued July 21, 2026
Signed by	Michael J. Kratsios (APST/OSTP) and Russell T. Vought (OMB)
Filed with	APST and the OMB Director
Threshold	Agencies with $3 billion or more in FY2026 budget authority for R&D
Deadline	~October 19, 2026 (90 days from July 21)
Required content	New funding opportunities, program solicitations, pilot initiatives, statements to the research community, internal organizational changes, each with timelines and responsible offices
Also required	How FY2026 and FY2027 budget execution supports the priority practices
Follow-on	Everything on budget formulation moves to FY2028 submissions to OMB, separately
Likely filers	Department of War, HHS (incl. NIH), Energy, NASA, NSF, Commerce (incl. NIST); Agriculture borderline at enacted levels
Below threshold	VA (~$1.86B), Transportation

Confidence: High on the trigger, the threshold, and the required content. All quoted from the memorandum's final page [CC1]. Medium on the filer list, which is assembled from CRS R&D-specific budget authority rather than from a published distribution list; the memo keys to enacted FY2026 authority and OSTP has not published who received it [CC2]. The October 19 date is arithmetic off "within 90 days," not a published milestone.

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2. Which plan to read first, and what to look for

These are not solicitations. They are the documents that pre-announce solicitations, and they will name responsible offices. Read in this order.

Energy, read first. Energy owns the Genesis Mission and the American Science and Security Platform, and the memo tells every agency to treat Genesis support as a central R&D priority [CC1]. Energy's plan is the only one that will describe the dataset assembly work at the level of specific holdings.

Look for: whether any biomedical or genomic dataset is named among assets being prepared for the American Science Cloud; whether VA-originated data appears; whether the plan describes a provenance or consent-scope step for human-subject data; and which office inside the Under Secretary for Science organization is named as responsible. That office is your point of entry for everything downstream.

HHS, read second. Read the classification guidance harder than the plan. See section 3.

Department of War, read third. The question is where health research sits once the portfolio tilts toward "national security-relevant research portfolios" [CC1]. DHP RDT&E is already dropping from $2.47 billion in FY2026 to just over $1 billion in FY2027 [CC3].

Look for: whether readiness is used as the argument that keeps medical research inside a national-security frame. If it is, that language is reusable in your FY2028 positioning. If DoW's plan treats health research as out of scope, that is a different market.

NSF, NASA, and Commerce: skim. Relevant for teaming and for X-Labs-style vehicles, less so for federal health.

Confidence: Medium-High. The reading order follows from the memo's own assignment of Genesis to Energy and from the classification requirement landing on HHS. Whether agencies publish these plans at all is genuinely uncertain: the memo requires submission to APST and OMB and says nothing about public release [CC1]. Plan for FOIA or for reconstruction from the FY2028 budget submissions.

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3. The HHS classification guidance is the document that matters

This is the highest-value item in this brief and the one with the longest tail.

The memorandum requires, verbatim: agencies "should note the R&D character classification of proposed activities as a percentage of their R&D funding portfolio and identify the specific programs through which the agency proposes to shift its portfolio toward earlier-stage work. Where agencies propose to significantly expand later-stage development activities, they should justify why such activities would not occur absent Federal support" [CC1].

Somebody inside HHS has to write the internal guidance that tells institutes how to code their work. That guidance is not the action plan and probably will not be attached to it.

Why it decides your market. The memo directs agencies to prioritize "foundational research in the biological sciences over the life sciences, a broader category not focused on foundational research," and lists what counts as favored biological science: molecular, cellular and structural biology; biochemistry and chemical biology; genetics, genomics, and synthetic and engineering biology; neuroscience; microbiology and quantitative biology [CC1].

Genomics is protected. The categories that carry most federal health IT services work are not on the list: health services research, implementation science, comparative effectiveness, clinical trial operations, deployment of tools into care delivery.

The positioning move. For anything you support that codes as later-stage, the memo itself tells you the required argument: why the activity "would not occur absent Federal support" [CC1]. That is a market-failure argument, and it has to be written before the coding happens, not after.

Three versions that hold up for federal health work:

• No commercial buyer exists. Deployment into VA or MHS operational environments has one customer. There is no private market that would fund integration into a government-only record platform.
• The population is not commercially attractive. Research in operational military populations, on deployment-related exposures, or in a beneficiary population under a closed benefit has no downstream commercial revenue to justify private investment.
• The output is a public good with no capture mechanism. Interoperability work, data standards, and verification tooling produce benefits that accrue to the government and to competitors alike.

Get those into your customer's hands as language they can lift, not as a white paper. The person writing the justification is under a deadline and did not ask for this assignment.

Confidence: High on the requirement. Medium on the market read. The classification requirement and the biological-sciences list are quoted from the memorandum [CC1]. Which HHS office writes the internal guidance, and on what timeline, is n.a., not published in any fetched source.

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4. The verification category, and who is already circling

The report devotes a full section to the argument that AI will generate scientific claims faster than anyone can check them, and calls for a "verifier equal in rigor and scale" [CC4]. It puts a number on the health-side damage: irreproducible findings in preclinical biomedical research alone misdirect an estimated $28 billion annually [CC4].

The recommended build: machine-auditable replication packages, open standards and APIs that plug into journal submission systems and grant reporting platforms, continuous replication mechanisms, and prizes for replicating or disproving influential results [CC4].

Demand-side evidence that this is real, not aspirational:

Instrument	Status
NIH Replication and Reproducibility Initiative	Agency-wide, active [CC5]
NIH central resource page	Live February 5, 2026 [CC5]
NIH Common Fund replication initiative	Funds researcher–CRO partnerships to replicate preclinical and translational studies [CC5]
NIH Replication Prize	$850,000 purse with the NASA Tournament Lab; winners announced May 2026 [CC5]
Gold Standard Science EO	Signed May 23, 2025; nine tenets including reproducibility, transparency, falsifiability [CC6]

Who is already positioned. Contract research organizations with replication service lines, from the NIH Common Fund structure. Research-integrity and data-provenance tooling vendors. The scientific publishing infrastructure companies, because the report explicitly names journal submission systems as an integration target. None of those is a traditional federal health IT prime, which is the opening.

Where a federal health services firm has a genuine claim. The gap in that list is audit trails for AI-generated research inside a FedRAMP boundary, on data that cannot leave a government enclave. If you already hold ATOs in a health environment and run compliance monitoring, that is a closer adjacency than it looks.

The honest risk. The Gold Standard framework driving this demand is contested. Brian Nosek of the Center for Open Science argued the order inserts a political process into how scientific evidence is understood and used; more than 6,000 scientists signed an open letter on the autonomy of scientific inquiry; the objection centers on the provision making a senior political appointee the arbiter of integrity violations [CC7]. A category built on a contested executive order carries reversal risk across an administration change. Price the pipeline accordingly and avoid building a practice that only works if the EO survives.

Confidence: High on the report language and the NIH instruments. Medium on the market sizing, which is an inference from stated demand rather than from any published procurement forecast. No solicitation for verification tooling has been identified. Dollar figures for this category: n.a.

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5. Positioning when the memo routes around past performance

The memo pushes five mechanisms that reduce the weight of a proposal library.

Mechanism	Memo language	What it changes
Fast grants	"flexible, low-friction," "rapid review timelines of under one month" [CC1]	A few pages, decided in weeks
Golden tickets	"let individual agency technical reviewers recommend unconventional proposals" [CC1]	One reviewer can advance what a panel would reject
Regranting	"delegate funding authority to working scientists" [CC1]	Decisions move outside the agency
Long-duration awards	"lasting five years or more," funded fully in year one [CC1]	Fewer, larger, stickier
Prizes	"at least a 3:1 leverage of private to Federal investment" [CC1]	Pay for results; you carry the risk

The report's stated target: the U.S. research system "should prioritize the individual scientist over legacy institutions" [CC4].

The 3:1 line is the one to underline. The memo directs that "Prizes should target at least a 3:1 leverage of private to Federal investment," and may be paired with advance procurement commitments, regulatory fast-tracking, and access to Federal testing facilities [CC1]. Read plainly, that means agencies will favor teams arriving with matching private capital. A services firm with no balance sheet for cost share is disadvantaged in exactly the mechanisms being expanded.

The cost-share directive reinforces it. Agencies are told to "review existing authorities for cost-shared R&D, including cooperative agreements, public-private partnerships, consortia models, and other transaction authorities where applicable, and propose expansions where statutory or regulatory barriers can be addressed" [CC1].

Three practical positions:

Bring a partner with capital, not a teammate with a capability. The differentiator in a 3:1 environment is who is standing next to you with money. That is a different partnering conversation than the one most capture teams are having, and it should start now rather than at solicitation.

Consortium membership is the cheapest hedge available. Consortium-based OTAs accounted for roughly half of DoW prototype OTA obligations FY2021 through FY2024, and nontraditional contractors make up 80 to 85 percent of membership in the large consortia [CC8]. Membership is inexpensive relative to a bid and it puts you inside the channel the memo is expanding.

Do not treat an OTA prototype as a production path. GAO found most selected prototype OTA efforts planned to transition to traditional FAR contracts for production rather than continuing on the OTA [CC8]. Plan the transition competition as the value-capture event and staff for it from the start.

SBIR context: authority lapsed roughly six months from October 1, 2025 and was reauthorized through FY2031 as of April 14, 2026 [CC9]. The report directs agencies to focus SBIR and STTR "to build strategic capabilities" [CC4], which reads as topic concentration toward AI-for-science, quantum, and critical technology rather than broad topic diversity.

Confidence: High on the mechanism language and the GAO transition finding. Medium on the partnering read.

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6. DHA services-layer competition as the integrator role ends

Separate from the memo, and on its own clock.

Milestone	Date
Philips and Amwell off Leidos management	End of July 2026
Oracle Health transitions	November 2026
Henry Schein and Solventum transition	By July 2027
Healthcare Management System Modernization line, FY2027 request	No funds [CC3]

DHA plans to end Leidos's role as lead systems integrator and award five sole-source, firm-fixed-price, outcome-based contracts directly to the technology providers, bringing integration in-house [CC10].

The capture read. Platform contracts go sole-source to the named providers. The integration function moves to the government. What that creates is a services layer around an integrator that is now a government program office rather than a prime, on a program that has moved from modernization into sustainment and optimization across nearly 10 million beneficiaries [CC10].

Work to position against, in the order the transitions land: integration engineering support to the government integrator; interface and data-exchange work between the five platforms; sustainment and optimization task work; and testing and cutover support at each transition date.

The genomics adjacency. VA's own documentation identifies the root cause of its pharmacogenomic result problem as a lack of interoperability between its electronic health record and the reference laboratory, with results moving as PDF files [CC11]. That is an interface problem in a program that is standing up in-house integration on the DoW side and gating funds on the VA side. If the FY2028 direction is to prepare federal datasets for AI, the data has to be computable first, and it currently is not.

Confidence: High on the transition dates and the contract structure [CC10]. Medium on the services-layer projection, which is an inference from the announced acquisition approach rather than from any posted requirement. No solicitation has been identified for the services layer. Watch for a sources-sought or RFI ahead of the November Oracle Health transition.

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7. Three questions to put to a program office before October closes

Use these in a capability briefing or an industry day, not in writing to a contracting officer during an active procurement. Each is designed to produce information you cannot get from a document.

1. "Is your organization filing an action plan, and which office is drafting it?"

The threshold is at the department level, so a program office inside HHS or DoW may not know whether it is contributing. The answer tells you where the pipeline document is being assembled and whether your customer has visibility into it. If the answer is that they are not involved, that is useful: it means their FY2028 programs are being characterized by someone else.

2. "How is your portfolio being classified against the earlier-stage shift, and who is writing the justifications?"

This is the question with the longest tail. If the program office is writing its own market-failure justifications, you can help shape them. If classification is happening above them, your customer is about to be described in language they did not choose, and they will want to know that before October rather than after.

3. "For any dataset you steward, has anyone asked you about provenance or consent scope for AI preparation?"

Neutral, answerable, and it surfaces whether the governance question in this week's public issue has reached the working level. A "no" is intelligence. It also positions you as the firm that raised it before it became a finding.

What not to ask. Do not ask which vendors they are considering, do not ask for the plan itself, and do not ask anything that presumes a procurement exists. None of these plans is a solicitation and treating them as one will close the door.

Confidence: Medium. These are constructed from the memo's requirements, not from any published engagement guidance. Your own organization's rules on communications with government personnel govern, and they govern over anything in this brief.

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8. What would change this read

Four things, in order of impact:

Agency plans are not published. The memo requires submission to APST and OMB and is silent on public release [CC1]. If nothing surfaces in late October, the reconstruction path is the FY2028 budget submissions, which arrive months later and carry less operational detail.

VA files voluntarily. Nothing prevents it, and it would put the data steward's terms into the record alongside the compute agencies. If VA files, the governance question moves from open to contested, which is a better position than open.

The classification guidance leaks or is published. That single document is worth more than all six action plans for anyone selling applied health research support.

An administration change. The verification category, the Gold Standard framework, and the physical-sciences tilt are all executive-branch direction rather than statute. Congress restored the NIH topline in FY2026 and blocked the indirect-cost cap in court [CC12]. Direction set by memorandum can be reversed by memorandum.

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Mary

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Sources

[CC1] White House, Fiscal Year 2028 Administration Research and Development Budget Priorities Memorandum (NSTM-5 / M-26-16), Kratsios and Vought, July 21, 2026, issued as an annex to Science: A New Golden Age at printed pages 85–104. All quoted language in sections 1, 3, and 5 verified against the report PDF: the 90-day trigger and $3 billion threshold; required action-plan contents; R&D character classification and the "would not occur absent Federal support" justification; "biological sciences over the life sciences"; the favored biological-sciences list; fast grants ("flexible, low-friction," "rapid review timelines of under one month"); golden tickets; regranting; long-duration awards "lasting five years or more"; "Prizes should target at least a 3:1 leverage of private to Federal investment"; the paired-incentive language; and the cost-shared R&D review directive. https://www.whitehouse.gov/wp-content/uploads/2026/07/White-House-Fiscal-Year-2028-RD-Priorities-Memorandum.pdf

[CC2] Congressional Research Service, R48694, "Federal Research and Development Funding: FY2026," December 2025 (agency R&D budget authority; five agencies account for approximately 92 percent of federal R&D; VA R&D approximately $1.86 billion). The memo keys the threshold to enacted FY2026 authority rather than the request; the filer list here is constructed from CRS figures, not from a published distribution list. https://www.congress.gov/crs_external_products/R/PDF/R48694/R48694.9.pdf

[CC3] Federal News Network, "DoD Seeks to Split Defense Health Program into Two Accounts in Fiscal 2027," April 2026 (RDT&E just over $1 billion versus $2.47 billion in FY2026; Healthcare Management System Modernization unfunded in the FY2027 request). https://federalnewsnetwork.com/budget/2026/04/dod-seeks-to-split-defense-health-program-into-two-accounts-in-fiscal-2027/ · Military Health System FY2027 J-Book Vol. 1 (COMP/PSCP), Office of the Under Secretary of War (Comptroller). https://comptroller.war.gov/Portals/45/Documents/defbudget/FY2027/budget_justification/pdfs/09_Military_Health_System/MHS_PB27_J-Book-Vol1-COMP_PSCP.pdf

[CC4] Office of Science and Technology Policy, Science: A New Golden Age, July 2026, Chapter V ("a verifier equal in rigor and scale"; $28 billion in misdirected preclinical biomedical research; machine-auditable replication packages; journal submission and grant reporting integration) and the report's goals section ("prioritize the individual scientist over legacy institutions"; SBIR/STTR "to build strategic capabilities"; "further leverage Other Transaction Authority"). https://www.whitehouse.gov/wp-content/uploads/2026/07/Science-A-New-Golden-Age.pdf

[CC5] NIH Extramural Nexus, "NIH Launches New Central Resource to Support Replication and Reproducibility," February 5, 2026; NIH Common Fund, "Replication to Enhance Research Impact Initiative" and Replication Prize ($850,000 purse with the NASA Tournament Lab). https://commonfund.nih.gov/replication-initiative

[CC6] Executive Order 14303, "Restoring Gold Standard Science," May 23, 2025. https://www.whitehouse.gov/presidential-actions/2025/05/restoring-gold-standard-science/

[CC7] Chemical & Engineering News (Brian Nosek, Center for Open Science). https://cen.acs.org/policy/Gold-Standard-Science-lead-discarding/103/web/2025/05 · New York Times, June 3, 2025 (open letter signed by more than 6,000 scientists). https://www.nytimes.com/2025/06/03/climate/executive-order-gold-standard-science.html · Science (AAAS), McNutt editorial locating the objection in the enforcement mechanism rather than the treatment of rigor. https://www.science.org/doi/10.1126/science.adz9562

[CC8] GAO-25-107546, September 2025 (OTA obligations growth; consortium-based OTAs approximately half of DoD prototype OTA obligations FY2021–FY2024; nontraditional contractor membership 80–85 percent in selected consortia; most selected prototype OTA efforts planned transition to FAR contracts for production). https://arpa-h.gov/sites/default/files/2025-09/GAOReport_Improved_Contracting_Data_Helps_Assess_Effectiveness_Sep2025.pdf

[CC9] SBIR/STTR authority lapsed October 1, 2025; S. 3971 reauthorized the programs through FY2031, signed April 14, 2026. Minnesota SBIR reauthorization update. Secondary source; confirm against the enacted statute before relying on the FY2031 date in a proposal. https://minnesotasbir.org/news/sbir-sttr-reauthorization-update-2025/

[CC10] Washington Technology, "How DHA Plans to End Leidos' Run as the Military's Health Record Integrator," June 12, 2026 (full deployment and sustainment across nearly 10 million beneficiaries; five sole-source firm-fixed-price outcome-based contracts to Oracle Health, Philips North America, American Well, Henry Schein, and Solventum; transition dates July 2026 through July 2027; stated rationale of eliminating pass-through costs and preserving the unified federal baseline). https://www.washingtontechnology.com/contracts/2026/06/how-dha-plans-end-leidos-run-militarys-health-record-integrator/414160/

[CC11] Department of Veterans Affairs Marketplace, "FastTrack PGx: Pharmacogenomic Testing" (root cause identified as lack of interoperability and integration between VA's electronic health record and the reference laboratory; manual, error-prone uploading; results stored as PDF files). https://marketplace.va.gov/innovations/pharmacogenomic-pgx-testing-enabling-the-va-provider-to-tailor-prescriptions-based-on-the-veteran-s-genetic-profile-no-more-one-size-fits-all-approach

[CC12] American Institute of Physics FYI, "Congress Set to Finalize Science Budgets, Rejecting Trump Cuts," January 2026. https://www.aip.org/fyi/congress-set-to-finalize-science-budgets-rejecting-trump-cuts · Venable, "First Circuit Holds NIH Rate Caps Unlawful," January 2026. https://www.venable.com/insights/publications/2026/01/first-circuit-holds-nih-rate-caps-unlawful