Comment from Mark Styczynski

I am a professor of chemical engineering leading a research group federally funded by NSF and NIH for 17 years. I have reviewed federal grant applications for multiple federal agencies. I write to strongly oppose the proposed rule. It undercuts the merit-based, expert-reviewed system that has made U.S. federally funded research a transformative public investment, and it would insert political control outside the quality of the science through the lifetime of a grant. This rule codifies non-scientific and capricious political preferences as criteria for distributing and revoking billions of dollars that make the lives of all Americans better when stewarded properly. It does not prevent waste. Instead, it explicitly requires expert advice to routinely be disregarded, and it adds uncertainty to an ecosystem that will destabilize it and push talented people to other countries. It is a poorly-justified, poorly-conceived idea with many negative repercussions. The following sections are particularly problematic. [200.205] Merit review Requiring an "appointee", and not a career employee who is a subject-matter expert, to provide final review and approval for all grants undercuts scientific merit and adds capriciousness and complications to funding decisions. Advancing the President’s policy priorities is not the remit of scientific research; it should not be a goal. Invoking the idea of protecting against "anti-American values" has echoes of the House Un-American Activities Committee, and could similarly be abused by an executive branch focused on consolidating power in a unitary executive. Importantly, the rule specifically states that the appointee should not "routinely defer" to expert review recommendations. It is concerning that the government would think it is a bad idea to routinely defer to experts, as is done everywhere else in a successful society. This idea actually PROMOTES waste rather than prevent it. There already exist ways that in unusual cases expert review can be overridden by career employees and other experts. Requiring that this overriding must happen routinely and be subject to political pressures is counterproductive. Connecting funding of science-focused grants to the political views of the current executive administration is a recipe for making American science worse. Please strike the revisions defined in 200.205(b)-(d), and maintain expert review based on scientific merit as the expected deciding factor for research funding. [200.205] Gold Standard Science The term and concept of Gold Standard Science is poorly defined in the rule, and in the cited EO is more like political interference based on misinformation. Scientific rigor, reproducibility, and transparency have already been increasing focus areas for agencies like NSH and NIH for the past decade or two. All this does is add a poorly-defined, politicized, and not scientifically informed layer that reflects one group’s biases, even though that is exactly what the rule claims to try to eliminate. Moreover, the justification for this rule is based on white papers like "Ditch II" from Heritage Foundation that misrepresent and exaggerate many findings; for example, they view a grant to "recruit and promote women in STEM" as "implying that the institution needs $1 million to not discriminate against women". Those who know about STEM demographics know that the issue being addressed is substantial, and it seems likely that reading the grant would quickly show that it is not a million dollars just to "not discriminate". With such bias and inattention to details being shown, such a document should not serve as proof of needing change. Please strike the revisions defined in 200.205(b)(5)-(8), and allow scientific rigor to be appropriately defined by scientists. You wouldn't want non-experts to tell you what is rigorous and safe for putting electrical wiring in your house; you similarly shouldn't want non-experts telling you what is rigorous and appropriate in scientific research. [200.340] Easier termination Section 200.340 lets an agency terminate any award at any time without cause and with no hearing rights to appeal the termination. This is not compatible with how science works. If every scientific grant can be pulled away at any moment by a new administration, you will waste dollars (counter to the goal of the proposed rules), you will ruin and undercut good science that can change Americans' lives, and you will spark brain drain to other countries. This will undercut American scientific excellence. There are already ways to terminate grants for actual problems like noncompliance, audit issues, etc. Scientific research is not like a contract to buy more widgets. Treating it like that puts American science in jeopardy. The proposal defeats its own stated purpose. Please withdraw the termination expansion in 200.340(a)(2), or at least exempt research awards and preserve administrative hearing rights under section 200.342.