Comment from Eric Jones

I appreciate the opportunity to comment on OMB-2026-0034. I am a professor at a school of medicine, and I do not currently receive any federal funding. However, I began my career under training grants provided by the NIH, and under NIH and DOE research grants to my supervisors. There is no question that without this funding, I would not be in the fortunate position I am today. I have the following specific concerns about the proposed OMB rulemaking, organized by section. [200.205d]: For all the mentions of "gold standard science", OMB does not seem to appreciate that peer review IS the gold standard of ensuring rigor and merit in scientific proposals. Making peer review "advisory" is an affront to researchers who devote precious time to the difficult and unglamorous work of evaluating grants for merit, plausibility, novelty, and impact. Science has advanced because of peer review, not in spite of it. [200.300]: This section leans heavily on the incredibly vague and slippery definitions of "gender ideology" and "DEIA" spelled out in the President's executive orders. At best, this proposal is a solution in search of a problem. I have never met anyone who believes "that 'sex' and self-assessed 'gender identity' are interchangeable". My medical school has a required course on "male and female" reproductive organs and function. So what are these ideologies that we so need to be protected from? They are whatever the President and the OMB don't like. Worse, it is unclear whether these amorphous policies would apply to individual grant recipients or also to their hosting institutions. If the latter, then a grant may be terminated by any mention of "gender" anywhere, in any program, even if far removed from the scope of the grant. Space physics and drug discovery researchers would have their grants terminated if someone in the gender studies department made an unfortunate social media post. The same can be said for section 200.219. For an administration that has consistently said nobody should have to be punished for the sins of others in their identity group, this certainly looks like punishing all researchers for the sins of a handful of radicals. [200.206]: This section would allow for denial or termination of awards based on affiliations with groups that "undermine public safety or national security", without elaboration. So if I belong to an advocacy group, one of whose members is arrested for disorderly conduct, I could be denied a grant for belonging to a group that undermines public safety? This is simply a tool for punishing the sin of having values not shared by the President. [200.303], [200.432], [200.454]: Part of the stated reason for the proposed rulemaking is to decrease administrative burden on researchers. Yet these sections would pile onerous and arbitrary new bureaucratic processes on researchers. For example, 200.432 requires advance agency approval for conference attendance, a quite ordinary (and, compared to research costs, inexpensive) part of being a scientist. Every conference attendance would have to be planned in advance for the duration of the grant. This is unrealistic, burdensome, and frankly silly. [200.205]: This is the section that has attracted the most attention, and rightly so. Aside from demoting peer review to a mere formality (see above), this section empowers partisan political appointees (who aren't even required to have scientific credentials) to approve, deny or terminate any grant for any reason at all that they deem unaligned with the President's priorities. I have tried in this comment to avoid the type of hysterical language used liberally throughout the Proposed Rule, but here I reach my limit. This proposal would create officially sanctioned party censors with absolute control over science. There is no other way to describe it: an apparatchik of the ruling political party gets to unilaterally give thumbs-down to any research with any possible outcome or implication deemed politically inconvenient to the President. This is a play stolen from the Soviet Union and China. It has no place in a constitutional republic. Congress needs to reject the Proposed Rule in its entirety. Tellingly, the rationale for this rule change do not once cite any scientific organization, scientist, or institution. Rather, nearly all statements of fact in the Executive Summary and Background and Regulatory History sections are cited to the President's own executive orders, or to culture-wars engines like the Heritage Foundation. The Proposed Rule does not solve any problem faced by scientists, federal agencies, or American taxpayers. It only solves the problems of the President and his donors. We don't need this. We can save money and refocus away from DEI without handing over the entire federal research funding enterprise to the President's toadies.