Comment from Gina Turrigiano

Re: Guidance for Federal Financial Assistance (2 CFR), Vol. 91 Fed. Reg. No. 103 (May 29, 2026) This proposal will undermine rather than serve the goals of enhancing transparency, accountability, and oversight of scientific research. By transfering core funding decisions from qualified scientific experts to political appointees, it will make federally funded science less merit-based, less rigorous, less stable, and less responsive to the public interest. I urge OMB to withdraw or substantially revise the following provisions: [200.205], [200.300], [200.340], [200.454], and [200.461]. These provisions entail such substantive changes to the scientific research enterprise that a 45-day comment period is clearly inadequate. Executive order 12866 mandates at least 60 days and up to 180 days for complex rules changes. I therefore urge you to extend the comment period so that the repercussions of these proposals can be fully considered. I am a Professor of Biology and Neuroscience at Brandeis University, where I run a federally-funded lab to study brain function and disorders. I am a National Academy of Sciences member, my lab has been continuously funded by NIH for ~ 30 years, and I have published > 110 peer-reviewed articles. I have trained > 40 PhDs and Postdocs who have entered the US Scientific workforce. I have served on NIH study sections, and on advisory panels of major scientific institutions across the country. I understand how federal research funding has historically worked, the strengths and weaknesses of the current system, and the evolving needs of US science. [200.205] Pre-issuance review by political appointees, with peer review demoted to advisory. This proposal requires senior political appointees to review every discretionary award, ensure it advances the Administration’s policy priorities, and disallows routinely deferring to peer reviewers, thus reducing expert review to an advisory role. This undermines the purpose of merit-based review. Peer reviewers assess methodological rigor and scientific significance, judgments that require technical expertise and cannot be made by political appointees. The success of the postwar U.S. research rests on funding decisions guided by independent expert evaluation rather than political preferences. A political review forbidden from deferring to that judgment replaces this merit-based system with a system that is vulnerable to crony interests and political influence. The contrast between U.S. and Soviet science illustrates the costs of such ideological control over research. [200.300] Content-based award conditions. Broadly defined and vague prohibitions create uncertainty that can discourage legitimate research and prompt self-censorship. The resulting chilling effect is likely to reduce scientific innovation, the opposite of the stated goals of these reforms. [200.340] Mid-award termination for shifting “priorities.” The proposal would expand authority to terminate active awards without a finding of noncompliance, for virtually any political reason. The resulting uncertainty will push investigators and institutions away from ambitious, long-term projects toward safer, shorter ones, and will undermine the training of the U.S. scientific workforce by making grant-funded positions increasingly precarious. Most critically, it will drive talented people away from scientific careers by making salary and research support unreliable. This would be a catastrophic change with lasting negative consequences. [200.461] Publication costs, APCs, and open-access fees [200.461] would be presumptively unallowable. This provision is in direct conflict with existing federal public-access policy, thus creating a “catch-22” in which open access is mandated but unattainable for many researchers. While this provision prevents using grant funds for compliance, existing policy states that other standard ways of providing open access to the work, such as posting to preprint servers, are also unallowable. This approach must be re-thought. There may be legitimate means of limiting federal expenditures on open access, but there must be a clear path that allows all federally funded scientists to comply when publishing their work. [200.205] “Gold Standard Science” as an undefined test — grants and institutions must meet this undefined standard. This vagueness opens the door for arbitrary and capricious enforcement. [200.202] Program goals aligned to administration priorities [200.204] Competitions exempted from public posting — a broad “national interest” exception could move entire competitions out of public view, defeating transparency. Respectfully submitted by Gina Turrigiano PhD, Levitan Professor of Vision Science at Brandeis University, member National Academy of Sciences.