Comment from Marko Spasojevic

I am an associate professor whose research has been supported by the NSF. I am concerned that several provisions of this proposed rule could undermine the effectiveness, fairness, and scientific integrity of the federal research enterprise, making US science less competitive. In particular OMB should strike or rewrite the provisions [200.205], [200.300], [200.340], [200.432], [200.454], and [200.461]. Specifically, the following are ridiculous: [200.205] Peer review has been a cornerstone of American science for decades. Changing this will weaken our science enterprises and make our country less competitive on the global stage. Moreover, it reduces confidence that funding decisions will be based on scientific quality and potential impact. A generalist appointee is not positioned to assess whether a proposed design is confounded, whether a sample is adequate, or whether an analytic plan supports the inferences drawn. The post-war American research system became the most productive in the world because the allocation of public funds was tied, through peer review, to independent technical judgment rather than to the preferences of whoever held office. A political review forbidden from deferring to that judgment does not add a safeguard atop merit review; it overrides merit with something that is not merit. [200.300]. Embedding categorical prohibitions on broad, loosely defined subject areas is anti-American and puts our scientific enterprise at risk. [200.340] Scientific research often requires long-term planning, personnel commitments, and multi-year investments that become difficult to sustain when funding can be withdrawn unpredictably. A grant is not a purchase of a deliverable; it is a multi-year commitment around which a laboratory hires and trains staff, enrolls and incurs ongoing ethical obligations to human research participants, and structures years of work that cannot simply be paused and resumed. Discretionary mid-stream termination will push scientists away from ambitious, long-duration, and transformative research that has led to our country being a lead in scientific advancement. [200.432], [200.454], and [200.461] —Taken together, these changes would cut federally funded researchers off from the professional community that makes their work usable: Conferences ([200.432]) would be allowable only if pre-approved and written into the award at issuance. Conferences are where results are presented, critiqued before publication, and turned into collaborations. A researcher cannot anticipate at award time which meeting in year three will matter, and a discretionary, per-conference approval gate adds an administrative step where none is needed. Access to the literature (Journal subscriptions (200.454]) is not a perk; it is the precondition for knowing what has already been established, which is the first requirement of excellent science. Publication costs, APCs, and open-access fees ([200.461]) would be presumptively unallowable, in direct conflict with existing federal public-access policy. In closing, these changes along with ([200.205], [200.202], [200.202(d)], [200.202(e)], [200.204], [200.206], [200.220], and [200.421] / [200.450]) will all greatly harm our country and our countries’ leadership on the world stage. I strongly urge OMB to withdraw or substantially revise [200.205], [200.300], [200.340], [200.432], [200.454], [200.461], and the related provisions listed above.