Comment from Thomas Bozza

I am an academic researcher who has run an NIH-funded laboratory at a top research university for 20 years. The proposed revision to the Uniform Guidance (2 CFR Part 200) contains provisions that will continue and expand the destabilization of federally funded research in the United States. While the grant funding process could benefit from mindful revision, this is not it. Adopting these changes will weaken science in America and provide our foreign competitors with even greater advantage. The rate of decline of American science will increase, and China will continue its ascendence. § 200.205 — Federal Agency Review of Merit of Proposals. This change allows senior political appointees to conduct pre-issuance review of grant proposals, rendering peer review "purely advisory." This subordinates a cornerstone of American scientific strength. The proposal states that appointees must ensure grants "advance the President's policy priorities" and are forbidden from "routinely ratifying" peer reviewer recommendations. Our peer review system is designed to insulate funding decisions from non-expert, politically motivated interference. This policy does the opposite. The Government should set priorities by communicating what types of projects will be given priority, allowing investigators to adjust their research and apply to appropriate funding calls — not hand-pick proposals in ways that discount scientific review. The peer review system built American dominance in science and technology during the 20th century. Why are we dismantling it? § 200.340-200.343 — Termination and Suspension. This gives the government broader power to pause or end awards if funding no longer aligns with agency priorities or the national interest, with no appeal process. It cannot be overstated how much this will destabilize the American research enterprise. While competitors in China enjoy ample, long-term funding stability, researchers here will operate under constant threat of sudden termination. Science requires stability to flourish. Forcing labs and institutions to think year-to-year will stifle the intellectual risk-taking and innovation that has defined American scientific eminence, and will further discourage graduate students and postdoctoral researchers from pursuing scientific careers. Good for China. Bad for the United States. § 200.206 — Federal Agency Review of Risk Posed by Applicants. This expands criteria agencies may use to deny awards, including whether an applicant has "affiliations with organizations engaged in activities that violate Federal law or undermine public safety or national security." This is a thinly veiled attempt to keep universities and individuals with certain political beliefs in line — so chilling that I had second thoughts about submitting these comments for fear of retribution. Is this really the United States? § 200.201 — Elimination of Fixed Amount Awards. Shifting all awards to cost-reimbursable models adds substantial red tape and transfers financial risk and administrative burden to recipient institutions, reducing the flexibility investigators need to pivot toward new scientific opportunities. Combined with termination-for-convenience provisions and expanded cost disallowance categories, institutions may spend money in good faith, do excellent science, and still be unable to recover costs if agency priorities shift mid-award. § 200.461 / § 200.432 / § 200.454 — Publication Costs, Conferences, and Memberships. These changes make publication costs and open-access fees unallowable, placing investigators in an impossible position — NIH already requires open access to federally funded research. If the government wants to change journal fee structures, address that through legislation directed at publishers. Conference pre-approval requirements will prevent scientists and trainees from networking globally and degrade early access to cutting-edge findings. This provision does not fix a real problem. Overall, these rules replace merit-based scientific judgment with political oversight at every stage of the grant lifecycle. They will accelerate the exodus of top researchers, discourage the next generation of trainees, chill entire fields of legitimate inquiry, and erode the research enterprise that made the United States the world leader in science and technology. Our competitors will be thrilled.