Comment from Kevin Uno

I am submitting this comment to oppose OMB’s proposed revisions to the Guidance for Federal Financial Assistance (2 CFR Part 200). As proposed, they would weaken scientific peer review, increase political influence over basic research and award decisions, expand discretionary grant termination, and restrict normal scientific dissemination and collaboration. I am a geochemist and professor at a major research university in Massachusetts. My lab uses stable isotope and organic geochemistry (biomarkers in sediments; isotopes in tooth enamel and carbonates) to reconstruct past environments relevant to human evolution and to support wildlife forensics, including radiocarbon approaches to combat illegal ivory trade. This work depends on competitive, peer-reviewed federal funding (including NSF), multi-year field and laboratory investments, trainee support, and collaboration with international partners. Why this concerns me and how it will affect my work Peer review is the core quality-control mechanism that makes federal research funding efficient and accountable to taxpayers. In my own program, peer-reviewed federal support enables method development, specialized analytical work (stable isotope mass spectrometry and organic geochemical analyses), field campaigns requiring years of planning and permits, and training of graduate students and postdocs. These proposed changes would harm my work and my trainees in concrete ways. If award decisions can be overridden based on shifting political priorities—explicitly stating peer review is “advisory”—it becomes harder to plan rigorous, long-term research and responsibly recruit and support trainees. If multi-year awards can be terminated “for any reason,” it becomes risky (and sometimes irresponsible) to begin projects that require sustained fieldwork, long-term international coordination, and multi-year analytical workflows; abrupt termination would strand students and waste taxpayer-funded investments already made in sample collection, permits, and instrument time. Restrictions that make conference participation and publication costs unallowable by default would slow dissemination, reduce transparency and reproducibility, and limit professional development for early-career scientists. Finally, broad limits on international collaboration would obstruct legitimate scientific partnerships and capacity-building that advance U.S. scientific leadership and are already governed by existing compliance and security frameworks. Specific problematic provisions (by section number) 200.205 (pre-issuance review by “senior appointees”; peer review “advisory”): Undermines merit review and invites non-scientific overrides of technical evaluations central to my field. 200.340 (discretionary termination): Creates destabilizing uncertainty for multi-year research, trainees, and large up-front investments in field and lab work. 200.432 (conference costs): Makes participation dependent on prior approval and award terms, which is impractical for conferences scheduled after awards and for student presentations and fast-breaking scientific exchange. 200.461 (publication costs): Makes publication/open-access charges unallowable unless pre-approved, impeding dissemination of federally funded results and shifting costs onto labs and trainees. 200.220 (international collaboration limits): Overbroad default restrictions risk blocking legitimate collaborations essential to earth science, paleoclimate, human origins, ecology, and conservation. 200.202 (alignment with administration priorities): Encourages viewpoint-based screening and short-term political influence over long-term, nonpartisan national research needs. The ask I respectfully request that OMB not implement these provisions as proposed, and instead revise the rule to: (1) preserve independent scientific peer review as the primary basis for research award decisions; (2) limit termination authority to well-defined, due-process grounds; (3) maintain allowability of reasonable publication and conference costs necessary to disseminate results; and (4) use targeted, clearly defined national-security safeguards for international collaboration rather than broad prohibitions. These proposed changes would harm the national interest by reducing the quality, efficiency, and global leadership of U.S. science and destabilizing the training pipeline for future scientists.