Comment from Brent Christner

I am a professor of microbiology who leads federally funded research programs focused on environmental microbiology, astrobiology, and the development of technologies with applications to national security, public health, and the economy. I strongly oppose several provisions of the proposed revisions to 2 CFR Part 200 because they would undermine the stability, transparency, and effectiveness of the U.S. scientific enterprise. The proposed changes to §200.340, allowing agencies to terminate active awards based on evolving agency priorities, would substantially increase uncertainty in research planning. Modern scientific projects often require years of coordinated effort, long-term personnel commitments, specialized equipment purchases, and collaborations among multiple institutions. The possibility that funding could be withdrawn after significant investments have been made would discourage ambitious, high-risk research and make it difficult to recruit and retain students, postdoctoral researchers, and technical staff. It would also reduce the willingness of institutions to invest matching resources in federally sponsored projects. The restrictions in §200.461 that would prohibit most publication and open-access costs would impede the dissemination of publicly funded research. Taxpayer-supported discoveries should be communicated broadly so they can be validated, reproduced, and applied by scientists, industry, educators, and policymakers. Limiting publication support would reduce scientific transparency and slow innovation. The proposed requirements in §200.432 for pre-approval of conference attendance and professional memberships would impose unnecessary administrative burdens while limiting opportunities for scientific exchange. Conferences are essential venues for presenting results, establishing collaborations, training students and early-career scientists, and accelerating the translation of discoveries into practical applications. Delays or uncertainty in obtaining approvals could significantly reduce these benefits. The provisions in §200.220 affecting international collaborations should be carefully tailored to legitimate security concerns without broadly discouraging scientific partnerships that advance U.S. interests. Many major scientific advances depend on international cooperation, standardized methods, and shared datasets. Excessive restrictions risk isolating U.S. researchers and reducing American leadership in science and technology. Finally, changes to §200.421 that reduce transparency in grant competitions and other provisions that inject political discretion into scientific funding decisions threaten the long-standing principle that research awards should be based primarily on scientific merit and expert peer review. The credibility and global leadership of the U.S. research enterprise have been built on competitive, transparent, and evidence-based funding processes. Federal research investments support not only scientific discovery but also workforce development, economic competitiveness, technological innovation, environmental stewardship, and national security. Stable and predictable funding policies enable universities to train the next generation of scientists and engineers while producing knowledge that benefits society as a whole. I respectfully urge OMB to reconsider these proposed provisions and preserve a research funding system grounded in peer review, transparency, and scientific excellence.