Comment from Andrew Moore

Comments on Proposed Rule: Regulation for Federal Financial Assistance Docket No. OMB-2026-0034 Submitted by: Andrew Moore, Associate Professor, Department of Anatomical Sciences, Stony Brook University I am an Associate Professor at Stony Brook University. My research investigates the evolutionary history and functional anatomy of vertebrates, with a focus on skeletal biology in extinct and living dinosaurs (i.e., birds). I have received $148,000 in NSF funding (Award Nos. DGE-1246908; OISE 1515288) in support of this work. I have recently submitted a $682,000 collaborative NSF proposal on the form, function, and evolutionary history of the avian respiratory system — a project with implications for avian conservation, STEM workforce development (two graduate students, one postdoctoral researcher), AI-driven methodological training, and K-12 public engagement. I write to object to three provisions that would cause severe harm to my research program and to American basic science broadly. [200.220] — Prohibition on Foreign Collaboration My research depends on collaboration with the Zigong Dinosaur Museum in Sichuan, China, one of the world's foremost vertebrate fossil repositories, as well as with other international museums. These collaborations are conducted openly, involve no proprietary technology, and raise no cognizable national security concern. The history of life on Earth is not a strategic asset. The administration's concern about protecting sensitive technologies is legitimate. But applying the same blanket prohibition to vertebrate paleontology and evolutionary biology as to defense-relevant engineering is neither proportionate nor rational. This provision will eliminate internationally competitive American science programs without advancing any security objective. I urge OMB to narrow § 200.220 to research areas with genuine security implications, and to establish a clear, accessible exception process for basic research collaborations that present no plausible security risk. [200.205] — Political Pre-Issuance Review The proposal to require senior political appointees to review every discretionary grant — with explicit instruction not to defer to peer reviewers — substitutes political alignment for scientific merit as the criterion for funding decisions. This is precisely the condition under which science ceases to function as a reliable method of inquiry. The history of basic research demonstrates repeatedly that practical significance cannot be anticipated at the outset: bacterial immune systems gave rise to CRISPR; studies of bird flight informed aircraft design; research on pneumatized bone informs both vertebrate biology and lightweight structural engineering. Political appointees do not have the domain expertise to evaluate proposals in these areas, and instructing them to override expert judgment does not improve science — it degrades it. I urge OMB to withdraw § 200.205(b) and restore the primacy of peer review in scientific funding decisions. [200.340] — Expanded Termination Authority Scientific research cannot be started, stopped, and restarted at administrative convenience. My research program depends on multi-year planning horizons: field seasons coordinated internationally months in advance, graduate students recruited on the basis of multi-year funding commitments, and specimen and data workflows that cannot be arbitrarily interrupted without irreversible loss. The human cost of this provision is particularly serious. My pending proposal would support two graduate students and a postdoctoral researcher — early-career scientists making consequential life decisions on the basis of reasonable expectations that funding commitments will be honored. Arbitrary mid-award termination with no meaningful appeal right makes careers in federally funded science financially precarious and will deter talented individuals from entering the scientific workforce at precisely the moment the United States should be investing in it. I urge OMB to withdraw the expanded termination authority in § 200.340(a)(2) and restore the requirement that termination of active awards requires a finding of noncompliance. Conclusion Peer review, basic research independence, and reliable multi-year funding commitments are the institutional conditions under which science actually works. This proposed rule dismantles all three. I urge OMB to withdraw or substantially revise the provisions addressed above. Andrew Moore Associate Professor, Department of Anatomical Sciences, Stony Brook University Andrew.j.moore@stonybrook.edu June 12, 2026