Comment from Heather Duncan

As an epidemiologist and public health educator, I am concerned by the proposed rule’s repeated reliance on the term “Gold Standard Science" in section §200.205, as referenced in Executive Order 14303, without providing an operational definition or measurable criteria for implementation. In its current form, the proposed requirement introduces substantial ambiguity into federal research funding determinations. The rule would require that all grant applications include benchmarks for compliance with “Gold Standard Science,” while also directing agencies to prioritize institutions that have “demonstrated success in implementing Gold Standard Science,” and simultaneously deprioritizing institutional prestige or historical research track records. However, because “Gold Standard Science” is not defined in the proposed rule, its application cannot be objectively assessed, operationalized, or consistently evaluated across applicants or funding mechanisms. From a public health and epidemiologic research perspective, this lack of definitional clarity raises several concerns. First, it undermines the principles of transparency and reproducibility that are foundational to scientific evaluation. Without explicit criteria, applicants cannot reasonably design studies or evaluation frameworks to meet the requirement, nor can peer reviewers apply it consistently. Second, the absence of a definition effectively transfers broad interpretive discretion to administrative actors without clear standards to guide decision-making. This introduces the risk of inconsistent or non-reproducible funding determinations across agencies, programs, and review panels. Third, tying funding priority to compliance with an undefined standard while explicitly de-emphasizing established indicators of scientific capacity—such as institutional research history, infrastructure, and peer-reviewed track record—may inadvertently weaken the ability of funding agencies to reliably identify institutions best positioned to conduct high-quality, methodologically rigorous research. In practice, scientific standards must be operationalized through clearly defined, measurable, and transparent criteria that can be consistently applied across contexts. If “Gold Standard Science” is intended to guide federal research funding, it should be accompanied by explicit definitions, implementation guidance, and evaluative metrics that allow applicants and reviewers to apply the standard in a consistent and non-arbitrary manner. Absent such clarification, the proposed provision risks introducing avoidable ambiguity into the federal research funding process and may compromise the consistency and integrity of grant evaluation procedures. -Heather Duncan, MPH, PhD