Comment from Heather Duncan

As an epidemiologist and public health educator, I am deeply concerned about the proposed expansion of authority permitting federal agencies to terminate active grants at any time on the basis that they are “inconsistent with program goals or agency priorities,” without any requirement to demonstrate noncompliance, fraud, or material breach of award terms as described in section §200.340. While the rule characterizes this authority as analogous to a “termination for convenience” clause in federal contracting, this framing does not reflect the fundamentally different nature of research grants. Federal research awards support long-term scientific, clinical, and public health investigations that are built on sustained infrastructure, regulatory oversight, and ethical obligations to human participants. Investigators design studies, obtain institutional review board approvals, establish data safety monitoring procedures, and recruit participants with the understanding that studies will be carried through to completion barring scientific or ethical concerns. Allowing active grants to be terminated solely on the basis of shifting or broadly defined “program goals or agency priorities,” with only a brief written rationale, introduces profound instability into the research ecosystem. The consequences of such instability extend beyond administrative disruption and directly affect human participants enrolled in clinical trials and longitudinal studies. In many cases, these individuals participate with the expectation of ongoing clinical monitoring, follow-up, and contribution to knowledge that may benefit future patients. Sudden termination of funded studies risks interrupting care pathways, discontinuing follow-up, and rendering participant contributions incomplete or unusable, effectively undermining the ethical commitments made at the time of enrollment. The impacts also extend to the scientific workforce. Multi-year research programs are sustained by teams of early-career researchers, technicians, coordinators, and principal investigators whose employment and professional trajectories depend on continuity of funding. Abrupt termination of awards can dismantle entire research teams, result in loss of specialized expertise, and effectively end nascent scientific careers. Over time, this level of instability will deter trainees and early-career scientists from pursuing research careers in the United States, particularly in fields requiring long-term investment such as epidemiology, clinical trials, and population health research. From a broader perspective, such uncertainty will accelerate a shift of scientific talent and research investment away from the United States that is already well underway. Highly trained researchers will reasonably choose to pursue opportunities in countries with more stable and predictable research funding environments. This “brain drain” would not only weaken the domestic scientific workforce but also erode the United States’ capacity to conduct large-scale, longitudinal, and translational research. The consequences of this erosion would likely be felt over decades, particularly in the domains of clinical innovation, chronic disease prevention, and pandemic preparedness. While agencies must retain appropriate oversight mechanisms to ensure responsible stewardship of federal funds, such authority must be balanced against the need for predictability, ethical continuity in human subjects research, and stability of the scientific workforce. Clear, narrowly defined criteria for termination—grounded in performance, compliance, or specific programmatic failures—are essential to maintaining both scientific integrity and public trust. In its current form, the proposed provision introduces a level of discretionary uncertainty that risks harming research participants, destabilizing scientific careers, and undermining the long-term strength of the U.S. research enterprise. -Heather Duncan, MPH, PhD