Comment from Janet McGrath

I write as a private citizen to oppose implementation of proposed OMB Guidance for Federal Assistance (2 CFR), Vol. 91 Fed. Reg. No. 103 including federal research grants. These proposed regulations will undermine the American scientific innovation. I share the stated goals of transparency, accountability, and oversight of taxpayer dollars. The proposed provisions decrease transparency and accountability by transferring funding decisions to political appointees with no scientific expertise and no accountability to the scientific community. The result will be federally funded science that is less rigorous and less responsive to the public interest. I urge OMB to withdraw these rules as written, particularly provisions: [200.205], [200.340], [200.432], [200.454], and [200.461]. Expertise: I am tenured professor at Case Western Reserve University. During my 40-year career in the social scineces, I have been funded by NSF and NIH and served as peer reviewer for both NSF, NIH. My commitment to transparent and accountable research is unimpeachable. [200.205] Pre-issuance review by political appointees, diminution of peer review. This proposal transforms scientific review into a political exercise by requiring political appointees to review funding awards to ensure they “demonstrably advance the President’s policy priorities.” Additionally, these political appointees “must not ministerially ratify or routinely defer to” peer reviewers. As such, relevant scientific expertise is sidelined. Despite well-known critiques, the logic of peer review is sound: the fairest, most scientifically sound, and most transparent way to assess a proposed study in terms of scope, methods, significance, and requested funding is to rely on expert review. Peer review employs multiple reviewers, explicit statements of COI, and clear justifications for funding recommendations. This is not achieved by appointees with no relevant scientific training. Merit review supports accountability. I urge OMB to strike the subsections subordinating expert peer review. [200.340] Mid-award termination for shifting “priorities.” An alarming feature of the proposal is the authority to terminate active awards based on “agency priorities,” without evidence of misconduct. Capricious decisions to terminate research will result in loss of important scientific findings, wasting taxpayer dollars on research that will not be able to generate useful results because it has been arbitrarily terminated. This proposal will have a chilling impact on the social sciences. Social science research is highly valued across sectors, including defense, education, agriculture, and health. Research will become more politically volatile under the proposed rules and will decrease our international standing. Termination for documented noncompliance or misconduct is appropriate. Termination to accommodate a changed political priority is not. I urge OMB to restore termination only for cause. [200.432], [200.454], and [200.461] —cost provisions decrease access to scientific information These changes will remove the ability to critique, learn from, and expand on federally funded research. Specific concerns: •Conferences ([200.432]) must be pre-approved. This opens the door to arbitrary rulings as to what conferences better fit political “priorities”, regardless of scientific value. •Journal subscriptions ([200.454]) would be unallowable. This is not good stewardship of federal dollars: journals are the primary means of scientific exchange and without access there is increased risk of incomplete, duplicative, or non-rigorous research. Journals are tools of good science. •Publication costs, APCs, and open-access fees ([200.461]) would be unallowable. This provision contradicts federal policy requiring access to research findings. Additional concerns: •[200.205] “Gold Standard Science” is undefined. •[200.204] Competitions exempted from public posting decreases transparency and accountability. •[200.206] Affiliation-based denial violates the right to free association and free speech. •[200.220] Broad ban on international collaboration will cripple our ability to engage with the world, diminish US leadership, and decrease our strength and security. •[200.421] / [200.450] Public-communication and advocacy limits researchers’ ability to share findings, decreasing accountability. These proposed changes will lead to poor stewardship of taxpayers’ money, less accountability and transparency, and poorer science. The American scientific establishment leads the world: these changes will dismantle this system and diminish not just science but the safety and security of the American public. I respectfully urge OMB to withdraw [200.205], [200.340], [200.432], [200.454], [200.461], and related provisions. Respectfully submitted, Janet W. McGrath, PhD Case Western Reserve University