Comment from Mark Styczynski

I am a professor of chemical engineering leading a research group federally funded by NSF and NIH for 17 years. I have reviewed federal grant applications for multiple federal agencies. I write to strongly oppose many of the proposed rule changes. I have previously submitted concerns with different sections of the changes, but additional problematic changes have now been brought to my attention. [200.432] - Conferences The proposed rule on conferences is problematic on multiple levels. 1) Conference attendance is critical for professional development of trainees (graduate students, postdoctoral associates, etc.). It is a key way they learn about advances in the field that can benefit their work, learn about new fields (giving them new perspectives on their projects), develop collaborations, and initiate networking that is critical for their success. If they cannot attend conferences using federal funds, it will be extremely difficult for trainees to attend conferences and they will miss out on this crucial aspect of professional development. Many researchers do not have funding from industry to make up for new federal restrictions, and even if they do they would likely be prohibited from using it for students supported by different funding sources. Discretionary money is also difficult to get, particularly in the quantity needed to support conference attendance for a whole research lab. This rule change would disproportionately impact early-career independent researchers who most need support for their trainees' development. 2) It is unreasonable to expect all conference attendance to be explicitly included in the terms of the award. It is essentially impossible to know when an award is given how many students will be ready to attend conferences in any year and what conferences will best suit their training needs. As it is, scientists in the federal government struggle to do this accurately when they must budget conference attendance just one year out, but this rule change would require forecasting 3, 4, or even 5 years in advance, which is unreasonable. 3) Express agency approval at the level of which conferences to attend and when is micromanaging that wastes government time. Agencies are understaffed, there are efforts to further prune staff counts, and yet the proposed rule adds tremendous additional red tape and responsibility to overburdened federal workers, whether that "approval" is given at the beginning of the award or during the course of the award. 4) There appears to be no justification or benefit for making conference attendance unallowable. This rule seeks to solve a problem that does not exist. For these reasons, I strongly urge you to remove the new prohibitions on conferences as allowable costs. It is fair to make it clear that conference attendance should advance program outcomes, but given the heavy skew of federal awards towards supporting trainees, applying the proposed restrictions would be burdensome with no real benefit. [200.461] Publication costs The justification for this change is provided in the proposal: "Publication costs are not inherently necessary to carry out the core programmatic objectives of most Federal awards. In many cases, such activities are discretionary..." However, this assertion is patently false. It is first critical to note that much of the publishing industry has shifted to open-access models and publication costs, driven by the government and society asking for the past two decades for greater access to what their tax dollars funded and creating open-access repositories. Many, if not most, of the appropriate locations to publish my own research now require publication costs. This will only increase as federal requirements for immediate public access via NSF and NIH repositories are implemented, undercutting the business model (restricted access) that would otherwise avoid the need for publication charges. It is thus possible, given recent federal actions, that most journals may soon require publication charges, making them even more necessary. The justification may also be construed to imply that publication itself is not necessary. This is also patently false. 1) Training and education of students is a key programmatic objective of many federal research awards (e.g., NSF). For them to advance in their degree programs, publications are explicitly necessary. 2) For many federal research programs, publications are viewed as critical deliverables that impact go/no-go decisions, renewals, or assessment of past project success by review panels for future awards. Thus, publication is an implicit objective. 3) Publication is the only way that scientific advances get peer-reviewed and disseminated, and that the public gets access to the work that they funded. And again, requiring explicit agency approval adds more responsibility and work to already overburdened federal workers. I thus recommend the new restrictions on publication costs be removed.