Comment on OMB-2026-0034-0001

Stellate Communications is a research communications firm that works directly with federally funded scientists and research institutions — primarily universities and independent research organizations — to help them communicate their findings to scientific, policy, and public audiences. Our 11 full-time, US-based employees have advanced degrees and/or training in science, research, and communication. Our business exists in support of, and because of, federally funded research. We submit this comment because the proposed rule would cause serious harm to our clients, the research enterprise we serve, our firm, and the people we employ. [§200.205] The proposed revision to §200.205 would require senior political appointees to review grant proposals for alignment with administration priorities, rendering expert peer review merely advisory. From our position working daily with federally funded investigators, we can attest that the existing peer-review system is what gives federal grant competitions their credibility. Researchers invest enormous effort into creating proposals and institutions build long-term research programs around awarded funding. Subordinating scientific judgment to political review will distort which research gets funded, chill investigators from pursuing questions that may be disfavored, and erode the trust of the international scientific community in U.S.-funded research. We have already seen this dynamic begin: in 2025, one of our clients experienced three temporary award freezes that had nothing to do with performance or compliance. The result was not orderly — it was chaos. Biomedical research labs lost momentum, staff faced uncertainty, and research that had been years in the making stalled. §200.205 would institutionalize that dynamic. [§200.340] The expanded termination authority under §200.340 would allow agencies to end active awards at any time if they no longer align with current federal priorities. For our clients, this means that a multi-year research program — one that has passed peer review, secured institutional commitment, recruited personnel, and begun generating results — can be cancelled mid-stream on political grounds. For our firm, it means that engagements built around the communications needs of active research projects can disappear without warning. We employ 11 people and work with 8 more contractors. We cannot absorb mid-project terminations without serious consequences for our staff and contractors. But more importantly, the researchers and institutions we serve cannot rebuild lost momentum, retain displaced staff, or recover sunk costs when awards are terminated arbitrarily. The damage to American research capacity is cumulative and lasting. [§200.432] The proposed revision to §200.432 would make conference attendance allowable only if expressly pre-approved by the federal agency and written into award terms and conditions. Scientific conferences are not perks — they are how researchers present findings, receive peer feedback, forge collaborations, and remain current in their fields. For our clients, restrictions on conference participation directly impair the dissemination work that is central to what we do together. A research communications strategy that cannot include conference presentations is fundamentally limited. Requiring agency pre-approval for each conference as a condition of the award adds an administrative burden that will fall hardest on smaller research teams and institutions with less grants management infrastructure. We urge OMB to withdraw §200.205, §200.340, and §200.432 as proposed. These provisions do not strengthen oversight — they politicize funding decisions, destabilize active research, and impose administrative burdens that serve no legitimate purpose. The proposed rule, if finalized as written, would measurably weaken American research capacity at a moment when that capacity is already under strain. Stellate Communications, Gabriela Serrato Marks, PhD, Partner and Co-Founder