Comment from Kent Lloyd

I am a biomedical researcher whose work depends on NIH-funded research, rigorous scientific peer review, publication of results, participation in scientific meetings, collaboration with specialized experts, and the ability to train and sustain a research workforce. My research is part of the biomedical research enterprise that advances understanding of human and animal health, improves disease models, supports development and validation of new approach methodologies, and contributes to future therapies, diagnostics, and public health interventions. The proposed revisions to 2 CFR part 200 would substantially disrupt NIH-funded biomedical research. Several provisions would replace scientific merit review with political or administrative criteria, create uncertainty around ongoing awards, limit dissemination of research findings, and impose case-by-case prior approval requirements that are incompatible with the pace and structure of modern science. I respectfully request that OMB not finalize the following provision. [200.454] Memberships, subscriptions, and professional activity costs. Proposed section 200.454 would make subscriptions to business, professional, academic, and technical periodicals unallowable and would require prior written agency approval for memberships in professional, civic, business, and technical organizations. This provision would cause concrete harm because biomedical researchers must have access to current scientific literature, technical standards, professional societies, and discipline-specific resources. Professional society memberships often provide reduced conference registration, access to scientific communities, trainee opportunities, standards development, committee service, and dissemination channels. Technical and academic subscriptions support literature review, experimental design, regulatory awareness, reproducibility, and responsible use of federal funds. For my research, keeping current with the scientific literature is not incidental to the award; it is necessary to conduct rigorous, nonduplicative, and well-controlled biomedical research. Treating academic and technical periodicals as unallowable would make federally funded research less efficient and less scientifically current. I request that OMB not finalize proposed section 200.454.