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. [200.461] Publication and printing costs. Proposed section 200.461 would make publication costs, including page charges and article processing charges for professional journals and peer-reviewed publications, unallowable unless required by statute or approved in advance by the federal agency on a case-by-case basis. It also states that a general requirement to make results publicly available would not authorize publication costs. This provision would cause concrete harm because publication is a core output of NIH-funded biomedical research. Peer-reviewed publication is how findings are disseminated, scrutinized, replicated, cited, and translated into future research and clinical advances. NIH-funded research has limited value if results cannot be efficiently published and shared with the scientific community and the public. My research depends on publication of methods, data, analyses, and findings so that other scientists can evaluate and build on the work. Requiring case-by-case prior approval for publication costs would delay publication, increase administrative burden, and create uncertainty at the exact point when results are ready to be shared. It would also disadvantage trainees and early-career scientists who depend on publication to advance their careers. Publication costs should remain allowable when reasonable, allocable, and directly associated with reporting federally supported research. I request that OMB not finalize proposed section 200.461.