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. [200.421] Advertising and public relations. Proposed section 200.421 would broadly make advertising and public relations costs unallowable except in narrow circumstances, including certain program outreach necessary to meet award requirements. This provision would cause concrete harm because biomedical research increasingly requires communication with research participants, animal care and use stakeholders, patient communities, collaborating institutions, trainees, and the public. Outreach is not always “public relations” in the ordinary sense; it can be necessary for recruitment, education, transparency, dissemination, and responsible conduct of research. For my work, clear communication about federally funded biomedical research is essential to public understanding and trust. Overly broad restrictions could deter legitimate dissemination of research findings, recruitment of participants or trainees, communication about research resources, or outreach to communities affected by the diseases and conditions under study. Existing cost principles already require costs to be reasonable, allocable, and necessary. A broad categorical prohibition is unnecessary and harmful. I request that OMB not finalize proposed section 200.421.