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. [200.450] Lobbying. Proposed section 200.450 would add broad restrictions on issue advocacy and public messaging that promotes or opposes a social, political, or public policy position unrelated to the statutory objectives or performance requirements of the federal award. This provision would cause concrete harm because the line between scientific communication and “public policy” messaging can be unclear in biomedical research. Scientists routinely explain the significance of federally funded research for public health, disease prevention, research infrastructure, animal and human health, data sharing, and evidence-based decision making. Researchers also communicate with policymakers, professional societies, patient groups, and the public about scientific evidence. My research depends on the ability to accurately communicate what the science shows and why it matters. Existing rules already prohibit using federal funds for lobbying. The proposed language is vague enough to chill legitimate scientific communication and public education, particularly in areas where biomedical findings may have policy implications. This would harm transparency and reduce the public benefit of NIH-funded research. I request that OMB not finalize proposed section 200.450.