Comment from Kent Lloyd
Kent LloydOpposeAcademic
Summary: A biomedical researcher argues that the proposed revisions to 2 CFR part 200 would disrupt NIH-funded research by replacing scientific merit with administrative criteria and creating unnecessary rigidity. They specifically oppose the prohibition of fixed amount awards, stating that such flexibility is necessary to tailor funding to specific scientific milestones and reduce administrative burdens.
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.
[200.201] Use of grants, cooperative agreements, and contracts; fixed amount awards.
Proposed section 200.201 would prohibit fixed amount awards unless otherwise authorized by federal statute.
This provision would cause concrete harm because different biomedical research activities require different funding structures. Fixed amount mechanisms can reduce administrative burden and support defined milestones, pilot projects, training activities, infrastructure work, or collaborative components where the scientific deliverable is clear. Eliminating this flexibility across federal awards would reduce NIH’s ability to tailor funding instruments to the scientific and administrative needs of particular programs.
For my research environment, unnecessary administrative rigidity diverts time and resources away from science. NIH and other research agencies should retain the ability to use appropriate award structures, with safeguards, when those structures improve efficiency and accountability.
I request that OMB not finalize proposed section 200.201.