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 provisions: [200.205] Federal agency merit review of proposals; [200.340] Termination and suspension; [200.202] Program planning and design; [200.206] Federal agency review of risk posed by applicants; [200.220] Prohibition of using Federal funds for covered foreign collaborations; [200.432] Conferences; [200.454] Memberships, subscriptions, and professional activity costs; [200.461] Publication and printing costs; [200.421] Advertising and public relations; [200.450] Lobbying; and [200.201] Use of grants, cooperative agreements, and contracts; fixed amount awards. Taken together, these provisions would weaken NIH peer review, politicize scientific funding decisions, destabilize ongoing awards, limit publication and dissemination, restrict scientific meetings and professional engagement, and discourage necessary collaboration. The result would be slower biomedical progress, reduced return on taxpayer investment, harm to trainees and early-career scientists, and diminished U.S. leadership in biomedical research. I respectfully request that OMB not finalize the provisions identified above.