Comment from Felix Rivera-Mariani

I am submitting this comment in my personal capacity as a scientist, educator, mentor, and public-health researcher. I oppose the proposed revisions as currently written because they would weaken merit-based grantmaking, destabilize ongoing research, and create uncertainty for students, communities, universities, public-health agencies, and nonprofit partners that depend on federal financial assistance. [§ 200.205 — Merit Review and Peer Review] OMB should preserve independent expert peer review as the central mechanism for evaluating scientific and public-health merit. Federal grants should be judged through transparent criteria, relevant expertise, methodological rigor, feasibility, public benefit, and statutory purpose—not shifting political priorities. Senior agency officials should retain oversight for legality, compliance, and stewardship of taxpayer funds, but they should not override rigorous expert review without a clear, written, evidence-based, and appealable rationale. Independent peer review is especially important for research addressing environmental exposures, respiratory health, immune risk, infectious disease surveillance, climate-related hazards, and health disparities. These areas involve complex datasets, longitudinal study designs, community partnerships, and technical methods that require specialized expertise. If expert review becomes merely advisory, federal grantmaking risks becoming less scientifically sound, less transparent, and less trusted by the public. [§ 200.340 — Termination and Suspension] OMB should remove or substantially narrow the proposed discretionary termination authority. Federal awards should not be cancellable simply because agency priorities or interpretations of the “national interest” change after an award is made. When recipients are meeting approved milestones, complying with award terms, and conducting work consistent with the original funding opportunity, they should have reasonable reliance protection. Mid-project termination can disrupt student stipends, graduate training, community partnerships, data-use agreements, laboratory workflows, clinical collaborations, and public-health deliverables. It also creates financial and operational risk for institutions that hire staff, establish subawards, maintain data infrastructure, and meet human-subjects and reporting obligations based on award terms. Termination should be limited to objective grounds such as noncompliance, fraud, inability to complete the project, statutory conflict, or documented failure to meet award terms. Any termination should include written justification, opportunity to cure when appropriate, due process, and recovery of allowable closeout and reliance costs. [§ 200.202 — Research and Development Awards] OMB should avoid restrictions that unnecessarily weaken scientific collaboration. Many public-health and environmental-health questions require place-based, cross-jurisdictional, and sometimes international collaboration. Air pollution, bioaerosols, infectious diseases, climate-related hazards, and respiratory-health risks do not stop at administrative boundaries. Federal agencies should be able to support collaborations when they are scientifically justified, ethically governed, legally compliant, and necessary to answer the research question. As a faculty mentor and researcher, I am also concerned that the proposed rule would harm students and early-career scientists, especially those from smaller institutions and underserved communities. Federal grants support more than data collection; they support training, mentorship, workforce development, reproducible data systems, and community translation. Uncertainty in award selection and continuation will discourage students from entering research fields the nation urgently needs, including environmental health, immunology, data science, epidemiology, and climate-health research. I respectfully request that OMB not finalize the proposed rule as written. OMB should revise the regulation to preserve independent expert peer review, require transparent written justification for departures from peer-review recommendations, limit termination authority to objective and appealable circumstances, protect recipients’ reliance interests, and maintain lawful support for environmental health, health disparities, public-health preparedness, and community risk-reduction research. Federal grantmaking should remain rigorous, transparent, accountable, and grounded in public benefit. I urge OMB to protect merit-based review, scientific integrity, and the stability required for research and public-health programs to serve communities effectively. Respectfully, Félix E. Rivera-Mariani, PhD, FAAAAI Associate Professor of Biochemistry, Microbiology, and Immunology Submitted in personal capacity