Comment from John Doe
John DoeOpposeAcademic
Summary: A PhD student at Ohio State University argues that the proposed regulations would allow non-expert political appointees to make funding decisions, potentially wasting federal dollars on sub-optimal research. The commenter also expresses concern that prohibitions on DEI/gender ideologies would hinder stratified random control trials and that restrictions on foreign collaboration would isolate American scientists from global innovation.
I am a 4th year PhD Student in Microbiology at Ohio State funded through National Science Foundation grants. I am specifically concerned about provision §200.205. As I understand it, this section would put the decision of a non-expert, political appointee over those of qualified expert scientists on which grants receive the opportunity for funding.
There have been numerous breakthroughs in microbiology that start from very basic science, which is required to make meaningful discoveries that greatly improve human, earth, and animal health, as well as provide economic innovation. In microbiome science specifically, the subfield I study, there is a lot of noise and hype around wellness and supplements (pre and probiotics). Without the hard science behind it, it's hard to know what supplements actually work and which are just placebo (or worse, actually cause harm!). We scientists need grant funding to figure out how microbes work in our bodies, and require experts to determine which grant proposals relate to microbiome science will actually help us determine signal from noise. Without expert knowledge, political appointees will not be able to make the best decisions on which grants to fund, and will likely end up wasting more federal dollars on sub-optimal proposals, or none at all, that take away from the projects that may lead to the next economic innovation or health breakthrough in microbiome science.
Secondly, I am concerned strict prohibitions of DEI and gender ideologies from research (section §200.300) will impair scientists ability to set up stratified random control trials. It is well established that drugs and microbiomes behave differently in different people, and to ensure the conclusions we are making from our science are generalizable to all people, or so that we know in which groups certain methods work while others don't, it's important to account for these variables in scientific studies.
Third, the prohibition of foreign collaboration (§200.220) and conference attendance pre-approval (§200.432) would severely inhibit our ability as American scientists to make the next big discovery. For example, the lab I work in and the projects I work on would not exist without our foreign collaborators in France, and our lab wouldn't exist without the bright minds from all over the globe who have come to our group to carry out research. Furthermore, the ability to share our science and get feedback from global audiences dramatically improves the robustness and creativity of our country's research. Without being able to "export" and share our science with the rest of the world via collaboration and conference attendance, we essentially insulate ourselves to the discoveries being made, and remove the emergent and multiplicative properties of collaborative research. While the rest of the world collaborates, we would be left behind.
In conclusion, I urge OMB to remove this provision and to let experts decide what is worth funding, to not regulate and enforce sweeping bans on ideologies that closely impact science (DEI and gender), and to not regulate collaboration.