Comment from Jordan Sill

To the Office of Management and Budget: I am an Assistant Professor of Pediatric Cardiology and an early-career physician-scientist whose research aims to prevent cardiovascular disease in children at high cardiometabolic risk. I write to oppose the proposed Regulation for Federal Financial Assistance and to urge OMB not to finalize it. My professional life is a direct illustration of why this rule concerns me. I am currently developing an NIH proposals, proposals that are judged by independent experts on scientific merit. The proposed rule undermines that premise in ways that would reshape my work and my field: Requiring senior political appointees to conduct a "pre-issuance review," and directing that discretionary awards "demonstrably advance the President's policy priorities," inserts political judgment into decisions that should turn on rigor and public health value. Reducing peer review to "advisory" status means the expert evaluation that has long anchored federal science could be overridden, so that scientific merit is no longer the deciding factor in what gets funded. For an investigator at my stage, whose research questions are evaluated against established methodological standards, that is a fundamental shift. The expanded authority to terminate or suspend active grants when they no longer align with shifting agency priorities introduces exactly the kind of unpredictability that disrupts discovery. Cardiovascular research in youth depends on multi-year, prospectively designed studies; cohorts are followed over time, and findings accrue only if funding is stable across the full study period. A mid-stream termination does not merely pause that work, it can render years of data collection and participant commitment unrecoverable. Early-career scientists, who cannot absorb that risk, are precisely the people most likely to be pushed out of research careers as a result. Restricting the use of grant funds for publication costs threatens to leave important findings unshared. Disseminating results, including in open-access venues, is how research reaches the clinicians and families who can act on it; limiting that defeats the purpose of having funded the work at all. And an overly broad prohibition on international collaboration would sever the partnerships that advance science across borders, isolating U.S. researchers from the global scientific community. Taken together, these changes inject political considerations into a system that should be governed by independent expert review, create uncertainty that will delay or derail meaningful scientific work, and threaten the United States' standing as the global leader in biomedical science. I respectfully urge OMB not to finalize the proposed rule. Sincerely, Jordan Sill, MD, MS Assistant Professor of Pediatric Cardiology