Comment from Alan Gaul

I am a postdoc at a large university, have been funded by multiple NSF grants, and I have published multiple peer-reviewed articles in high impact journals. I am concerned that the proposed changes to provision §200.461 are at odds with President Trump’s Executive Order (EO) 14303 Restoring Gold Standard Science. In EO 14303, President Trump writes that “science is facing a reproducibility crisis” and “Reproducibility, rigor, and unbiased peer review must be maintained.” It is clear that President Trump recognizes that unbiased peer review is the gold standard for maintaining scientific rigor and reproducibility when publishing research results. For instance, Section 3avii of EO 14303 mandates that Gold Standard Science be subject to unbiased peer review, implying that all Federal awards for scientific research should require awardees to submit their results to unbiased peer review. In Section 3B of EO 14303, President Trump orders the Director of the Office of Management and Budget to “update applicable agency policies” to “ensure that agency scientific activities are conducted in accordance with this order.” However, it is clear that the OMB Director did not read EO 14303 closely, as the proposed changes to provision §200.461 “make publication costs unallowable.” This proposed change prohibits spending Federal grant money on the existing mechanism for ensuring scientific results undergo unbiased peer review – publication in scientific journals – without proposing an adequate replacement. The proposed changes further state that “Publication costs are not inherently necessary to carry out the core programmatic objectives of most Federal awards.” However, this statement is at direct odds with EO 14303 mandating that Gold Standard Science should undergo peer review. The proposed changes to provision §200.461 should be rescinded, otherwise the Gold Standard Science that President Trump asks for cannot be achieved.