Comment from J K

I am a scientist doing research and teaching cell and molecular neurobiology. I currently hold an NIH 15 grant for my research (and have received both NIH and NSF funding previously) investigating how signals from the gut and other tissues regulate neuronal signaling in different physiological conditions. This research can help to identify potential new therapeutic targets for various neurological and neurodegenerative conditions in which neuronal signaling balance is disrupted – an enormous disease burden in the U.S. I am writing to oppose Section 200.461, which would make grant funding for publication costs unallowable. Given the NIH requirements for making all publications and data freely accessible and given the high cost of all journal publication and especially open access publication, which can be several thousand dollars per manuscript, it would severely limit my ability to comply with these federal grant regulations. Thus, the impact of my research would be limited, as would my ability to obtain federal grants given the difficulty with getting my research published appropriately. This is true for research across the spectrum but particularly true for me as a faculty member at a primarily undergraduate institution where our research funds and particularly our publication funds are extremely limited. These limitations to my lab’s ability to publish and, by extension, to obtain additional federal funding not only limits our research contributions but also limits the training potential for my students who rely on publications as currency for getting into future graduate and professional training programs. If provision 200.461 is enacted, my ability to publish in the most relevant and accessible journals will be limited, preventing future grant funding, and harming my students’ opportunities for professional development and future training. This provision would harm not only my own lab and research, but multiple other labs at my institution who likewise have very limited funds for publication costs. I urge OMB to eliminate this provision and to maximize sharing of scientific information, which in turn maximizes the potential for scientific advancement.