Comment from Kent Lloyd

I am a biomedical researcher whose work depends on NIH-funded research, rigorous scientific peer review, publication of results, participation in scientific meetings, collaboration with specialized experts, and the ability to train and sustain a research workforce. My research is part of the biomedical research enterprise that advances understanding of human and animal health, improves disease models, supports development and validation of new approach methodologies, and contributes to future therapies, diagnostics, and public health interventions. The proposed revisions to 2 CFR part 200 would substantially disrupt NIH-funded biomedical research. Several provisions would replace scientific merit review with political or administrative criteria, create uncertainty around ongoing awards, limit dissemination of research findings, and impose case-by-case prior approval requirements that are incompatible with the pace and structure of modern science. I respectfully request that OMB not finalize the following provision. [200.340] Termination and suspension. Proposed section 200.340 would allow agencies to terminate an award if the agency determines that the award no longer effectuates program goals, agency priorities, or the national interest “as they exist at the time of termination.” This provision would cause concrete harm because biomedical research cannot be conducted responsibly under a system in which a multi-year award can be terminated based on changing priorities after the award has been made. NIH-funded projects require long-term planning, hiring, acquisition of animals or biological materials, maintenance of colonies and specialized models, longitudinal data collection, specialized equipment, core facility use, trainee support, and collaboration across institutions. Sudden termination would waste taxpayer dollars already invested, strand trainees and staff, interrupt ongoing experiments, compromise animal welfare planning, and prevent the generation of interpretable results. For my research, stability of award terms is essential. Biomedical experiments often cannot simply be stopped and restarted without losing cohorts, timelines, statistical power, or years of accumulated work. This provision would make it harder to recruit and retain staff, plan experiments, enter collaborations, or responsibly steward NIH funds. I request that OMB not finalize proposed section 200.340.