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. [200.202] Program planning and design. Proposed section 200.202 would require federal programs to align with administration policies and priorities and would impose a “domestic-first framework” for research and development awards involving international elements. This provision would cause concrete harm because NIH-funded biomedical research should be designed around scientific opportunity, disease burden, public health need, and expert assessment of feasibility and rigor. The best biomedical science often depends on access to unique expertise, patient populations, animal models, data resources, reagents, facilities, or scientific networks that may not be available within a single institution or country. A rigid domestic-first framework would delay or prevent scientifically necessary collaborations, even when they directly advance U.S. health and scientific leadership. My research depends on the ability of NIH and peer reviewers to evaluate whether a collaboration, resource, model, dataset, or technical method is scientifically justified. Requiring programs to align with current administration priorities risks reshaping biomedical research around short-term political objectives rather than long-term scientific and public health needs. I request that OMB not finalize proposed section 200.202.