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. [200.220] Prohibition of using Federal funds for covered foreign collaborations. Proposed section 200.220 would prohibit federal funds from supporting bilateral or multilateral collaborations, agreements, programs, or activities with covered foreign countries or covered foreign entities, with exceptions requiring senior agency approval. This provision would cause concrete harm because biomedical research is global. Infectious disease, genetics, toxicology, comparative medicine, therapeutics, rare disease research, model organism research, and public health research often require international data, reagents, expertise, or study populations. Existing laws and agency policies already address research security, export controls, sanctions, foreign influence, and disclosure obligations. A broad government-wide prohibition risks blocking legitimate scientific collaborations that are necessary to answer important biomedical questions. For my work, even uncertainty about whether a collaboration, dataset, biological resource, conference interaction, or technical exchange might fall within the rule would discourage collaboration and slow research. The result would not be better security; it would be less science, less transparency, and fewer opportunities for U.S. researchers to lead internationally important biomedical advances. I request that OMB not finalize proposed section 200.220.