Comment from Christine Fagnant-Sperati

The proposed rule will negatively impact my personal life, my professional capacity to accomplish my work, and the United States' general ability to engage in sound science. I am a research scientist and I have worked at a large public institution for 17 years in the field of public health (specifically, infectious disease research). My position has been funded through NIH funds continuously since 2020. I have 2 small children at home who I provide for. Proposed rule change §200.340 that allows grants to be terminated at any point would create dramatic instability to my personal life, as I would no longer be able to reliably maintain my employment. Realistically, I would likely leave my current position as I cannot afford to unexpectedly lose my job at the whim of a government employee. As the primary caregiver and breadwinner for my children, I need to maintain my employment. Proposed rule change §200.461 that would prohibit use of federal funds for publication of research articles would negatively impact my ability to conduct sound science. Publishing scientific work in peer-reviewed journals (to provide guardrails that we are conducting sound science) is critical to share our scientific findings and advancing the scientific field. This allows the US Government to easily access our work and apply our research findings. Having other scientists publish their work is similarly important, as I regularly read journal articles to make sure I am staying on top of the most recent scientific discoveries. If we lose the ability to use our grant funds to publish, this will impact our ability to publish regularly. Finally, my research for the past 15 years has all been done in collaboration with scientists from foreign institutions, including individuals from India, Kenya, Mozambique, Bangladesh, South Africa, Peru, and Ecuador. These scientists bring their own unique and local perspectives to the science that we do. By allowing these scientists to contribute to our collaborations, we are actually improving our national security by improving public health and global health. These are not bad actors - they are individuals who care about the well-being and health of people globally. Global health impacts health in the United States, as we saw with the COVID-19 pandemic. We need to keep foreign collaborations open, and I think provision §200.220 would severely hamper that potential. I strongly urge you not to adopt the proposed rule change.