Comment from Ellie Browne

The Office of Management and Budget ,I am a PhD student and researcher at Yale University who receives funding from the National Institutes of Health. I perform cutting-edge work at the interface of the gut microbiome, nutrition, and cancer; our work is at the forefront of understanding and curing immune and metabolic disease. I strongly believe the OMB should withdraw the proposed rule. (§200.202), the domestic-first framework, and (§200.220), restrictions on international collaboration, would paradoxically set the United States far behind our competitors in research. Our current research infrastructure relies heavily on drawing talent and collaborations from other countries, including adversaries like China. Many of my collaborators are Chinese nationals; like me, they are only interested in advancing our understanding of human health. There is no application of our work together that would disproportionately advantage the US or China; it only serves to advance humanity's collective understanding of our biology. Limiting international collaboration would only serve to set the US dangerously behind. (§200.205), limiting the authority of the peer review process and putting more power in the hands of political appointees, would hamstring science funding for important problems. Unfortunately, many important scientific problems bear rhetorical similarity to politically controversial topics. For example, research on the gut microbiome often refers to "diversity" to describe the variation of bacterial and fungal species inhabiting humans; if a busy politician were to skim a microbiology grant referencing "diversity," they may not have enough time to discern that this project actually has nothing to do with race, gender, sexuality, or any other social category. The current peer review process enables scientists with enough time to read grants to accurately assess their contents. Further, science is frankly difficult to understand. It requires several years of training in a specific field to even begin to understand a research paper, and several more years to provide valuable input as to its merits and flaws. As a chemical microbiologist with a master's degree and several publications, I would not feel confident in my ability to meaningfully assess grants in loosely related fields, such as microbial ecology or synthetic chemistry. Taking funding decisions out of the hands of specialists will prevent meaningful assessment of grants, thereby funding unimportant projects and leaving important projects unfunded. (§200.300), political restrictions on grants, and (§200.340), the termination at any time of research grants contrary to "the national interest," would raise the same problems I outline regarding (§200.205). (§200.300) raises additional issues: better understanding DEI, gender, and transition is essential to effective legislation of these issues. Simply cutting funding to controversial topics is effectively burying our head in the sand. (§200.340) raises additional issues as well: labs budget based on assuming continuing funding, and worthwhile experiments often take years to execute. If grants are able to be suddenly terminated, large, long-term experiments may be forced to halt; this could waste untold amounts of money with inconclusive results, and in the case of research involving animals, innocent lives. Ellie Browne [ ]