Comment from Jeremy Wolfe
Jeremy WolfeOpposeAcademic
Summary: Dr. Jeremy M. Wolfe, a professor at Harvard Medical School, opposes the proposed regulation because it would prevent researchers from using grant funds for conferences that were not explicitly approved at the time of the award. He argues that the rule is impractical for emerging meetings or relevant topics discovered during research and suggests that existing peer-review processes are sufficient to manage travel costs.
I am writing to raise concerns about 200.432 that states: “The costs for attending conferences are allowable only if participation in the conference is expressly approved by the Federal agency and included in the terms and conditions of the Federal award.”
There are at least two reasons why this is problematic.
1)If a new meeting arises (e.g. a new society is founded or a special interest group decides to have a meeting), it would be impossible to use grant funds to pay for costs.
2)Even for existing meetings, the relevance of grant-funded work to that meeting might not be obvious at the time that the grant was approved. As an example, I have a colleague doing grant-funded work on human-AI interaction. Their work turns out to be very relevant to issue in medical imaging though this was not their original topic of interest. I suggested that they come to the meeting of the Medical Image Perception Society. That would not be possible under the proposed rule.
I have sat on NIH study section where we could easily see and comment on travel lines in budgets. Between peer-review and agency management, it is practical to avoid excessive travel spending. The proposed regulation is the wrong solution to a perceived problem.
Jeremy M Wolfe, PhD
Professor of Ophthalmology & Radiology,
Harvard Medical School
Visual Attention Lab
Department of Surgery
Brigham & Women's Hospital
900 Commonwealth Ave
3rd Floor
Boston, 02215
Phone: 617-851-1166
Fax: 617-768-8816
Best email: jwolfe@bwh.harvard.edu
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URL: search.bwh.harvard.edu