Comment from Kathryn Dewsbury-White
Kathryn Dewsbury-WhiteOpposeAdvocacy
Summary: A not-for-profit education association argues that the proposed regulation's "convenience terminations" are harmful to long-term research. They contend that these terms disrupt proof-of-concept research and prevent the federal government from accurately assessing the return on investment for awarded funds.
(200.340) Serving a not-for-profit education association, that relies on direct awards as well as collaborations with research institutions – our ability to contribute meaningful to the field is affected by the ability to engage in action research over a sufficient and predicable period. We most often participate in proof-of-concept research – which includes many variables and occurs over a period of time, to evaluate impact. Contract-style, “convenience terminations” are harmful to our ability to make appropriate use of the federal dollars awarded, cutting short the federal administration and public’s information about return on investment.