Comment on OMB-2026-0034-0001
Society for Vascular SurgeryOpposeAdvocacy
Summary: The Society for Vascular Surgery (SVS) opposes the proposed revisions to 2 CFR Part 200, arguing that they undermine scientific peer review, restrict international research collaboration, and threaten the stability of long-term medical research. They specifically express concern that political appointees would override expert scientific judgment and that new restrictions on publication costs and project termination would harm patient care and research transparency.
The Society for Vascular Surgery (SVS) submits the attached comment letter in strong opposition to the proposed revisions to 2 CFR Part 200. Our comments focus on four provisions of particular concern:
•Section 200.205(b), which would require senior political appointees to conduct pre-issuance review of discretionary federal grants and would reduce scientific peer review to an advisory role rather than the primary basis for funding decisions;
•Section 200.220, which would impose new government-wide restrictions on international research collaboration;
•Section 200.340 which proposes the ability to terminate ongoing projects found to be inconsistent with program goals or agency priorities; and
•Section 200.461, which would make publication and journal costs largely unallowable absent statutory requirement or agency pre-approval.
SVS is the leading medical society representing vascular surgeons and other vascular care specialists across the United States. Our members both compete for federal research funding — primarily through the National Institutes of Health — and treat the patients whose care depends directly on the discoveries that Federal research funding makes possible: patients with peripheral artery disease, aortic aneurysms, carotid disease, venous disease, and limb-threatening ischemia, all conditions that can be life threatening. We write from both vantage points.