Comment from Brian Storrie

Comments on OMB Proposed Rules, Regulation of Federal Financial Assistance, Federal Register, p.32198, Volume 91, No. 103, May 29, 2026 Brian Storrie, Ph.D., Professor Emeritus Department of Physiology and Cell Biology, University of Arkansas for Medical Sciences Overview: Most of the basic science funding and considerable portion of the clinical research funding comes from agencies of the federal government. Amongst there are the National Institutes of Health (NIH) and the National Science Foundation (NSF). Funding decisions by both these agencies is based upon rigorous review by highly qualified scientific peers and is subject to final approvals by agency program staff and scientific advisory boards which include lay people. Although there are tensions within this system, for example, over the balance between basic and applied or clinical research or how much of the assessment should be project based and how much should be investigator based. Irrespective of these tensions, the fundamental decision on ranking research proposals has been the considered judgement of peer review. This system places ranking in the hands of the people closest to the proposed work, its technical merit and its potential impact. The proposed OMB regulations the places the final ranking and the end decision in the hands of a senior political appointee. This choice would be a grave mistake and a long-term threat to the future health and prosperity of the citizens of this country. The proposed regulations affect nearly every aspect of the scientific process, including peer review as cited above, grant administration, conference attendance, scientific publishing, and participation in professional societies. Specifically, Shift of final authority on funding to senior political appointees – see above Require that each award advance the President’s policy priorities – The great danger here is freezing out investigator-initiated projects. The great advances that lead to biotech-based industries came from the unplanned outcomes of investigator-initiated research. Allow funding agencies to terminate active grants at any time and for any reason – Grants are a contract between the agency and the investigator. Progress is long term and builds from results. Making this subject to arbitrary cancellation destroys the whole element of partnership between agency and investigator that is essential to research progress. Prohibit federally funded collaborations with researchers in designated countries – The fundamental core of science supported by federal agencies such as the NIH and NSF becomes public domain upon its completion. Great thoughts can come from multiple places. Require agency pre-approval for attendance at scientific conferences – This strikes at the fundamental of free information exchange and codifies the assumption that all makes sense to do can be absolutely planned. Prohibit the use of federal grant funds for journal publication costs – It costs money to be a scientific journal. The dissemination of results is central aspect of doing science. Good science is not just the act of convincing yourself, but rather is the act of convincing reviewers and others. That requires publishing. That act involves costs that must be paid. In brief, the free exchange of outcomes from federally funded research has been the basis of partnership on which many industries have thrived and the welfare and health of the citizens of the United States of America have advanced. Do not destroy the goose that is laying the golden egg!