Comment from Josh Dubnau

I am a Professor in the Department of Anesthesiology and the Department of Neurobiology and Behavior at Stony Brook University. I have had continuous NIH funding for almost 25 years. My research has been funded by NIMH, NINDS and NIA. I also was the recipient of a Transformative R01. My research focus is on fundamental mechanisms that underlie neurodegenerative disorders such as Alzheimer’s disease, frontotemporal dementia and amyotrophic lateral sclerosis. My lab’s work has been at the forefront of proposing and developing a novel hypothesis that has been impactful in development of ongoing clinical trials for several neurodegenerative disorders. My lab currently holds two R01 awards from NIA. I also am a co-PI on an R01 with a colleague at Texas A&M. These NIH awards currently support the efforts of 5 PhD candidates, 4 postoctoral researchers and one technician. I have grave concerns about a number of the proposed changes to federal regulations that govern research grants. Let me say up front that the proposed rule changes are an existential threat to research. For decades, the USA has led in research across multiple disciplines. This excellence in USA based research is a tremendous economic value, it has led to incredible innovation including, but not limited to medicine. The primary driver of research excellence in this country is academic research, supported by government funded research grants. The proposed rule changes will decimate this enterprise. If enacted, research in this country will wither. I specifically wish to comment on the following sections: 1.§200.205 — Political appointee review of grants This would destroy the rigor of government funded research. Politics has no place in the decisions on which grant applications should be funded. This proposal is the stuff of a totalitarian regime that is so afraid of truth that they will undermine our entire society for political means. Grants should be prioritized based on peer review, without any interference from politics. Peer review is a rigorous, evaluative process by experts who score proposals based on their merits. Political appointees lack the expertise, and instead serve a political agenda. 2.§200.340 — Grant termination This proposed rule change would allow already funded grants to be terminated at the discretion of federal funding agencies, presumably at the will of political appointees. This would be a terrible mistake. Ending awards mid stream would wast the months spent training the team and developing a pipeline for successful experiments. Typically it can take more than a year until the team is producing new and exciting data and then can take another year or more until those data reach a satisfactory conclusion sufficient to publish. Grants that are ongoing with a good faith effort to achieve the stated goals should never be terminated. 3.§200.432 — Conference attendance pre-approval Researchers must be enabled to attend international conferences so that we can learn about new developments and share our own findings. Requiring pre-approval for any conference not listed in the initial award is an onerous bureaucratic obstacle that serves no purpose. 4.§200.454 — Journal subscriptions (now unallowable) I cannot think of any reason why the government would restrict scientists’ ability to access the published record of their field. There are aspects of journal subscription fee structures that need reform, but this isn't reform. 5.§200.461 — Publication costs (now unallowable) This rule isn’t reform of what is broken about the publication industry, it is just a needless obstacle to dissemination of research to the public. 6.§200.300 — DEI and gender ideology prohibitions This is another example of the politicization of science. Let experts evaluate proposals and fund the proposals with the best review outcomes. 7.§200.218 — Disparate-impact research banned Without research into how government decisions impact various constituencies, it is impossible to craft government policies that serve the taxpayers. How would we know which populations to target public health initiatives unless we study this? 8.§200.220 — Foreign collaboration prohibition Multi and cross disciplinary science requires collaboration, often with international colleagues. This rule would stifle innovation. 9.§200.202 — Programs must align with administration priorities. Federally funded research must align with the needs of society, not the political agenda of any one administration. The politicization of science that occurs in totalitarian regimes has always undermined research - e.g. the soviet union and Nazi Germany. 10.§200.204 — Grant competitions can be exempted from public notice This would instill a lack of transparency and accountability that would further undeminre research and our democracy. Josh Dubnau Professor Stony Brook University School of Medicine.