Comment from Gloria Tavera

I am an early-career physician-scientist intestinal disease working to establish my first independent research program in the United States. I am writing to oppose this proposed rule, with particular concern for §200.205, §200.340, and §200.202(e). Independent peer review is the foundation on which young investigators build a career. My ability to compete for a first independent award depends on experts in my field judging my science on its merit and promise — not on whether a political appointee deems it aligned with an administration's priorities. §200.205 makes peer review advisory and places final authority with appointees who, in most cases, lack the specialized expertise to evaluate a given proposal. This does not improve oversight; it substitutes loyalty for merit at exactly the career stage when the system most needs to identify scientific talent rather than political fit. §200.340 compounds the harm. Research independence requires multi-year stability — to recruit staff, enroll patients, and pursue questions that take years to answer. A grant that can be terminated at any time "for convenience" is not a foundation anyone can build a career on. Faced with that uncertainty, talented young scientists will leave U.S. academic research for industry or for other countries that still offer stable, merit-based funding. I want to stay and do my work here. This rule makes that materially harder. §200.202(e)'s restrictions on international collaboration would further isolate U.S. researchers from the global networks that drive discovery and train the next generation. I urge OMB to withdraw or substantially revise this rule and to preserve independent scientific peer review as the basis for federal funding decisions. I also urge OMB to extend the 45-day comment period, which is far too short for changes of this scope. Respectfully, Dr. Gloria Tavera MD, PhD UCSF