Comment from John Roche

The proposed rule raises serious concerns about the independence of science and the future of biomedical and population-based research in the United States. Predictable, transparent and evidence-based approaches to funding are essential to maintaining the nations leadership in research and ensuring that communities continue to benefit from effective public health programs. Policies that undermine independence or shift decisions away from established scientific and public health expertise risk weakening the innovation and collaboration needed to meet current and future health challenges. For decades, federally supported work has driven scientific innovation, improved health outcomes and helped deliver lifesaving programs in communities across the country and around the globe. These advances are possible because of strong, merit-based processes grounded in independent, expert review. Federal grants and cooperative agreements support a wide range of work across biomedical research and community-based health programs, and abrupt changes that create uncertainty or introduce new barriers threaten progress toward new discoveries to advance health and hope for everyone, everywhere. Federal grants would now be approved by political appointees who would contact universities and other institutions and asked them to change the nature of their work in order to more closely align with the Presidents agenda making funding subject to culture-war politics, not science and research. Agencies would now be able to terminate grants at any time if they no longer align with agency priorities or current administration policy. Previously, grants could only be canceled due to significant issues like fraud or mismanagement. This is significant when combined with OMBs proposal to discourage awards that give recipients more flexibility, while pushing to lock them into multi-year commitments. The combination allows the government to lock-in projects that are aligned with agency priorities while retaining a way to terminate them if political priorities change. The document seems to suggest that only studies that can be replicated would qualify for federal grants. Certain scientific activities, like observations of astronomical or weather events, and acknowledgement of sex non-binaries that is incompatible with studying human development are inherently not replicable. While the regulation prohibits viewpoint discrimination or discrimination based on political views, it also singles out specific topics, like disparate impact liability, as prohibited from receiving federal awards. It also expressly removes language that federal awards should support the public welfare and the environment. The revised regulation severely restricts the extent to which foreign organizations may be funded by the U.S. government, adopting what it calls a domestic first framework. The language appears to conflict with carve-outs for science in the CHIPS and Science Act, which expressly permitted research projects that involve reciprocal exchanges of information. The document also suggests that awardees should not work with organizations that also work with foreign adversaries, which would generally prevent cooperation with almost all of Americas allies and major international organizations like the World Meteorological Organization (aka the folks who coordinate global weather forecasting) and CERN (where US scientists collaborate on the worlds largest particle collider). The proposed rule takes aim at DEI, defining it broadly as unlawful discrimination. This weaponizes civil rights language against the very communities who have been subject to discrimination. Research focused on racial equity, health disparities, climate justice face severe scrutiny or outright elimination.