Comment from Benjamin Sanders

The Office of Management and Budget ,Good Afternoon,I am graduate worker in the Department of Neuroscience at Yale University School of Medicine, where I am completing my dissertation research on the molecular mechanisms of Alzheimer's disease and related neurodegenerative disorders (Parkinsons’s Disease, Amyotrophic Lateral Sclerosis). My research as a graduate worker is directly dependent on research grants administered by the federal government. I currently receive a fellowship from the National Institute on Aging at the National Institutes of Health under grant 1F31AG086008. Given my immediate stake in the integrity of the federal grant-making process, I am writing to express my firm opposition to the proposed revisions to 2 CFR Part 200 and to urge OMB to withdraw this proposed rule in its entirety.The proposed changes represent a significant threat to the independence and integrity of federally funded scientific research. They would replace merit-based & peer-reviewed science with politically directed grant-making, chill international scientific collaboration, and expose ongoing research projects (including my own) to arbitrary termination based on shifting political criteria rather than scientific value. These porposed changes would impose costs on American society that far exceed any potential administrative benefit. Alzheimer's disease alone is projected to cost the United States over one trillion dollars annually by 2050 (Alzheimer’s Association). The only path to reducing that burden is through rigorous, independent, federally funded research into prevention, early detection, and treatment. Politicizing the grant process that supports that research would delay or prevent discoveries that could reduce suffering for millions of Americans and their families. Additionally, the United States' economic leadership in the biotechnology, pharmaceutical, and medical device industries rests on the foundation of publicly funded basic research. Discoveries made in NIH-funded university laboratories have produced treatments and industries that employ hundreds of thousands of Americans. Undermining the independence and integrity of that research enterprise would, over time, erode the innovation pipeline on which those industries depend. The proposed rule would also accelerate an outflow of scientific talent. Canada, the United Kingdom, Germany, and increasingly China are actively recruiting American researchers who are no longer confident in the stability of federal research support. Early-career researchers like me are making career decisions right now. The message sent by this proposed rule is that the federal government does not value independent science, will not honor its funding commitments, and will direct research according to political criteria rather than scientific merit. The proposed 'domestic-first framework' under §200.202 would require federal agencies to justify any international element of a research program and to certify alignment with broadly defined 'national interest' criteria before permitting such elements to proceed. While I do not currently have active international collaborators on my NIA fellowship, the expectation from the field is to attend and present my work at conferences both domestic and international. These are not only opportunities to share research progress, but to foster cooperation and collaboration to advance research further in Alzheimer’s Disease and Alzheimer’s Disease Related Dementias. These national and international collaborations are essential to address this disease that affects 65 million Americans and is projected to grow to 82 million by 2050 (Alzheimer’s Association), and this doesn’t even include the global burden of the disease. The prevalence of this disease does not acknowledge borders, so why should American research be limited by a wall of bureaucracy? Many of the landmark genetic studies, including those that identified APOE4 and other major risk variants, have depended on large internationally pooled biobanks and cohort studies. Major clinical trials for Alzheimer's therapeutics also require patient populations and research infrastructure that no single country possesses. I strongly urge OMB to withdraw this proposed rule.Peer review exists precisely to ensure that funding decisions are made based on scientific rigor, methodological soundness, and potential impact, not ideology. Giving political appointees the discretion to override peer-review recommendations and explicitly requiring grant awards 'advance the President's policy priorities,’ as proposed in §200.205, shifts American scientific research away from that of merit-based awards. My own fellowship underwent rigorous evaluation by inde