Comment from Ilya Levental

I am a biomedical research scientist, Professor of Biophysics, and a research group leader at the University of Virginia, one of America’s flagship public research universities. My lab has established a productive and impactful research program over the past 15 years and my lab is now among the world leaders in our field. Our research has been supported by the NIH for decades and I have served in several advisory roles for the NIH and international scientific societies. I am commenting to forcefully push back against many of the proposed “Regulation for Federal Financial Assistance” rules by the OMB, whose implementation is certain to cause will cause irreparable harm to the American scientific enterprise, which is a crown jewel of American influence, soft power, and has provided innumerable benefits to Americans over many decades. Many of the proposed changes are detrimental, but below I will highlight the most damaging and directly relevant to my work: §200.205 and §200.340 will lead to grant approval by political appointees rather than scientific peers. The fact that the merit of scientific grants is evaluated by scientists rather than bureaucrats or political appointees is the SINGLE BEST ASPECT of American science. Having been involved in all its aspects, I know without hesitation that peer review of federal grants is extremely rigorous, fair, thoughtful, and clearly the best way to accomplish the difficult task of picking out the most meritorious and potentially impactful science for funding. Turning this over to government officials will inevitably reduce the quality of American science, as well as public trust. §200.432, §200.454, and §200.461 will massively disrupt the primary mechanisms by which scientific findings are shared with the wider scientific community and the public. Scientific publications and conferences are critical venues for communication and collaboration, and such communication is central to scientists work. Science done in the dark is not worth doing, results and advances are only valuable if they are communicated to the community. §200.220 increases the regulatory burden on international collaboration as to make it is effectively a ban. It is nearly impossible to do impactful science without broad collaboration, and it makes no sense isolate American scientists from the freely available expertise of international collaborators. The rules against international collaboration has already led me to eliminate a promising research program because our partner is an American scientist working at the University of Toronto. More generally, many of the proposed rules will add onerous bureaucratic oversight, causing pointless disruption and inefficiency. They will have the opposite effect to their proposed cost savings and efficiency, rather adding layers of friction and bureaucracy, preventing scientists from focusing their efforts on advancing knowledge, American economic strength, and human health. In closing, I urge OMB to withdraw these provisions, which would dramatically harm American science.