Comment from S S

S SOpposeAcademic
Summary: A physician-scientist and NIH-funded investigator at an academic medical institution opposes the proposed regulations, arguing they would replace merit-based peer review with political oversight. The commenter expresses concern that these changes would allow for the termination of active grants based on shifting political priorities, potentially wasting taxpayer investment and harming patient care.
I am submitting this comment as a scientist in an academic medical institution in Texas. I am a physician-scientist and NIH-funded investigator who has spent my career conducting translational neuroscience research while caring for patients with severe neurological and psychiatric disorders. My laboratory includes medical students, graduate students, postdoctoral fellows, research staff, and clinical collaborators working to develop novel therapies for Parkinson's disease, treatment-resistant depression, obsessive-compulsive disorder, and suicidality. I write to oppose proposed Sections 200.205, 200.340, and 200.202 because they would replace scientific judgment with political oversight, permit termination of active grants for political reasons, and require federal research priorities to align with changing White House priorities rather than scientific merit and Congressional intent. These changes threaten the foundation of the U.S. scientific enterprise. Section 200.205 would allow political appointees to override the expert peer-review process. America's leadership in biomedical research has been built on funding decisions made by scientists with the expertise to evaluate innovation, rigor, feasibility, and impact. While peer review is not perfect, it is objective, transparent, and accountable. Political review is inherently subjective and vulnerable to changing administrations and ideological priorities. Transformative discoveries, including deep brain stimulation, which now benefits patients with Parkinson's disease, epilepsy, dystonia, and OCD, were made possible because scientists were free to pursue innovative ideas that were not necessarily aligned with short-term political priorities. Section 200.340 would allow active grants to be terminated based on political considerations rather than scientific or administrative performance. Biomedical research often spans many years. Laboratories hire personnel, recruit patients, purchase specialized equipment, establish collaborations, and commit substantial institutional resources with the expectation that awarded grants will continue as long as investigators meet their obligations. If grants can be terminated because political priorities change, ongoing clinical studies may be abandoned, years of longitudinal data lost, trainees displaced, and taxpayer investments wasted. In my own laboratory, termination of an active grant would directly affect patients participating in research, highly trained staff, graduate students, postdoctoral fellows, and early-career investigators whose careers depend upon completing these projects. Scientific research cannot simply be paused and restarted without permanent loss. Section 200.202 would require research programs to align with White House priorities rather than scientific opportunity and Congressional intent. Many of the most important advances in medicine arose from investigator-initiated basic science whose eventual applications could not have been predicted. My own work combines neuroscience, engineering, and clinical medicine to develop neuromodulation therapies for devastating neurological and psychiatric disorders. Progress depends on asking fundamental scientific questions whose importance often becomes apparent only years later. If research funding becomes contingent upon political priorities that change every election cycle, investigators will be discouraged from pursuing innovative, high-risk ideas that have historically produced the greatest breakthroughs. Taken together, these provisions would fundamentally change why the United States has become the world's leader in biomedical research. For decades, our success has rested on stable federal investment, rigorous peer review, scientific independence, and the confidence that meritorious research will be evaluated on scientific rather than political grounds. These proposed changes would erode that confidence, discourage young investigators from pursuing research careers, weaken international collaborations, and make the United States a less attractive place to conduct cutting-edge science. Once scientific leadership is lost, rebuilding it takes decades. As both a physician and scientist, I am especially concerned that patients will ultimately bear the greatest cost. Every delayed discovery represents delayed treatments for individuals living with devastating neurological, psychiatric, oncologic, cardiovascular, and infectious diseases. For these reasons, I respectfully request that Sections 200.205, 200.340, and 200.202 not be finalized. I further urge OMB to withdraw these provisions and preserve the longstanding principles of merit-based peer review, scientific independence, and stable federal support that have made the United States the global leader in biomedical research. Thank you for your consideration.

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