Comment from Gulden Karakok

[200.205] I am writing to express my strong opposition to the proposed revisions to 2 CFR § 200.205, which require a pre-issuance political review for all discretionary federal grants. As a professor at a regional, Research 2 (R2) university serving local students, I teach full-time in a department that prepares future elementary educators, mathematics teachers, mathematicians, computer scientists, and statisticians. Alongside my heavy teaching load, I am the primary investigator on an active National Science Foundation (NSF) grant that is currently in the critical no-cost extension (NCE) stage. This funding supports cutting-edge, interdisciplinary research using eye-tracking technology to develop interventions for reducing math anxiety—a widespread educational issue that acts as a major bottleneck in the American STEM workforce pipeline. The NSF's gold-standard merit-review process relies on rigorous, independent peer evaluations assessing both Intellectual Merit and Broader Impacts. This system ensures taxpayer money funds objective, high-potential scientific innovation. Relegating this expert panel consensus to "advisory only" and giving final sign-off to senior political appointees introduces extreme instability, even for projects currently in extended or final operational phases. Regional R2 institutions lack massive institutional endowments to absorb sudden funding delays or administrative pauses caused by shifting political agendas. For an interdisciplinary project like mine—which requires seamless integration of technology and educational placement—such unpredictable oversight threatens to derail years of accumulated data and student interventions. Without a predictable, merit-driven federal ecosystem, high-impact regional research simply cannot survive. I strongly urge OMB to withdraw the proposed changes to § 200.205.