Comment from Gulden Karakok

[200.432] [200.454] [200.461]. I am writing to oppose the proposed restrictions on conference attendance (§ 200.432), journal subscriptions (§ 200.454), and open-access publication fees (§ 200.461). I am a faculty member at a regional, Research 2 (R2) university where I teach full-time and direct an NSF-funded research program integrating eye-tracking technology to combat math anxiety. My project is currently in its no-cost extension (NCE) stage. The NCE year is uniquely dedicated to final data analysis, synthesizing results, and widely distributing our findings to the broader educational community. Because this work is highly interdisciplinary, presenting our final results at diverse scientific conferences is an absolute necessity for peer validation, not an administrative luxury. Forcing teaching-heavy faculty to navigate an aggressive, case-by-case prior written approval process for conference travel adds an unmanageable administrative burden that will disproportionately harm regional institutions lacking large administrative compliance teams. Furthermore, making article processing charges (APCs) presumptively unallowable heavily penalizes regional universities during the final closeout of a federal award. My undergraduate and graduate students rely on open-access publications to engage with cutting-edge literature. More importantly, for our math anxiety interventions to have real-world utility, our final data must be immediately and freely accessible to local public school teachers, school psychologists, and regional administrators who lack expensive institutional journal subscriptions. Stripping open-access funding from NSF grants—particularly during an NCE year meant for final dissemination—creates an unfunded mandate that actively blocks local communities from benefiting from taxpayer-funded scientific discoveries. I urge OMB to maintain the standard allowability of publication, subscription, and conference costs.