Comment from S M
S MOpposeAcademic
Summary: A neonatologist and clinical researcher expresses opposition to the proposed rules, citing concerns over the politicization of funding decisions and the potential for delays in the grant process. They also argue that the restrictions on journal subscriptions and publication costs will create significant barriers to disseminating research and maintaining open access.
I am a neonatologist and clinical researcher and am the principal investigator on several NIH grants related to the effects of prenatal exposures on brain development and later development/behavior in children. This comment reflects my own personal views and not the views of my employer.
I have several concerns about the proposed rules. I am concerned about the potential politicization of funding decisions under §200.205. Political review could reduce the perception that grants are awarded primarily on technical merit and peer review. NIH funding is already difficult and uncertain with prolonged timelines between grant submission and funding decisions. An additional review layer could delay funding decisions and create uncertainty for applicants. I am also concerned about §200.454 (journal subscriptions are not allowable under the new rule) and §200.461 (publication costs are not allowable). These 2 rules will create barriers to disseminating research. NIH grants now require immediate open access for scientific articles that are published using NIH funds. This costs thousands of dollars. If NIH grants now do not allow NIH funds to be paid using NIH grant fees, I'm not sure how articles are going to get published at all.
Also, if open-access publication becomes harder to fund, research findings may be less widely available and transparency will decrease. I urge OMB to not finalize any of these rules.