Comment from Ian Boggero

[200.205, 200.340] To Whom it May Concern: Thank you for allowing to to comment on the proposed rule. I am an associate professor at the University of Kentucky College of Dentistry. My NIH-funded research focuses on developing and refining psychological interventions for chronic face pain. I am writing in my personal capacity to oppose the proposed revisions to sections 200.205 and 200.340 that would undermine the integrity of federal grant review processes and federal science agencies' ability to identify and fund impactful research. I am deeply concerned about Section 200.205 of the proposed rule change. Because many of the lines of research funded by NIH span 5 years or longer, they will by definition experience changes in administrations. If one political appointee decides that a project does not fit their priorities, and they are able to terminate the project, but a subsequent administration decides to re-fund it, this will lead to considerable waste and will slow scientific progress. Moreover, requiring grants to undergo review by a political appointee introduces the possibility for fraud and corruption into the system. This will hamper progress and erode public trust in the scientific process as it will necessarily make all science political by definition. This would be a great disservice to the country. If grants were terminated for political reasons, (section 200.340), it would instill fear in scientists and researchers throughout the country that their grant may be terminated at any time. This could have great personal and scientific repercussions. Many of the top researchers in the area would likely leave science altogether, which would significantly demolish the research infrastructure in the country. Many top scientists might leave to other countries which would not only be bad for science, but would also place the USA at a considerable disadvantage and confer a serious national security risk. In summary, this proposal would fundamentally and permanently alter the infrastructure that has made the USA the top science-producing country in the world.