Comment from Kelly Lozo

As a senior program manager at UCLA whose job it is to assist leading faculty secure and sustain NIH training programs, I write with serious concern regarding the OMB's proposed rule revising 2 C.F.R. Part 200 (Docket OMB-2026-0034, specifically: § 200.205 — Political pre-issuance review § 200.340 — Discretionary termination authority § 200.205 & § 200.300 — Training grants (T32, F31, F99) § 200.405 & § 200.432 — Publication costs and conference travel costs unallowable by default After careful review of the provisions identified below, I am requesting that OMB withdraw this rule entirely. It is difficult to overstate the significance of transforming the Uniform Guidance, a policy framework deliberately designed to be guidance, into binding federal regulation. Guidance can be updated as the research enterprise evolves; regulation locks in today's political priorities as permanent legal requirements. The research institutions, principal investigators, and scientific societies that depend on federal funding have built their compliance systems around the flexibility that guidance allows. Replacing that flexibility with rigid regulatory requirements will impose costs that fall disproportionately on those with the least capacity to absorb them: small liberal arts colleges, community-based research programs, and historically underrepresented institutions. The predictable consequence is not a more accountable research enterprise, it is a more concentrated one. This is the opposite of broadening participation. Federal training grants do not merely fund trainees, they fund the social and professional infrastructure of the scientific workforce: mentorship relationships, laboratory experiences, conference participation, professional network development, and exposure to the breadth of a scientific discipline. The proposed DEI restrictions (§ 200.300) and political pre-issuance review requirements (§ 200.205) create uncertainty about whether the components of training grants that serve these functions will survive regulatory scrutiny. The uncertainty itself is harmful: program directors cannot recruit trainees to a program whose future is in doubt. Federal research funding decisions have historically been insulated from political interference because Congress has recognized that political judgment about scientific merit is not reliable. The proposed pre-issuance review provision (§ 200.205) reverses that judgment, creating a mechanism through which scientific peer review recommendations can be overridden by political appointees without any requirement to demonstrate technical deficiency. As a staff member whose role is supported by NIH I urge OMB to recognize what this provision would destroy: not just individual grants, but the entire system of trust — among investigators, institutions, international partners, and the public — that makes American federally funded science the most credible in the world. Science operates on timelines that have nothing to do with political cycles. A longitudinal cohort study may take a decade to yield meaningful results. A clinical trial must follow participants through a defined protocol to produce valid, publishable findings. Basic research programs require sustained inquiry across years of negative results before yielding the breakthrough that justifies all of it. The proposed discretionary termination authority (§ 200.340) treats all of this as cancellable at will whenever "agency priorities" shift. The cost is not merely financial: it is the loss of years of irreplaceable scientific progress that cannot be recaptured by subsequent funding. Open-access publication mandates and open-access publication cost prohibitions cannot coexist in the same regulatory framework. The proposed rule (§ 200.405) would create exactly that contradiction, requiring federally funded investigators to make their findings freely accessible to the public while simultaneously prohibiting them from using grant funds to pay for the open-access fees that compliance requires. Additionally, eliminating conference travel (§ 200.432) will impose the greatest cost on the scientists with the fewest alternative resources. I urge OMB to withdraw this proposed rule in its entirety. The cumulative impact of these changes on peer review integrity, award stability, international collaboration, broadening participation, and the allowability of core research costs cannot be addressed through targeted revision. The proposed 45-day comment period is wholly inadequate for rulemaking of this scope and consequence, and the October 1, 2026 effective date does not allow the research community, institutions, or federal agencies sufficient time to assess or prepare for its effects. If OMB declines to withdraw the rule, I urge at minimum a substantial extension of the comment period, genuine engagement with the scientific community, and the removal of the specific provisions identified above.