Comment from Rachel Cole
Rachel ColeOpposeAcademic
Summary: A PhD researcher at a Midwest university opposes the proposed changes to the Guidance for Federal Financial Assistance. The commenter argues that allowing the termination of grants based on brief written rationales would waste resources, jeopardize scientific discovery, and harm patients participating in long-term biomedical research.
I am a PhD researcher at a Big Ten midwest institution working on Parkinsons disease research, which is the 2nd most common neurodegenerative disease, affecting over 1.1 million Americans. I strongly oppose the proposed changes to the Guidance for Federal Financial Assistance.
In particular, I oppose the revision that would allow termination of any grant if it is inconsistent with program goals or agency priorities (200.340). While funding should require compliance throughout the course of a grant, termination of a grant based on only a brief written rationale is irresponsible and wasteful. Grant funding supports scientific discovery, which relies on complete and thorough data collection. Investing money, time, and expertise to begin the project as funded, only to have that funding terminated would be a complete waste and serious loss of potential discovery. High-quality science cannot be conducted when the security of funding is constantly in jeopardy. Patients who are in clinical trials or who stand to benefit from the completion of years-long biomedical projects will be significantly harmed by this revised rule. Scientific advances and patient care, along with job security and scientific infrastructure, are significantly at risk from this rule. Please do not allow this rule to move forward.