Comment from Christopher Krupenye PhD

As a scientist, professor, and citizen of the United States, I am deeply concerned by the OMB's proposed "Regulation for Federal Financial Assistance" rule. The rule includes a number of fundamental changes with serious consequences for American science. To name a few: Grants that have gone through rigorous peer review by leading scientists and suggested for funding by expert program officers could be, at the final stage, removed from consideration by a political appointee who decides flippantly and without justification that the proposed work is anti-American. The rule requires programs to be aligned with administration policies and priorities, meaning that all kinds of critical research efforts could be sidelined. This includes basic research with with future applications that will only be discovered if the basic research is carried out, or research into politically polarized topics that are nonetheless critical for solving the world's greatest problems (e.g., polarization, vaccine development, or climate change). The effect is that scientists - the experts - will be expected to continue contributing enormous effort (expending months writing proposals that already face a tiny funding rate, spending weeks reviewing their colleagues' proposals or serving on panels) and yet will ultimately have very little say into the research priorities of federal funding agencies or which proposals are most deserving of funding. The rule also allows grants to be abruptly terminated. This is disastrous. It causes deep harm if a multi-year project ceases unexpectedly midway. Vulnerable patient populations participating in trials will lose access to experimental treatments and lose trust in the scientists they are working with. Even in the absence of such outcomes, the potential for terminations will negatively shift the way researchers do science. The reason that grants are often 5 years is so that sufficient time is available for the research team to think deeply about their hypotheses and research design, to establish the relevant groundwork for their research (e.g., run preliminary studies, etc), and to pursue studies that require multiple years of investment. This gold standard approach is only possible if scientists know that they have multiple years of support. Worries that funds will disappear at any moment will promote more rushed and less careful science and a focus on smaller and less impactful studies that can be completed more rapidly. We will see much less slow, thoughtful, or large-scale scientific projects. We will see fewer of the kinds of long-term and often high-risk studies that have the potential to transform scientific understanding. And in the longer term, I am afraid that we will also watch as China, Europe, and other countries outpace American science and obtain a competitive edge in development of new energy technologies, of AI, and of the other scientific innovations that will determine which country leads the world in the future. The OMB rule's purported goal is to improve "transparency, accountability, and oversight." But there is no existing problem with transparency, accountability, or oversight. The rule jeopardizes what has made American science the crown jewel of the world: that it operates independently, without political interference. We recruit and train the best scientists and we allow them to determine what science should be supported. This does not mean that the government cannot issue funding priorities, as they have always done. But it does ensure that critical research, including basic research across diverse disciplines, is not threatened by politicization.