Comment from Carmen Marsit

Publication Charges and Conference Attendance (§200.461 and §200.432) I am an executive associate dean for research and distinguished professor at Emory University Rollins School of Public Health. I am commenting in my personal capacity as a children’s health researcher with two decades of experience in public health research supported continuously by federal funding from the National Institutes of Health. I have been the primary or co-author on over 400 peer reviewed publications and attend 2-3 scientific conferences each year. In order to disseminate the important research that my group does, I often need to pay article processing charges (APCs) to publish my research in peer reviewed journals as well as attend scientific conferences where my trainees and I present on our research to both the scientific community and broader community of interested or impacted individuals. The proposed revisions to §200.461 and §200.432 would undermine a central public purpose of federally funded research: ensuring that the knowledge generated with public dollars is shared broadly and effectively with the scientific community, as well as with stakeholders of the research, including individuals and communities whose suffer from health conditions or environmental conditions that impact their health. Point 1 - APCs: Disallowing article processing charges and conference attendance costs would make dissemination more difficult, not more accountable. Although the proposal suggests that exceptions to the general disallowance of APCs may be approved on a case-by-case basis, that approach would impose substantial administrative burdens on both recipients and federal agencies who would need to review requests and make approvals. The proposal also provides no standards or criteria for granting such exceptions, raising serious concerns that decisions could be inconsistent, arbitrary, or unsupported by a clear policy rationale. I agree that the current scientific publishing model is deeply flawed and increasingly unsustainable. However, OMB has not justified the proposed disallowance of APCs on that basis. If the intended policy goal is to reform the scientific publication system, prohibiting APCs on federal awards will not accomplish it. Instead, it will merely shift publication costs from federal grants to universities, research institutions, and individual investigators, while leaving the underlying market structure unchanged. Point 2 – Conference Attendance: The proposed requirement that conference attendance costs be allowable only when participation is expressly approved by the agency and included in the award terms and conditions is similarly burdensome and impractical. It is not clear whether the proposal would require approval at the start of an award for attendance at a particular conference on particular dates. If so, that requirement is unworkable. I would not know, at the beginning of the grant period what the results of our work will be, when they will be ready for presentation, and often who the right audience might be. In practice, this provision would operate as a de facto prohibition on using federal funds for conference attendance, again frustrating the government’s own interest in the dissemination of the research it supports. As described in the Executive Summary, the broader objective of the proposal is to reduce fraud, waste, and abuse in federal grants and to ensure that federal awards serve the national interest and advance the President’s priorities. If OMB believes that conference attendance is an area of widespread fraud, waste, or abuse, it should present evidence and make that case directly. In my experience at multiple universities where I have worked, travel and conference participation are subject to rigorous controls, with strict rules on reimbursement limits, documentation requirements, and cost controls. Conclusion: If the proposed changes to §200.461 and §200.432 are adopted, I may lack access to non-federal funds needed to share findings from my research on the environment’s impacts on children’s health, meaning federally funded research may never reach the scientific and public health audiences it is intended to inform. Funding research while restricting the ability to disseminate its results is inherently wasteful. Recommendation: I recommend that OMB rescind the proposed changes to §200.461 and §200.432 in full. If OMB elects to retain them, it should provide a clear rationale that is logically connected to the stated objectives of OMB-2026-0034 and should acknowledge, analyze, and quantify the administrative and practical burdens these changes would impose on both recipients and federal agencies as well as work to reduce those burdens.