Comment from Heather Rusiewicz

To whom it may concern: I am writing to comment on 200.204, 205, 111, 340, 332.I am concerned for my faculty and students as both a Department Chair and Associate Dean for Research for a School of Health Sciences, as well as a scholar. As an active researcher, Department Chair, and Associate Dean for Research, the primary impact of these proposed changes would be increased uncertainty when developing, managing, and sustaining federally funded research. My research focuses on implementation science and improving the adoption of evidence based practices for individuals with communication disorders. This work depends on long term planning, interdisciplinary collaboration, community partnerships, and dissemination of findings. If these proposed standards had been in place during previous federally supported projects, uncertainty regarding undefined terms such as "national interest," "anti-American activities," or "reputational harm" could have influenced project planning, partnership development, dissemination strategies, and faculty mentoring. From my leadership roles, I am also concerned about the broader impact on recruiting and retaining faculty investigators, supporting early career researchers, and preparing graduate students whose education and research experiences depend upon stable, transparent, and predictable federal funding. Beyond the specific provisions discussed above, I encourage OMB to consider the broader message these proposed changes send to the research community. Scientific discovery thrives when investigators understand the expectations by which their work will be evaluated and can confidently build long term programs of research, mentor students and junior faculty, and establish collaborative partnerships. Uncertainty surrounding undefined standards may unintentionally discourage innovation and slow the translation of research into clinical practice. As Department Chair and Associate Dean for Research, I view research not only as the generation of new knowledge but as the foundation for educating the next generation of scientists, clinicians, and health professionals. Policies that promote transparency, consistency, and scientific merit will best serve both the research community and the public who ultimately benefit from federally supported research. I am concerned that several of the proposed changes introduce undefined standards that could reduce predictability in the federal research funding process and create unnecessary uncertainty for researchers and institutions. As both an active researcher and research administrator, I believe clear, transparent, and consistently applied policies are essential to supporting scientific innovation, collaboration, workforce development, and the responsible stewardship of federal research investments. Thank you for your consideration.