Comment from Mark Johnson

Dear Mr. Vought, As a member of the American Academy of Neurology, I'd like to voice concern regarding the Office of Management and Budgets (OMBs) recently proposed regulation for federal financial assistance,a government-wide policy that would severely impact the medical research communitys ability to sustain critically important neuroscience research. The proposed rule would effectively politicize the grant award process by requiring a political appointee to conduct a merit review of all grant awards prior to the disbursement of the grant. Robust review and program integrity are vital to the strength and stability of federally funded grant awards going to well-deserving applicants, but imposing a review by a political appointee will introduce inconsistencies based on that administration and the personal preference of the appointee charged with conducting the review. Furthermore, the proposal would codify that peer review recommendations must remain advisory and not be routinely deferred to. These recommendations are the product of the expertise of the scientific community and adhere to strict guardrails to reduce bias. The highly technical nature of biomedical research requires independent peer review, and this regulation would minimize its importance. OMB proposes to restrict grant awards from being used for publication costs, membership dues, and conference attendance costs in order to improve accountability and reduce burdens on grant recipients. These proposed restrictions on how grant funds can be used will cause significant unintentional downstream effects on the quality of and access to published findings supported by federal funding, the sustainability of membership-based organizations, and access to the professional community that neuroscience researchers rely upon to advance and disseminate their research. Prohibiting federal grant funds from being used for these purposes only stands to create more burdens on researchers who must either navigate new significant administrative barriers or secure additional funding sources to support these necessary activities. Additionally, this proposed rule would add additional criteria to the grant application process that imposes a domestic-first framework. Domestic research is important for its ability to support local economies as well as increase the United States competitiveness in biomedical research globally. In the reality of todays research ecosystem, collaboration with researchers and laboratories across the globe are fundamental elements of research design aimed at revolutionizing our understanding of the brain, discovering new therapies and treatments, and supporting brain health for all. If finalized, this proposal would restrict American researchers from collaborating with long-term research partners who live outside the United States, slowing the pace of discovery and hinder the United States global competitiveness as American researchers will be less empowered to leverage the knowledge, expertise, and resources of international partners to support their own research. I strongly urge OMB to not finalize the proposed regulation for federal financial assistance as it has the potential to cause irreparable damage to the state of biomedical research. Sincerely, Mark D. Johnson, M.D.