Comment from Cristina Millan

As a university faculty member and federally funded researcher, I oppose several provisions of the proposed rule because they would undermine scientific research, student training, and the long-term competitiveness of the U.S. research enterprise. Section 200.340 Termination of Active Grants oAllowing agencies to terminate active grants because they no longer align with changing agency priorities creates unnecessary uncertainty. oMulti-year research projects require stable funding commitments to support students, staff, and long-term scientific objectives. oGrant continuation should be based on performance and compliance, not shifting political or administrative priorities. Section 200.220 Restrictions on International Collaborations oNational security must be protected, but broad restrictions on international collaborations could hinder scientific progress. oExisting research security requirements already provide safeguards against inappropriate collaborations. oScientific partnerships are essential for innovation, workforce development, and maintaining U.S. leadership in research. Section 200.461 Publication and Open Access Costs oPublishing research results is an essential part of the scientific process. oProhibiting grant funds from covering publication and open access costs will reduce the visibility and impact of federally funded research. oTaxpayers should have access to the research their investments support. Section 200.432 Conference Travel and Professional Memberships oConferences and professional societies are integral to scientific advancement, collaboration, and student mentoring. oRequiring prior agency approval for these routine activities adds unnecessary administrative burden without improving accountability. Section 200.421 Exceptions to Public Grant Announcements oOpen competition promotes transparency, fairness, and merit-based funding. oAny exceptions for national security should be narrowly defined and subject to appropriate oversight to prevent misuse. Section 200.300 Restrictions on DEI Activities oThe proposed language is overly broad and could unintentionally limit mentoring, outreach, accessibility, and workforce development efforts. oBroadening participation in STEM strengthens the nation's scientific workforce I respectfully urge the Office of Management and Budget to withdraw or substantially revise these provisions. Federal grant policies should continue to emphasize merit-based competition, scientific integrity, transparency, accountability, and stable support for research and education. These principles have made the United States the world's leader in scientific discovery and technological innovation, and they should remain the foundation of our federal research enterprise. Thank you for considering my comments.