Comment from Jordan Cole

I am a child neurologist and physician-scientist whose research focuses on improving access to evidence-based care for children with neurodevelopmental disabilities. My work examines how to ensure that all children who meet established clinical guidelines receive appropriate genetic evaluation, regardless of where they live or where they receive care. As both a clinician caring for patients and a federally funded researcher, I have a direct interest in maintaining a grant review process that is objective, rigorous, and grounded in scientific expertise. I appreciate OMB's goal of strengthening accountability for federal financial assistance. However, I have serious concerns regarding the proposed changes to 2 CFR §200.205, which would introduce an additional review of discretionary awards by senior political appointees. While it is appropriate for administrations to establish broad funding priorities, individual grant applications should continue to be evaluated primarily on scientific merit through independent expert peer review. Scientific peer review is not without limitations, but it remains the most effective mechanism for evaluating the methodological rigor, feasibility, and potential impact of complex research proposals. Adding an additional political review process raises the concern that funding decisions may be influenced by factors unrelated to scientific quality. Preserving the independence and central role of expert peer review is critical to maintaining public trust in the federal research enterprise. I am also concerned that several aspects of the proposed rule could discourage or limit federally supported research examining disparities in healthcare access and health outcomes. Research in this area is not intended to advance a political viewpoint; rather, it seeks to understand why evidence-based care is not delivered consistently and how healthcare systems can better serve patients. In my own field, many children who meet established national recommendations for genetic testing never receive it. Studying these implementation gaps is essential to improving diagnostic accuracy, reducing delays in care, and ensuring that existing standards of care are delivered consistently across populations. I respectfully encourage OMB to revise the proposed rule to preserve independent scientific peer review as the primary basis for evaluating research proposals and to ensure that rigorous research on healthcare access, implementation, and health disparities remains eligible for federal funding when scientifically justified. These revisions would support both accountability and scientific excellence while maximizing the public benefit of federally funded research.