Comment on OMB-2026-0034-0001

International Antiviral Society-USAOpposeOther
Summary: The commenter argues that the proposed revisions to the Uniform Guidance would hinder scientific progress, workforce development, and the broader economy by restricting conference attendance. They contend that these restrictions create administrative uncertainty for researchers and would negatively impact local economies that rely on convention-related tourism and spending.
The proposed revisions to the Uniform Guidance governing federal financial assistance would significantly alter how federal grant recipients participate in scientific and professional conferences. Although the proposal seeks greater oversight of federal expenditures, the restrictions on conference attendance could produce substantial unintended consequences for scientific progress, workforce development, and the broader U.S. economy. Scientific conferences are not discretionary travel in the ordinary sense. They are a core component of the research enterprise. Conferences allow investigators to present findings, receive expert critique, establish collaborations, train students and early-career researchers, disseminate federally funded discoveries, and accelerate the translation of research into practical applications. In many fields, conferences also serve as the primary venue for developing multi-institutional collaborations that ultimately produce competitive federal grant proposals. The proposed requirement that conference attendance receive explicit administrative approval introduces uncertainty that will discourage participation even when attendance is scientifically justified. Investigators frequently cannot predict, at the time a grant is awarded, which meetings will be most important 2, 3, or 4 years later as research evolves. Requiring advance approval as part of award terms reduces the flexibility that scientific research requires. The effects extend well beyond academic research. Thousands of professional conferences held annually support local and regional economies throughout the United States. Scientific meetings generate demand for convention centers, hotels, restaurants, transportation providers, audiovisual contractors, exhibit companies, catering services, local retailers, and tourism-related businesses. Many cities have invested heavily in convention infrastructure specifically because conferences generate substantial economic activity. If attendance by federally funded investigators declines, the resulting reduction in conference participation could have cascading economic consequences, including: •Reduced hotel occupancy and lodging tax revenues. •Lower utilization of convention centers and meeting facilities. •Reduced business for restaurants, transportation providers, and local retailers. •Lower revenues for conference management companies, exhibitors, and event service providers. •Decreased employment in hospitality, tourism, and event support industries. •Reduced local tax revenues that many municipalities depend upon. These effects would not be confined to biomedical or basic science meetings. Federal grants support research, education, and public service activities across agriculture, engineering, environmental science, public health, early childhood education, workforce development, transportation, emergency preparedness, veterans' services, and many other sectors. Professional meetings in all of these fields rely on participation by federally funded investigators and practitioners. Restrictions on conference participation may also disproportionately affect early-career investigators, graduate students, postdoctoral fellows, and researchers from smaller institutions who have few alternative funding sources. Conferences often provide the first opportunity for young scientists to present their work, meet collaborators, obtain employment opportunities, and establish independent careers. Reduced participation could weaken the future scientific workforce. There are also important implications for the return on federal investment in research. Federal agencies invest billions of dollars annually to generate new knowledge. Conferences are one of the principal mechanisms through which that knowledge is disseminated, evaluated, challenged, and ultimately translated into innovation, improved healthcare, technological advancement, and economic growth. Policies that significantly impede dissemination risk reducing the overall value realized from those public investments. A more balanced approach would preserve agency oversight of travel expenditures while recognizing that conference participation is an integral and expected component of conducting federally funded research. Existing grant management systems already include institutional oversight, budget review, audit requirements, and federal cost principles designed to prevent misuse of funds. Additional restrictions should be carefully evaluated to ensure that they do not impose costs that exceed any anticipated savings. For these reasons, the conference attendance provisions should be reconsidered or substantially revised to preserve scientific communication, protect local economies that depend on professional meetings, and maximize the public return on federal research investments.

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