Comment from Kathryn Whitehead

[200.300, 200.218] To Whom it May Concern: I am a professor of chemical engineering and biomedical engineering. I direct my department's PhD program and have spent much of my career mentoring students and early-career scientists, including women entering fields where they remain underrepresented. I am writing in my personal capacity to oppose the proposed changes to sections 200.300 and 200.218. Efforts to broaden participation in science are not ideology. They are workforce development in a country that does not train enough scientists and engineers to meet its own needs. Mentorship programs, recruitment efforts, and pipeline initiatives aimed at bringing more people into STEM fields, including people from groups historically underrepresented in them, exist because the talent pool is larger than the group currently being drawn from. Section 200.300 would put these ordinary, decades-old practices at risk of being read as unlawful DEI activity, regardless of their actual content or legal compliance. My department's ability to recruit and retain strong graduate students depends on this kind of institutional infrastructure remaining intact. Section 200.218's ban on disparate-impact studies would reach further than its framing suggests. My own research concerns maternal health, an area where measurable disparities in outcomes are well documented and are themselves the subject of legitimate biomedical inquiry, not political advocacy. Understanding why certain populations experience worse outcomes from a given condition or treatment is a scientific question with a scientific answer, and it is often the necessary first step toward fixing the problem. A blanket ban on federally funded disparate-impact research would foreclose that first step across public health, epidemiology, and clinical research more broadly, not just in the areas the rule's authors likely had in mind. I would also note that NIH has long required researchers to consider sex as a biological variable in study design, precisely because failing to do so has historically produced medical research that generalizes poorly to half the population. A rule restricting funds from promoting undefined "gender ideology" risks being applied, intentionally or not, in ways that create confusion around this kind of established, methodologically sound research practice. Broadening the pool of people who do science and understanding how conditions affect different populations differently are not fringe positions. They are basic good practice in a field that is supposed to serve everyone. I urge OMB to withdraw the proposed changes to sections 200.300 and 200.218.