Comment from Maya Rao

[§200.205, §200.340, §200.220] I am a research staff member at a university whose research on on weather-related hazards on health has been supported by the National Institutes of Health since 2023 through its Climate Change and Health Initiative and now the Health and Extreme Weather program. I also previously worked in National Eye Institute-sponsored clinical trails for three years, and have implemented projects with non-profit organizations funded through cooperative agreements with the U.S. State Department to support global health, humanitarian assistance, and poverty alleviation in low and middle income countries. [§200.205] I am concerned with the provision that political appointees can override peer review, because this threatens the scientific process and will make scientific research biased and subject to political influence. Science should be conducted independently from the influence of any political agendas. It should be led, reviewed and overseen by experts in that scientific field. Political appointees do not have the appropriate training or knowledge base to determine the scientific merit of a research proposal. [§200.340] Similarly, I am concerned about this provision allowing grants to be terminated for political reasons. Terminating a grant early, before implementation has concluded is a major disruption to the scientific process and can have severe consequences, as many studies cannot simply be resumed after interruption. Terminating a project early can risk losing years of work, preparation, resources, money data, and time spent by researchers and participants on whom data are collected. Therefore, a decision to terminate an award needs to be considered carefully, in terms of the scientific, ethical, and resource implications. While some terminations may be justified after careful consideration and thorough examination of the pros and cons, it is not justifiable to simply terminate a grant for political reasons. [§200.220] The proposed restriction of working with international collaborators will have significant negative consequences for research advancements in the US. American researchers benefit from the knowledge and expertise of other collaborators around the world, and without access to these research partners, we are missing out on key information, innovation, technology, and novel methods. When studying an issue that has contextual nuances, US researchers may also suffer from not being able to collaborate with international colleagues to study the issue in other countries beyond the US context. Learning about how a disease or a hazard works in another context and shed light on issues that could potentially affect Americans in the future. American researchers will fall behind if limited only to the US context. Research does not occur in a vacuum, and with international travel and global changes that cross borders, restricting international collaborations ignores the reality of how the world works. If this provision takes effect, my research team may not be able to access funding and conduct research on critical issues, such as the impact of heat on health, changes in rainfall and temperature effects on mosquito-borne diseases, and solutions for improving food security in response to changes in weather patterns. If we are successful in obtaining government funding, we risk losing that funding in any moment, and our research projects being cancelled mid-way through implementation based on political whims. We will have lost time, money, effort, data, and relationships with other collaborators in the process. Answering these public health research questions is critical to helping Americans to protect their health and adapt to extreme weather. We need scientific integrity and support from renowned institutions like the NIH to achieve these research goals, but this provision would significantly hinder our ability to receive and maintain such support. I urge OMB to withdraw this provision.