Comment from Kathryn Whitehead

[200.432, 200.454, 200.461, 200.206, 200.450] To Whom it May Concern: I am a professor of chemical engineering and biomedical engineering. My career has depended on the professional infrastructure this proposed rule would dismantle: society membership, conference attendance, and publication. I am writing in my personal capacity to oppose the proposed changes to sections 200.432, 200.454, and 200.461. Professional society membership has shaped my career directly. I have held leadership roles in the Controlled Release Society and the American Institute for Chemical Engineers, both of which depend on sustained, active membership rather than one-off participation. Under section 200.454, membership costs would require prior written approval and could be banned outright if an agency decided the society's primary function was issue advocacy, a determination made by the agency rather than the researcher. Conferences are where collaborations start, where trainees present their first work, and where a field corrects itself in real time when new data emerges. Section 200.432 would make conference costs unallowable unless spelled out in advance in a grant's terms, which is impossible for a multi-year award to anticipate. Research does not follow a fixed itinerary set at the time of funding. The flexibility to attend the conference where the relevant conversation is happening that year, not the one on file three years earlier, has been essential to my work and my trainees' careers. Publication is how research becomes useful to anyone outside my lab. I publish an average of 6-7 papers a year in journals including Nature Biotechnology, Nature Communications, and Nano Letters. Publication and open-access fees, covered under section 200.461, are already a meaningful cost of doing federally funded research. Making them unallowable by default, with exceptions only by case-by-case agency approval, would push researchers toward paywalled venues or discourage timely publication altogether. That does not save money. It delays the transfer of federally funded discoveries into the hands of other scientists, clinicians, and companies who build on them. Sections 200.206 and 200.450 compound these problems. Broadening pre-award risk assessment to scrutinize a researcher's professional and civic affiliations, combined with a ban on unspecified "issue advocacy," introduces a subjective and shifting standard into what should be a scientific evaluation. Ordinary professional service, serving on a society board, organizing a conference, mentoring in one's field, could be read as disqualifying depending on who is doing the reading. Membership, conferences, and publication are not perks layered on top of research. They are the mechanism by which research happens and matters. I urge OMB to withdraw the proposed changes to sections 200.432, 200.454, 200.461, 200.206, and 200.450.