Comment from Kathryn Whitehead

[200.205, 200.340] To Whom it May Concern: I am a professor of chemical engineering and biomedical engineering. My research focuses on drug delivery, including RNA-based therapeutics for maternal health. I am writing in my personal capacity to oppose the proposed revisions to sections 200.205 and 200.340, which would undermine the integrity of federal grant review and the ability of science agencies to fund impactful research. Peer review is the foundation of scientific funding and is used internationally to guide funding decisions. Reviewers are subject-matter experts, qualified to judge both the scientific merit of a proposal and the ability of the research team to execute it. Political appointees are not equipped to make these judgments. Under section 200.205, grants would function less like grants and more like at-will contracts, subject to the priorities of whichever party holds power at a given time. Academic research is a long-term enterprise. Funding decisions made on short political cycles will discourage exactly the kind of original, long-horizon work that produces breakthroughs. My own research on RNA delivery and maternal health therapeutics does not track any current political priority, but it addresses one of the largest unmet needs in medicine. Section 200.340's termination provision would allow grants to be cut off mid-award without a clear evidentiary standard. This is a poor use of taxpayer funds: it means studies go unfinished, results go unreported, and trainees lose the support needed to complete their degrees and move into the workforce. It also changes how I run my lab. If awarded funding can disappear at any point for reasons unrelated to scientific performance, I will hire fewer people and pursue safer, less ambitious projects, the opposite of what federal research funding is meant to encourage. Grant funding decisions should be made on scientific merit, not on whether a project aligns with the priorities of whichever administration happens to be in office when the award is made. I urge OMB to withdraw these proposed changes to sections 200.205 and 200.340.