Comment from Eric Landsness

I am a neurologist and physician-scientist at Washington University School of Medicine in St. Louis. My laboratory conducts federally funded research aimed at developing new therapies for neurological diseases, including stroke and disorders of sleep. I am submitting this comment because I believe several aspects of the proposed rule would significantly weaken the biomedical research enterprise in the United States. The United States has become the world leader in biomedical research because funding decisions are based on rigorous scientific peer review. NIH grant applications undergo extensive evaluation by independent experts who assess scientific significance, innovation, feasibility, methodological rigor, and the qualifications of the investigators. This process is not perfect, but it is transparent, merit-based, and grounded in scientific expertise. I am particularly concerned about the proposed requirement that political appointees review discretionary grant awards before funding decisions are finalized and the proposal to emphasize that peer review recommendations are advisory rather than routinely deferred to. Introducing political review into what has historically been an evidence-based scientific process risks undermining confidence that funding decisions are based primarily on scientific merit. Scientific priorities naturally evolve as new discoveries are made, but they should not fluctuate according to changes in political leadership. The uncertainty created by this proposal would have consequences beyond individual investigators. Research laboratories make long-term hiring decisions, train graduate students and postdoctoral fellows, invest in expensive equipment, and pursue projects that often require many years to reach patients. Greater uncertainty in the grant process will make these investments more difficult and ultimately slow scientific progress. These changes also have important economic consequences. Federal research grants support highly skilled jobs in Missouri, including research staff, trainees, technicians, and data scientists. They stimulate collaboration with biotechnology companies and bring substantial federal investment into our state. Every successful grant awarded to institutions such as Washington University generates economic activity that extends well beyond the laboratory. I am also concerned about proposed restrictions on using grant funds for publication costs, conference attendance, and professional society memberships. Publishing results, presenting findings at scientific meetings, and collaborating through professional organizations are fundamental components of the scientific process. These activities accelerate discovery, improve research quality through critical feedback, and ensure that taxpayer-funded research is rapidly disseminated to other scientists and clinicians. Finally, biomedical science is increasingly collaborative. Many advances depend on partnerships with investigators in other countries who provide complementary expertise, patient populations, or specialized technologies. Policies that unnecessarily restrict these collaborations risk reducing American scientific leadership rather than strengthening it. I fully support responsible stewardship of taxpayer dollars and rigorous oversight of federal grant funding. However, I believe these goals are best achieved by strengthening scientific peer review, transparency, and accountability—not by introducing additional political review into funding decisions or restricting the mechanisms through which scientists communicate and collaborate. For these reasons, I respectfully urge OMB to reconsider these provisions before issuing a final rule.