Comment on OMB-2026-0034-0001

Public Comment Opposing the Proposed Revisions to Uniform Guidance (2 CFR Part 200) – Docket No. [Insert Docket Number if available, or reference 2 CFR Part 200 Revisions] To whom it may concern, I am writing to express my strong opposition to the White House Office of Management and Budget’s (OMB) proposed revisions to the federal Uniform Guidance (2 CFR Part 200). As a veteran software architect, technical lead at Tai Chu Quant AI Technology, and an independent researcher working at the intersection of quantitative finance, theoretical physics, and computational geroscience, I am deeply concerned that these revisions will severely cripple scientific progress, compromise the peer-review system, and paralyze critical international research collaborations. 1. The Inherent Contradiction of Eviscerating Publication Cost Allowability (§200.461) The proposal to amend §200.461 to make Article Processing Charges (APCs) unallowable as eligible costs on federal grants represents an impossible policy contradiction. The 2022 OSTP (Office of Science and Technology Policy) memo mandates immediate public access to taxpayer-funded research upon publication. Yet, by removing the primary financial mechanism (APCs) that enables open-access publication, the OMB is effectively placing researchers in a legal and operational deadlock. For my interdisciplinary projects—such as building deep learning-driven histopathology frameworks and multi-dimensional biomarker frameworks (e.g., the 9-WCM model)—open-access publication is not a luxury; it is a vital necessity. It ensures that our mathematical models and computational tools are immediately accessible to global clinical and hardware teams. Defunding APCs will disproportionately suppress independent, high-impact AI-driven biomedical research. 2. Erosion of Academic Integrity via Political Overrides and Arbitrary Terminations (§200.205 & §200.340) I strongly object to the revisions under §200.205, which propose allowing political appointees to override the established scientific peer-review process. Scientific evaluation must remain decoupled from political shifts and dictated solely by methodological rigor, data reproducibility, and technical innovation. Allowing non-experts to veto peer-reviewed grant selections will introduce systemic bias and severely damage the global credibility of US-funded science. Furthermore, the expansion of grant termination clauses under §200.340 creates an unstable funding environment. Complex systems modeling and biological age tracking projects require years of continuous, predictable multi-stage iteration; the looming threat of arbitrary, non-scientific project termination will deter top-tier technical talents from pursuing high-risk, high-reward foundational research. 3. Devastating Blow to Global Scientific Progress and Foreign Collaborations (§200.220) Most critically, the proposed ban or severe restriction on foreign collaborations under §200.220 is fundamentally detached from the realities of modern, cutting-edge science. Breakthroughs in advanced fields like Quantum-inspired Evolutionary Algorithms, Background Pressure Theory, and quantitative medicine cannot be achieved in geographic isolation. My own research heavily relies on heterogeneous data pipelines, global open-source software architectures, and cross-border analytical validation. Restricting collaboration with international entities and blocking access to overseas laboratory validation networks will not protect domestic interests; instead, it will blindfold American-led projects, cut off access to global clinical cohorts, and cause the United States to lose its competitive edge in the global AI and biotechnology race. Conclusion Science is an inherently open, collaborative, and global endeavor. The proposed revisions to 2 CFR Part 200—specifically §200.461, §200.205, §200.340, and §200.220—will construct an insurmountable barrier to open science, compromise academic independence, and isolate US research from the global scientific community. I urgently request the OMB to withdraw these damaging clauses and preserve the integrity, open accessibility, and collaborative nature of federal research funding. Sincerely, Ying Ye Founder & Technical Lead, Tai Chu Quant AI Technology Co., Ltd. Independent Computational & Geroscience Researcher