Comment from Andreas Jenny
Andreas JennyOpposeAcademic
Summary: A tenured professor at the Albert Einstein College of Medicine opposes the proposed regulations, arguing that they would politicize research funding and undermine the peer-review system. The commenter contends that these measures would prioritize ideology over scientific merit, potentially stifling innovation and discouraging experts from volunteering for review panels.
To whom it may concern.
I am a geneticist and cell biologist by training and have been faculty at the Albert Einstein College of Medicine for the past 19 years. Currently, I am tenured Professor of Developmental and Molecular Biology, Genetics, and Medicine. My research program addresses questions related to aging, neurodegeneration and infertility. My primary source of funding for the past 17 years has been from several NIH institutes including NIGMS, NICHD, and NIA. Therefore, not only my own job, the ones of my currently 6 PhD students and 3 postdocs, but also their entire training depends on public funding of my research program. Inherently, this makes me qualified to respond to the following parts of the OMB proposal:
$200.202 Program Planning and Priorities
NIH institutes currently use RFAs to solicit proposals for topics deemed a priority which in part are decided upon input from experts funded by the appropriate institutes. The more this process is politicized, the higher the chance that not the best and most important research is funded. The former is particularly important, as some of the biggest inventions have been made by researchers purely based on coincidence with the broader implications shown only much later. Who would have thought that studying weird repetitive sequences from bacteria would lead to the discovery of an adaptive immune system of these organisms. Since the discovery these CRISPRs, they have been adapted to modify the genetic code of cells and are a promising novel tools for gene therapy. It would have been a huge mistake not to fund that research in the beginning. And this is only one example. Others are the identification of the components of every major cell signaling pathway known to date: they were found by tinkering with bacteria, worms, yeasts, or flies! Had this been prevented as not conforming with a political program, we would have many fewer cures for diseases. Should this happen in the future, fewer cures would be developed. Remove provision $200.202.
$ 200.205 Merit Review and Political Review
A huge benefit of the US funding of science is the peer review system in which peers evaluate applications and recommend them for funding, a rating which cannot not changed by politically motivated oversight. The latter would guarantee to lower the quality of scientific output, as not the quality, but ideology would determine funding. You may find this appropriate today, but imagine that a democrat will become the next president and cancel all federal funding to universities in states like Texas, Iowa, the Dakotas, or Oklahoma purely for retribution! This would strongly impact colleagues of mine, including for example a collaborator of mine at Iowa State University with whom I currently share a NIH grant.
The proposed OMB measure would lead to arbitrary decisions by non-experts and thus antagonizes the goals of the measure such as transparency and accountability. I have served on several review panels for NIH myself. Reviewing grants takes a ~ two weeks of voluntary work each time in addition to my research and teaching obligations. Knowing that someone without appropriate knowledge can override peer review will make all review work obsolete. The consequence: no one would volunteer to participate as peer reviewers. I therefore ask you to withdraw provision $200.205.