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 hinder international research collaboration, allow for the unnecessary termination of high-quality grants, and create impractical administrative hurdles for conference attendance. The commenter requests the withdrawal of provisions $200.220, $200.340, and $200.432.
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. This is part 2 of my comments and specifically comments the following items:
$200. 220; $200.340; $200.432
$200. 220: Foreign Collaboration
Basic and medical research should be apolitical and therefore not have to respect borders (at least of democratic countries). In my own career, my lab has collaborated with a lab in Paris, France, in a project in which we identified an interplay between the Parkinson Disease causing gene aSynuclein and the lysosomal protein Lamp1. My lab was working on Lamp1, my collaborator on aSynuclein. Talking together at a meeting, we decided to perform a series of experiments that in the end showed that the loss of the lysosomal protein made the PD model worse. Had we not been allowed to work together, we would not have been able to do this research and identify this mechanistically important interplay! Please withdraw provision $200.220.
$200.340: Termination and suspension
Awards are currently given based on scientific merit, impact, and feasibility as judged by review panels made up of highly qualified scientists from related fields. Having grown up in the European system and dealt with grants there, I quickly became familiar with the US peer review system and its advantages: experts judge, rate, and give feedback that helps to improve not only the application itself, but ultimately also the research that will be conducted once funded. Importantly, this system, while perhaps not perfect, guarantees that the quality of funded work is excellent - with the current level of competition for funding (~10-12 % , institute dependent) there simply is no bad grant that is funded. Once a funding decision has been made (based on strictly on the ranking by peers) there is absolutely no reason to terminate a running grant prematurely (aside from rare exceptions such as fraud). The consequences would be dire: research deemed excellent would have to be terminated, future scientists in training would lose their job and would have to find new ones prior to the end of their training. Who would employ half trained people? Provision $200.340 should be withdrawn.
$200.432: Conferences
I am puzzled that conference attendance costs would require explicit agency approval in the award terms. A NIH application is awarded for 4 to 5 years. Scientific conferences aren’t organized early enough for such a time scale. It therefore would be impossible to attend any meeting with grant support. As having organized a conference myself (NESDB in 2013), I can tell you that no conference organizer can select presenters that far ahead, as the latest research will decide who will present a poster or talk. I therefore ask you to withdraw provision $200.432.