Comment from Rafael L Bras

I write to express my most serious personal concern about OMB's proposed new Guidance for Federal Financial Assistance. Federal assistance impacts the lives of every single American, rich or poor. It impacts individuals from all political persuasions. The Guidance moves away from decisions based on merit and good ideas. It takes away Congress' ability to appropriate resources to be used according to legislative and national priorities. For 50 years I have been a university professor, researcher and academic administrator in three top research universities Throughout most of that time the USA's preeminence in science, engineering and technology was uncontested. Colleagues and students were literally changing the world and improving the human condition. That preeminence is gone, with Europe and China being extraordinary competitors. The reason for our decline is underfunding, over-regulation and the dismantling of fine-tuned system that promoted excellence and competition. The Unified Guidance will destroy what is left of our successful enterprise: 1.It usurps merit based and peer review by requiring political approval of grants. Once the administration sets national priorities, grants should be awarded based on merit, not a political litmus test subject to manipulation and change. Let ideas be proposed and selected, if worthy of selection, based on content. 2.It gives authority to the Executive Branch to terminate grants for any reason, at any time. This uncertainty places a major obstacle on planning and execution of efforts. Such power also makes it possible to ignore the will of Congress. 3.It makes it difficult, and possibly impossible, for researchers to attend academic conferences. These conferences are the way the web of innovation and creativity is built. 4.It makes it difficult, if not impossible, to pay for publishing costs. Publishing is the archival and trusted way to disseminate knowledge. It is the way that reputation of institutions and individuals is built. The US is already behind China and Europe on this metric. It is apparent that publication rates are slowing down even faster because of recent administration decisions, and cuts and delays in disbursement of resources. 5.It makes international collaborations difficult or impossible, again interrupting a proven way to gain and disseminate knowledge. This further isolates the United States from the global community of researchers. 6.The suggested guidelines also impose additional burden of administration and bureaucracy on institutions. On top of already enacted cuts, these additional costs will break many organizations and institutions. If adopted, OMB's proposed new Guidance for Federal Financial Assistance pose a serious threat to professional and scholarly organizations that have, since the beginning of this country, served the nation very well. And let us not forget the myriads of other grant recipients, from states to food kitchens, that depend on grants to serve the public. Possibly the most serious consequence of these proposed guidelines is the frustration and cynicism of our young people; the future scientists, engineers, technologists, investors and entrepreneurs of this country. I urge you to call for hearings on the Guidance, urge additional time for comments and insist on addressing the above and other impacts of this action. This is not a partisan issue, it is policy that will seriously hamper what we all want: serving citizens well and promoting the creativity of our people to solve our and problems.