Comment from Anonymous
Anonymous AnonymousOpposeAcademic
Summary: A tenured Professor of Epidemiology opposes the proposed revisions to 2 CFR Part 200, arguing that they would undermine scientific independence and stability. The commenter specifically criticizes the potential for the government to terminate active grants based on political priorities and the reduction of peer-review recommendations to an advisory role for political appointees.
I am writing in strong opposition to the proposed revisions to 2 CFR Part 200 (Docket OMB-2026-0034).
I am a tenured Professor of Epidemiology who has been continuously supported by federal research grants from the National Institutes of Health (NIH), the Centers for Disease Control and Prevention (CDC), and the Department of Defense (DOD) throughout my professional career. These grants have enabled me to conduct research examining the role of environmental exposures in breast cancer, pubertal development in girls, and obesity. The proposed changes, particularly Sections 200.340 and 200.205, would fundamentally undermine the stability, integrity, and scientific independence that are essential to federally funded research.
My work in environmental epidemiology has contributed to a broader scientific understanding of how environmental contaminants affect human health. Advances in this field have informed public health protections and regulatory decisions regarding harmful chemicals and environmental toxins. Research of this kind depends on a funding system that is guided by scientific merit, rigorous peer review, and long-term stability rather than shifting political priorities.
Section 200.340
Section 200.340 would allow the government to terminate active research grants based on changing agency priorities rather than scientific considerations. Such authority would create significant uncertainty for researchers conducting multi-year studies that require sustained support and long-term participant follow-up.
In environmental epidemiology, researchers investigate important public health questions arising from gaps in scientific knowledge, such as the potential relationship between per- and polyfluoroalkyl substances (PFAS) and breast cancer risk. These questions are driven by scientific evidence and public health need, not by political considerations. The possibility that ongoing, peer-reviewed research could be terminated because priorities change during the course of a project would discourage innovative and potentially impactful science, waste taxpayer investments already made in funded projects, and undermine confidence in the federal research enterprise.
I strongly urge OMB not to finalize Section 200.340.
Section 200.205
Section 200.205 would require political appointees to approve research grant awards while explicitly reducing the role of scientific peer-review recommendations to an advisory function. This change threatens a cornerstone of the U.S. research funding system: independent expert evaluation of scientific merit.
I have served as a reviewer on multiple NIH study sections and have seen firsthand the rigor, expertise, and substantial effort that go into evaluating grant applications. Peer review ensures that funding decisions are informed by scientists with the appropriate subject-matter expertise and that proposals are assessed fairly and objectively based on their scientific quality, innovation, feasibility, and potential impact.
If funding recommendations developed through this rigorous process can be routinely overridden for non-scientific reasons, it diminishes the value of peer review and risks discouraging qualified scientists from participating in review panels. Such a shift would weaken confidence in the fairness and credibility of federal research funding decisions and could ultimately compromise the quality of the science being supported.
I strongly urge OMB not to finalize Section 200.205.
Thank you for the opportunity to comment on these proposed revisions.