Comment from Anonymous

I appreciate the opportunity to provide comments on the proposed revisions to the Uniform Guidance governing federal financial assistance. As a federally funded nurse scientist, my research examines how early-life environmental exposures influence child health across development using long-term longitudinal cohort studies. My comments focus on the potential implications of the proposed rule for human subjects research, scientific progress, and the biomedical research workforce. A primary concern is the potential impact that funding interruptions or award terminations could have on research participants. Many federally funded studies involve individuals and families who have voluntarily committed to years of participation, including repeated health assessments, biological sample collection, and follow-up visits. Interruptions to ongoing studies affect not only investigators and institutions, but also participants who have invested their time with the expectation that their contributions will advance scientific knowledge. Maintaining public trust in research depends on our ability to responsibly complete studies whenever possible. These concerns are particularly important for longitudinal research. Birth cohorts and other long-term studies represent substantial federal investments that often span decades. Their scientific value depends on continuous follow-up during specific developmental periods. If data collection is interrupted during critical windows of child development, those observations cannot simply be collected at a later date. Missing a developmental time point permanently limits what can be learned and reduces the scientific value of data already collected. Even temporary disruptions may lead to participant attrition, missing data, and loss of irreplaceable information, diminishing the return on federal research investments. The uncertainty surrounding potential funding interruptions also has broader consequences for the research enterprise. Even when projects ultimately continue, uncertainty delays hiring, slows participant recruitment, postpones purchasing decisions, and complicates collaborations across institutions. These disruptions reduce research efficiency and delay scientific progress without improving research quality or security. The proposed rule may also affect the stability of the scientific workforce. Modern research depends on highly trained research coordinators, analysts, laboratory personnel, graduate students, and postdoctoral scholars whose expertise develops over many years. Prolonged uncertainty surrounding research funding makes it more difficult to recruit and retain this workforce and may discourage early-career investigators from pursuing research careers. Workforce stability is essential to maintaining the United States' leadership in biomedical research. Finally, I encourage OMB to provide clear and objective definitions for terminology related to foreign collaborations and countries of concern. Researchers and institutions require consistent guidance to ensure compliance across federal agencies. Broad or ambiguous language may unintentionally discourage scientifically valuable international collaborations that pose little or no national security risk. Many of today's most pressing public health challenges, including environmental health, child development, and chronic disease prevention, benefit from carefully governed international research partnerships. Clear implementation guidance would help institutions protect national interests while preserving collaborations that advance scientific discovery and improve health. Thank you for considering these comments. I appreciate OMB's efforts to strengthen oversight of federal financial assistance while encouraging policies that also preserve scientific integrity, protect research participants, support the research workforce, and maximize the public's investment in biomedical research.