Comment from Jeanette Scheid

I am a child and adolescent psychiatrist, associate professor of psychiatry at Michigan State University. Over the course of my career I have engaged in research, usually in partnership with others and funded by federal as well as private grants. My chief activities are as a clinician and teacher. Research focusing on the behavioral health issues in children and adolescents lags behind that of general behavioral health, which remains in relatively early stages compared to other branches of medicine. In this context, it is critical to encourage investigators across the board, from understanding clinical presentation and etiologic factors to expanding knowledge about all treatments, including safe and effective medications and psychosocial/behavioral interventions. Each of the sections in the proposed rules is contrary to the goal of expanding knowledge leading to the assessment and care of youth as described: Section 205 - investigations are typically complex, builds on prior work and the well-established process of peer review - the risk that funding for a project could be overridden by others would have a chilling effect even prior to work and risk findings that are grounded in the political process rather than established scientific principles. Section 340 - it is already challenging to obtain funding for behavioral health research in children. The lack of stability arising from the risk of loss of funding without clear merit/rationale will add a significant barrier to investigators. Section 432 - scientific progress depends on free/open dialogue between investigators, clinicians, and systems/policy personnel - this provision would place unnecessary barriers to communication. Section 454 - research teams rely on established methods of communication including journals that publish scientific findings - barring funding for journal subscriptions will inhibit the scientific process. Section 461 -prohibiting funding for publication costs) would cause a barrier on the other end. Having had to pay out of pocket in the past to publish my findings, this section is particularly concerning. Section 300 - I understand the current administration does not prioritize DEI, but as a practicing child psychiatrist, I can speak with confidence that there are very real issues for youth of color and other marginalized folk and attempting to conduct research without accounting for these issues/factors is like doing research on heart conditions without accounting for participant's blood pressure. Section 218 - as a practicing child psychiatrist, I struggle to advocate for building systems/supports for the complex needs of my patients - children ARE an underserved group, so understanding and addressing the barriers to services is critical and should not be optional. Section 220 - we live in the world, understanding child/adolescent mental health across countries/systems is important to improving domestic behavioral health services. Section 202 - research questions should be driven by scientific questions, not by any administration's priorities, especially if we as a scientific and clinical community are to be able to use prior work to ask new questions and expand knowlege. Section 204 - if funding opportunities are not made public, teams with great ideas and capacities will not be included, again limiting research. I hope this point by point critique will allow substantive review of the proposed changes. Given the multiple problems this would pose to moving forward in understanding and addressing the behavioral health needs of children. I would respectfully suggest that the OMB withdraw the entire proposed rule. Jeanette M Scheid, MD, PhD Associate Professor, Psychiatry Michigan State University East Lansing, MI