Comment from Anonymous

I am a pediatric oncologist who works at a major US research institution which relies on federal grants to improve outcomes for children suffering from cancer. I have received federal funding from the NIH to improve the care of children with cancer. I have several concerns about the OMB's proposed Regulation for Federal Financial Assistance rule as it pertains to research on pediatric cancer and child health in general. Section 200.205 creates a layer of pre-issuance review to the already arduous process of grant submission and threatens the credibility of research coming out of the United States. I agree with the administration that eliminating political agendas from scientific discovery is a noble pursuit. This section of the rule makes this concern worse, not better. The United States has, for over a century, led the world in medical innovation and scientific discovery because it has relied on apolitical conduct of research. If we insert politics into scientific research, we cede this ground to other countries. Section 200.340 is extremely problematic because the ability to terminate grants on the political whims of the administration in power makes the financial security of the US scientific enterprise extremely unpredictable. For decades the US has been the leader in medical innovation and scientific research because our government has let science be science, and it has recruited the best minds from both the US and elsewhere to perform research under the protections of the US constitution - most notably free speech. If we destabilize the financial security of our scientific community by passing rules like this, US students will be dissuaded from pursing graduate degrees and research careers, foreign talent will go elsewhere, and the US will cede it's worldwide leadership in both technological and healthcare research to other countries - like China. If you don't think the Chinese government is hoping this rule passes and our scientific enterprise is destabilized, you are kidding yourself. They are literally salivating at the prospect of recruiting US minds to do research there and to keep their most talented researchers home. Rules like this help them and hurt the US. Finally, cutting funding for an ongoing study simply because AI tells someone with absolutely no scientific experience that the work is problematic with any given administration's political ideology is a tremendous waste of taxpayer dollars. Sections 200.432, 200.454, and 200.461 dramatically change the rules of the road for how we share scientific discoveries. I agree with the administration's sentiment that journals have become profit behemoths with predatory practices. They know researchers need to publish to survive, and they see an opportunity to take advantage of that and make a profit. This rule, however, is not the solution to that problem. The funds for these publication costs will come from elsewhere and will inhibit our universities and research intuitions from investing in our local communities and innovation. The way to solve this problem is via congress. They need to make laws that reign in this predatory practice and protect US taxpayers from this fleecing. This solution passes the buck elsewhere and does nothing to solve this problem. Further, conference attendance is absolutely vital for scientific career development. Restricting researchers from travel to not only share their work but also to collaborate with other researchers has a maiming effect on our scientific community. We simply cannot innovate if we cannot collaborate and disseminate. Section 200.300 is problematic for the above reasons, but most specifically it is completely arbitrary in how this rule is applied. In my own experience I had a mentee's K application canceled because her research was deemed DEI." The issue was that her research had absolutely nothing to do with DEI. Her work is focused on identifying risk factors in children who die of their cancer and finding ways to mitigate those factors so that less children die of cancer. And yes, there are non-medical factors which prevent children with otherwise curable cancer from being cured; and yes, those risk factors include racial, economic, geographic, and psychosocial categories. So, no, my mentee had no political ideology or DEI-interest guiding her work, but because she is seeking to address racial and economic factors which prevent good cancer care, some AI program and a bureaucrat with absolutely no scientific experience cancelled it. If you have an issue with a certain area of medical research, fine, make a rule that is SPECIFIC and can be implemented consistently and fairly. This rule is WAY to vague. Bottom line: these rules hurt US citizens, the US research enterprise, and helps foreign enemies (most notably, China) develop programs which will eventually overtake our capabilities. Thank you.