Comment from Hannah Kubinski

I am writing in strong opposition to the OMB's proposed revisions. I am a second-year PhD student in the Molecular Genetics and Microbiology department at Duke University. My work focuses on identifying the molecular mechanisms that drive sex differences in human health and disease. This work uses cell lines from individuals with natural variation in sex chromosome copy number, individuals who may fall outside the typical "binary of sex." This proposed rule puts my work, and the work of countless others in the field, in jeopardy. Specifically, section §200.300 may block grant funding for my lab and others who address sex in their studies. This section states that federal funds are prohibited from being used to fund any theory that "denies the biological reality of sex or the sex binary." Sex is not binary. Biological sex emerges from the interaction of multiple developmental components: sex chromosomes, sex hormones, and anatomy. These categories can vary independently of one another, and a range of combinations does exist in individuals. If this rule is enacted, funding to my lab may be terminated or never allocated. Without federal funding, our lab cannot run, and scientific discoveries will stop. We cannot simply switch systems or forgo these resources, and we cannot deny the fact that sex is not binary. The cells we use from these individuals have led to major discoveries in the field and will lead to countless more. Enacting this rule will be detrimental to research in the sex differences space and will result in a loss of productivity and future scientific findings that could one day save lives. This will harm all individuals across the spectrum of sex, not just those who fall on the male or female sides. I urge the OMB to withdraw this provision, §200.300, entirely, both because of the inaccurate information it is based on and because of the damaging impact it will have on leaders in the field of sex differences research in the United States. It will have widespread impacts not only on labs like mine that will lose funding, but also on the individuals who may benefit from this research in the future. Thank you for reviewing my comments.