Comment from Anonymous

I am an undergraduate student at UC San Diego, currently interning in a research lab in the Skaggs School of Pharmacy. I am submitting a comment OPPOSING OMB’s revisions to the federal government’s “Uniform Guidance”. I OPPOSE §200.340 - Termination and Suspension, which grants federal agencies the authority to cancel grants that don’t fulfill “federal agency priorities” or “the national interest as they exist at the time of the termination.” The revision’s language remains conspicuously broad, allowing government agencies to essentially terminate funding because they feel like it. Subjecting research to the fickle nature of political actors destabilizes research environments and alienates graduate students from pursuing such a volatile career, making it harder for undergrads like myself to seek out stable mentorship opportunities in labs. This disinvests in students’ education, diminishing the country’s ability to produce competent researchers capable of responding to the challenges of the 21st century. I likewise OPPOSE §200.205 - Federal agency merit review of proposals, which faces similar problems with vague language such as prohibiting discretionary awards from promoting “anti-American values.” The section fails to define or even provide examples of “anti-American values,” allowing federal agencies to weaponize perceived metrics of identity and nationality against researchers. Empowering federal agencies in such a way threatens to reproduce the effects of the Cold War-era House Un-American Activities Committee, sowing fear and division that further estranges students and faculty from research environments. To preserve the independence of research environments and the quality of students' education, §200.340 (a) (2) and §200.205 (a) (2) (iv) should be withdrawn from the OMB’s revisions.