Comment from Philip Jackson

I am submitting these comments in my personal capacity as a Director of Publications for a medical specialty society. My role is to support the publication and dissemination of peer-reviewed research, working every day with researchers, editors, reviewers, and publishers. Over the course of my career, I have seen firsthand how much time, expertise, and public investment go into producing high-quality clinical research. I've also seen the critical role that independent peer review and scientific publication play in ensuring that research ultimately improves patient care. For those reasons, I am concerned that several of the proposed revisions to 2 CFR Part 200 would weaken, rather than strengthen, the U.S. research enterprise. Most concerning is the proposal to reduce expert scientific peer review to an advisory role in funding decisions. Peer review is the foundation of modern scientific research because it relies on experts with the technical knowledge needed to evaluate scientific merit. Political leaders appropriately establish broad policy priorities, but evaluating the quality and potential impact of an individual research proposal requires specialized expertise. Undermining that process risks making funding decisions less predictable, less objective, and ultimately less effective in catalyzing scientific advances. I am equally concerned about the proposal to make publication and journal costs largely unallowable. From my perspective in scientific publishing, publication is not an optional administrative expense—it is how federally funded discoveries become available to clinicians, researchers, patients, and policymakers. Without publication, the public receives far less value from its investment in research. Open-access publishing, in particular, has become an important mechanism for ensuring that taxpayer-funded research is broadly accessible. Restricting support for publication costs would create barriers to sharing knowledge while doing little to improve accountability or transparency. I also urge OMB to reconsider the proposed provisions allowing termination of ongoing research projects based on changing agency priorities and imposing broad restrictions on international scientific collaboration. Medical research is increasingly collaborative and often spans many years. Stable funding and durable, flexible international partnerships are essential to answering complex scientific questions and translating discoveries into better patient care. The United States has built a magnificently inventive and productive biomedical research enterprise by investing in scientific excellence, rigorous peer review, and the broad dissemination of research findings. I respectfully urge OMB to preserve those principles by withdrawing these proposed provisions or revising them to protect the independence of scientific peer review, maintain support for publication costs, and avoid unnecessary barriers to long-term and collaborative research. Thank you for considering these comments. Respectfully, Philip Jackson Director of Publications Society for Vascular Surgery