Comment from Hailey Robertson

I am a PhD student studying infectious disease ecology at Yale University. I receive funding through my own NSF Graduate Research Fellowship (GRFP) and additional support from the NSF and NIH via my advisors' grants. I am opposed to the proposed changes and urge OMB not to finalize this rule. As a trainee, I know firsthand how disruptive grant termination after my advisors' multi-million, multi-year grant focused on identifying viral pandemic threats was abruptly frozen. Research pipelines, fellowships, and training that we had invested years into developing suddenly no longer had support, including ongoing work on hantavirus - which emerged while our grant was still frozen. The type of work that I do, and will continue to do, throughout my career helps build preparedness against these types of outbreaks. Federal funding is crucial for this work because ecological surveillance and epidemic preparedness are public goods that require sustained, long-term investment without promise of immediate commercial payouts. The proposed §200.340 expands the authority to defund and terminate active grants in the middle of their award based on political priority. This uncertainty around grant terminations makes it harder to do that work, as the threat of defunding the baseline ecology of zoonotic disease research (especially when public health does not align with political priority) ensures that we will be reactive rather than proactive when the next spillover occurs. As an aside, these terminations of active grants are also an incredibly inefficient use of taxpayer dollars by essentially making all the research completed up until the termination a sunk cost, that can perhaps never be recovered. This instability is only amplified by the broad prohibition on international scientific collaboration proposed in §200.220, which makes it harder to access case data, provide assistance with disease surveillance and interventions, and deploy expertise in the unfortunate circumstance that it's rapidly needed in an epidemic scenario. As we know, infectious diseases do not respect borders and they require readiness of response, so the prohibition on use of federal funds for international collaboration is devastating to my line of work and the public health of all Americans because at worst, it ends foreign collaboration and at best, it means that researchers question the terms of engagement with their international partners that cost us precious response time. In addition to the public health consequences, unexpected grant terminations and freezes introduce severe operational and economic conditions that decimate team productivity. In the private sector, no one would expect a firm to remain productive if its primary venture capital or revenue stream was abruptly frozen overnight. A company facing such a sudden fundraising shortfall would see its operations grind to a halt, its talent pool disperse, and its leadership entirely consumed by crisis management rather than product development. Yet, section §200.340 expects scientific labs to absorb this exact shock. During the period where our grant was frozen, our lab was forced to operate on emergency reserves. Staff performing critical public health work faced imminent layoffs and severe distress; we were unable to hire the necessary post-doctoral researchers to support the project and mentor students; and my advisor was forced to pivot away from scientific oversight to spend valuable time on administrative triage, searching for patchwork funding. Just as a sudden capital freeze destroys private sector productivity, expanding the authority to terminate active grants under §200.340 guarantees that this chaotic state of survival that I experienced will become the norm for American research labs. Lastly, I am concerned with provision §200.432, which would require agency pre-approval to attend conferences. PhD students and early-career researchers are the engine of innovation that push fields forward through disseminating their hands-on research and novel methods at conferences. Bureaucratic hurdles like agency pre-approval will disproportionately affect trainees like me. Unlike faculty, graduate students lack the administrative infrastructure and expertise required to navigate federal clearance systems. Furthermore, PhD training operates on a highly compressed, strict timeline; students have a narrow window of just a few years to complete their dissertations and secure employment. Introducing unpredictable administrative delays to conference attendance threatens to derail their time-sensitive research and cause them to miss fleeting career opportunities. Forcing the very population responsible for driving scientific progress to battle bureaucratic inertia will create a chilling effect on innovation and severely disrupt the pipeline of future leaders. OMB, please do not move forward with these changes, especially to §200.340, §200.220, and §200.432.