Comment from anonymous anonymous
anonymous anonymousOpposeAcademic
Summary: A postdoctoral researcher at Yale University opposes the proposed rule, arguing that it creates administrative barriers to international collaboration and undermines the merit-based peer review system. The commenter expresses concern that political discretion and broad restrictions on research topics will stifle innovation and discourage long-term scientific investment.
The Office of Management and Budget ,Public CommentI am a postdoctoral researcher at Yale University conducting research in the biology of aging. My work investigates the cellular and molecular mechanisms underlying aging and stress tolerance, with the long-term goal of improving our understanding of healthy aging and age-related disease. As an international researcher working in the United States, I respectfully urge the Office of Management and Budget (OMB) to withdraw the proposed rule.My personal view on key proposed changes & their section numbers: [§200.202] Domestic-first frameworkModern biomedical research is inherently international. Scientific progress depends on collaboration among researchers with complementary expertise, regardless of nationality. In my own field, advances in aging biology rely on contributions from laboratories across the United States, Europe, Asia, and many other regions. Restricting international components unless they are individually justified would create additional administrative barriers, discourage productive collaborations, and slow scientific progress without improving research quality. Scientific questions should determine collaborations-not national borders.[§200.205] Political discretion in grant awardsFederal research funding has long relied on rigorous peer review by experts who evaluate proposals based on scientific merit, feasibility, innovation, and potential impact. Allowing political priorities to supersede independent scientific review risks undermining confidence in the fairness and integrity of the funding process. Researchers should be encouraged to pursue important scientific questions based on evidence and merit rather than anticipating shifting political priorities. Stable, merit-based funding is essential for attracting talented scientists and maintaining the United States' leadership in research.[§200.220] Restrictions on international collaborationScience advances because knowledge is shared across institutions and countries. International collaborations often provide access to unique expertise, technologies, biological materials, and datasets that are unavailable within a single institution or country. Broad restrictions on collaborations based on nationality rather than specific, evidence-based security concerns could isolate U.S. science, reduce innovation, and make the United States a less attractive destination for outstanding researchers. While national security should always be protected, broad restrictions should not unnecessarily limit legitimate scientific collaboration.[§200.300] Political restrictions on research topicsScientific funding should be guided by scientific merit and public health priorities rather than political terminology. Biomedical research frequently examines biological differences among populations, health disparities, and other factors that are essential for understanding disease and improving medical care. Broad restrictions based on politically defined categories create uncertainty about which research questions are permissible and may discourage investigators from pursuing scientifically important work. Such uncertainty ultimately reduces innovation and weakens the evidence base used to improve healthcare.[§200.340] Grant termination based on "national interest"The ability to terminate research grants at any time based on a broad and undefined "national interest" standard creates substantial uncertainty for researchers, institutions, trainees, and long-term scientific projects. Many biological studies require years of continuous work to produce reliable results. The possibility of abrupt termination discourages ambitious, long-term research and makes it difficult to recruit talented scientists or invest in innovative projects. Predictability and stability are fundamental to responsible stewardship of taxpayer-funded research.More broadly, these proposed changes risk weakening the principles that have made the United States the global leader in scientific research: independent peer review, international collaboration, academic freedom, and long-term investment in discovery. As an international scientist who chose to conduct research in the United States because of its reputation for scientific excellence and openness, I believe these principles benefit not only researchers but also the American public through improved health, technological innovation, economic growth, and global competitiveness.For these reasons, I respectfully urge OMB to withdraw the proposed rule and preserve a research funding system that is based on scientific excellence, transparency, and independent peer review rather than political considerations.