Comment on OMB-2026-0034-0001

These comments reflect my own personal opinion and not necessarily that of my employer. I support policies that promote transparency, accountability, and responsible stewardship of federal resources. However, federal regulations should also enable the efficient conduct, management, and dissemination of research that serves the public interest. Research institutions incur legitimate facilities, compliance, technology, administrative, and publication costs that are essential to conducting high-quality federally sponsored research. Fair and consistent cost allocation methodologies are critical to ensuring these costs are appropriately attributed and that institutions can effectively fulfill their responsibilities as recipients of federal funding. I am particularly concerned about proposed restrictions on publication costs. Publication is not ancillary to research—it is a fundamental component of the public benefit generated by federal investment. The purpose of federally funded research is not only to generate new knowledge, but also to disseminate that knowledge so it can advance science, improve patient care, inform public policy, and benefit society. Limiting the allowability of publication costs may delay or impede the communication of federally funded discoveries and shift these costs to institutions already operating under significant financial constraints. I encourage OMB to preserve policies that support equitable reimbursement of necessary research infrastructure, administrative, and publication costs while minimizing unnecessary administrative burden. Federal research funding should prioritize the timely generation, publication, and dissemination of knowledge so that the benefits of scientific discovery reach patients, communities, policymakers, and the public as quickly and effectively as possible. Gerard Byrne, CMA, CPA - Massachusetts, USA