Comment from VALERIE ARBOLEDA

I am an Associate Professor of Human Genetics and Pathology at the University of California, Los Angeles, a physician-scientist, and the principal investigator of a federally funded research laboratory studying rare genetic diseases. I write to oppose this proposed Rule in the strongest possible terms and to demand that the OMB withdraw it immediately. This Rule, if finalized, would constitute an unprecedented and destructive political takeover of American science — and it will cost lives. Science is apolitical. Medicine saves all lives. The work we do in biomedical research is not ideological. It is urgent. We study the root causes of disease — in children born with rare genetic syndromes, in patients dying from infections we do not yet fully understand, in families who have nowhere else to turn. This work cannot be done meaningfully under conditions of constant threat, uncertainty, and political motivation. Science requires stability, independence, and the freedom to follow evidence wherever it leads — not wherever a political appointee decides it should go. When that freedom is removed, patients die from diseases we could have understood, could have treated, could have prevented. The cost of this Rule will not be measured in dollars. It will be measured in lives. §200.205 — Political appointee review of grants Competitive peer review by scientific experts is the foundation upon which American biomedical leadership was built. This provision would allow political appointees to override that system and substitute ideology for evidence. No political appointee has the scientific expertise or the democratic mandate to second-guess expert review panels. This is not reform — it is the political censorship of science. Peer review must remain the sole and inviolable basis for funding decisions. §200.202 / §200.204 — Alignment with administration priorities; exemption from public notice Disease does not align with political priorities. My laboratory studies rare genetic syndromes in children and investigates why certain patients suffer disproportionate disease burden from infections that remain poorly understood. None of this work fits neatly into any administration's agenda, nor should it have to. Requiring research to conform to shifting political priorities, and exempting grant competitions from public notice, transforms science funding into a political instrument. These provisions must be struck entirely. §200.340 — Grant termination I co-lead an NIH T32 training grant supporting the next generation of genomic scientists. Allowing the government to terminate active grants based on political content does not save money — it destroys years of scientific progress, wastes prior federal investment, and ends the careers of early-stage scientists who have committed their lives to this work. Science cannot be conducted under the constant threat that funding will be pulled for reasons having nothing to do with scientific merit. This provision is punitive and must be removed. §200.220 — Foreign collaboration prohibition Rare diseases demand global collaboration. Patient populations are too small, and the scientific questions too large, for any single institution or country to answer alone. Prohibiting foreign collaboration will isolate American researchers, weaken our science, and ultimately harm the patients who depend on the international exchange of knowledge. §200.454 / §200.461 — Publication and dissemination costs Publicly funded science must reach the public. Making publication costs unallowable — while open-access mandates remain in place — is a direct contradiction that will suppress the dissemination of taxpayer-funded research. These provisions must be reversed. My demand is unambiguous: The OMB must withdraw this Rule in its entirety. It politicizes funding, criminalizes legitimate scientific inquiry, and places every active research program under threat of ideologically motivated termination. Medicine is not a partisan enterprise. We treat all patients. We study all diseases. We follow the science — because that is how lives are saved. This Rule would make that work impossible, and I will not stand by silently while it is enacted. Withdraw this Rule now.