Comment from Aimee Surprenant

Thank you for the opportunity to provide comments on the proposal to revise the Guidance for Federal Financial Assistance, OMB-2026-0034. As a dean of a graduate school at an R1 university, I am extremely concerned about several of the changes being proposed that would politicize federal funding decisions and increase the cost and burden to federal funding recipients. For over 60 years the United States has been the leader and driver of innovation around the world, mainly due to the Federal investment in basic and applied research. We have cured cervical cancer, AIDS and sickle cell anemia. We have developed intelligent computer systems, batteries, innovative agricultural methods and more. We have created the technology that has sent our astronauts to the moon and satellites ringing the earth and beyond. In addition to improving people’s lives, these investments have had a tremendous financial return: estimates range from $5 to $11 dollar return on every dollar invested in basic research (https://mattsclancy.substack.com/p/frequently-asked-questions-about). Part of the reason we have thrived as a nation is because we have funded our scientists, engineers, and scholars and trusted them to innovate. We have created apprenticeship models that pass that spirit of innovation from mentor to mentee in the form of post-doctoral fellows and graduate students. We have supported those students through our research grants and given them the tools to continue to contribute to the greatness that is American science and ingenuity. If these changes are implemented we risk all of that. Putting strict rules around international collaboration, adding uncertainty by allowing cancellation without notice or cause, and prohibiting certain research for political reasons will all contribute to drive talented individuals from choosing a career in research or it will drive them to leave the country. It is already happening. Europe has created a Choose Europe for Science initiative (https://research-and-innovation.ec.europa.eu/news/all-research-and-innovation-news/choose-europe-science-over-100-national-and-regional-initiatives-aim-attract-global-research-talent-2026-01-30_en), Canada has launched a program to recruit world-leading researchers (https://www.canada.ca/en/innovation-science-economic-development/news/2025/12/government-of-canada-launches-new-initiative-to-recruit-world-leading-researchers.html), and even South Korea has expanded their visa program to attract foreign science and technology talents (https://www.koreaherald.com/article/10760272). In previous years this would have not worked because scientists wanted to be in the United States because it was known to support innovation. Indeed, the United States has attracted scientists and innovators from around the world and convinced them to stay. Fully 76% of international PhD awardees stay in the United States (https://eig.org/immigrant-retention-estimates/). But those numbers are at risk as and more of our most talented researchers are leaving the country and potential students are choosing to go elsewhere. In an article for the Global Health Technologies Coalition, the author notes “Without strong and predictable federal research support, the United States risks losing its place as a top engine of global biomedical progress. Young researchers see more uncertainty than opportunity, and other nations are investing heavily to take the lead, accelerating a US brain drain. If US policymakers do not act to restore the foundational factors that rooted American scientific leadership, the future of science may unfold elsewhere—and the next generation of discoveries may not be American-led.” https://www.ghtcoalition.org/blog/the-american-brain-drain-how-a-us-retreat-from-research-is-driving-innovators-abroad Please reconsider this rule for the good of the country. Thank you for your time. Aimee Surprenant, PhD Blacksburg, VA