Comment from Martha Bhattacharya

To Whom it May Concern: My name is Martha Bhattacharya, and I am an Associate Professor of Neuroscience at the University of Arizona in Tucson, AZ. I direct a NIH-funded research laboratory working on neurodegenerative diseases like Alzheimer’s and ALS. My work also has implications for cancer and neurodegenerative disease. My lab has been supported by NIH since 2018 and, prior to that, I was supported by a T32 postdoctoral training grant. I am also a regular scientific reviewer on NIH grant review panels for the Center for Scientific Review (CSR) at the NIH. I am concerned about the OMB proposed rule in OMB-2026-0034-0001 (“Regulation for Federal Financial Assistance”) and the provisions within that change the federal grantmaking system. The proposed changes would dramatically alter the integrity of the scientific grantmaking process for the worse and threaten the entire scientific enterprise in the United States. I specifically urge you to reconsider the following sections of the OMB memo: • §200.205 — Political appointee review of grants. This step, at best, slows down the apportionment of funds to grants that have already been identified as well deserving of funding. At worse, it would impose a non-scientific layer of review to the process and would be a means to discard grants ranked highly by the expert scientific reviewers. If this rule takes effect, my lab would have to wait longer for the results of grant applications, making some of the things I propose already outdated by the time we get funded to pursue them. • §200.340 — Grant termination. Because grants are multi-year operations that fund the development of tools, growing of cells, and breeding of animals that often take years, grant terminations mid-grant risk throwing away earlier investments. What’s worse, a grant terminated in the middle will immediately risk the career of a young scientist working on the project and funded by the grant, who relies on this meager support (often only $32K/year) to make ends meet and to advance their training. If my grant would be terminated in this way, I would immediately have to remove three scientists from a project trying to understand how a gene variant causes epilepsy, which would halt progress on this work. • §200.432 — Conference attendance pre-approval. As scientific projects evolve, the types of conferences and the invitations accepted to present may change from the originally written conferences. Scientists and the scientific community should continue to be able to adjust their conference attendance as dictated by the science, not by what had been predicted almost 5 years earlier. In my case, as our work has been found to have cancer implications when the project had been ongoing for 2 years, I would be prohibited from sharing it at cancer-focused conferences, since these were not approved in advance when the grant was submitted in 2022. • §200.461 — Publication costs (now unallowable). While I support a reigning in of publication costs, and I support the work of NIH in trying to find a solution that works for taxpayers as well as for scientists, at the moment we still need to pay for publication costs in order for our work to be shared with the public. This has gotten all the more expensive since open access requirements were created. • §200.300 — DEI and gender ideology prohibitions. Scientists strive to use clear and scientifically-valid language in describing the work they do. It is critically important that we include and purposefully study diverse groups in our work, including those that are not part of the majority US population. This is because the effects of future drugs and treatments may depend on our understanding of how they are metabolized differently between sexes. It is also important to continue to support trainees of every race, gender, and sexual identity so that our scientific workforce continues to reflect our society and asks questions that matter. • §200.220 — Foreign collaboration prohibition. The ban on foreign collaborations will stifle scientists’ ability to work with the best people across the globe. I have had very productive collaborations in the past with non-US faculty and other scientists, and these have enriched the work we have done. • §200.202 — Programs must align with administration priorities. • §200.204 — Grant competitions can be exempted from public notice. This rule would create a lack of transparency that may bias applications to these opportunities to those notified by the current administration. This would mean less time for researchers to prepare high-quality applications. I urge OMB to withdraw all of the provisions set forth in this memo. This memo’s provisions will tear down a scientific research and discovery ecosystem that has been, until now, the envy of the entire world and has produced substantial discoveries that improve human lives. Thank you, Martha R.C. Bhattacharya