Comment from Sarah Goetz

I am submitting this comment to express my strong opposition to the proposed changes to 2 CFR Part 200 (Docket OMB-2026-0034). I am a cell and developmental biologist studying fundamental mechanisms of how cells communicate during embryonic development, and how dysregulation of these processes leads to diseases from developmental disorders to cancer to neurodegeneration. I am currently an Associate professor at Duke University, commenting on my own behalf and independently of my employer. My work has received crucial support from several federal grants over more than 25 years. These include a T32 training grant while I was a graduate student at UNC Chapel Hill (Integrative Vascular Biology), a K99/R00 award supporting my postdoctoral work and transition to independence (NICHD), an R01 (NICHD) and an R03 (NCATS) supporting work in my laboratory. I have many concerns about the proposed rule, including that it would curtail foreign collaboration (§200.220) and would restrict the ability of scientists to communicate their work widely through publications and attendance at conferences (§200.432 and §200.461). However, my principal concern is that these proposed rules would replace a system that has operated with a high degree of fairness, openness, and transparency with one that is arbitrary and capricious. Specifically, section §200.205 grants political appointees the final authority to approve grants, rather than deferring to scientists with expertise in the relevant field who have invested time in reviewing and writing detailed critiques of the grants in question. The new rule dramatically reduces the transparency and fairness of the process because it essentially allows political appointees to reject for arbitrary reasons grants that were deemed by experts, using publicly accessible criteria, to be of the highest impact. §200.340 further compounds this arbitrariness by allowing for the termination of any grant at any time if it is deemed “inconsistent with program goals or agency priorities”. This is overly broad and essentially allows grants to be terminated for any reason. Additionally, §200.339(b) broadens the basis under which individuals can sue to oppose federal funding under the False Claims Act, and allows the Department of Justice to join their suits. Since “violating the terms and conditions of a Federal award” would be defined incredibly broadly or even arbitrarily, this would essentially allow individuals to sue to rescind grants for almost any reason. Seeking grant funding has always been a highly competitive and uncertain process. But implementation of these rules will create an extreme degree of uncertainty, even after a grant is awarded and a principal investigator fully complies with the terms of the award. These conditions will be untenable to most US scientists, and will dissuade many from pursuing scientific careers in the first place. I strongly urge OMB not to implement any of the changes cited above.