Comment from Christopher Miller

Opposing OMB's Rule Amending 2 CFR Part 200 (Docket ID OMB-2026-0034) I am writing as a cancer researcher at Washington University in St Louis, currently supported in part by several NIH grants. I firmly oppose OMB's proposed revisions to 2 CFR Part 200 as currently written. If implemented, this rule would fundamentally weaken the merit-based, scientifically driven grantmaking system that has made the US the leader in global research and innovation for a century. We all want to improve cancer treatments, and these rules risk slowing progress for decades. I urge OMB to withdraw or substantially revise the following provisions: ** Expanded Agency Discretion in Funding Decisions [200.202, 200.204–200.206] I have participated in peer review from both sides, and while no system is without flaws, I remain convinced that NIH study sections do a good job of objectively deciding the best research to fund based on _scientific merit_. Inserting shifting political whims into the process would cause instability and bias into a system that depends on consistency and expert evaluation. The goal should always be to fund the best science, not the most politically convenient science. ** Termination of Active Grants at Agency Discretion [200.340–200.343] Allowing political appointees to terminate awards at any time would be catastrophic for multi-year research programs. Projects in our lab depend on long-term investments for things like establishing animal colonies or tracking patient's responses to disease. Terminating grants mid-project means that the investments already made are wasted. Furthermore, unappealable terminations remove any due-process check on arbitrary decision-making. ** Restrictions on International Collaboration [200.220] Science is inherently collaborative and international. Cutting off legitimate scientific partnerships only weakens the ability of US scientists to innovate and to recruit top global talent. It also risks ceding scientific leadership to other nations. ** Pre-Approval Requirements for Conferences and Professional Memberships [200.432, 200.454] Requiring agency pre-approval for scientists to attend conferences or have membership in professional societies would create a significant new administrative bottleneck. Venues such as the American Association for Cancer Research (AACR) annual meeting are essential for sharing findings, building collaborations, and accellerating research. Case-by-case federal pre-approval — with no defined timeline or standard — risks delaying or blocking routine scientific exchange that has never previously required this level of oversight. Collectively, these provisions would replace scientific merit with political discretion, introduce unprecedented instability into multi-year research, isolate American science from global collaboration, and add substantial new administrative burdens — all without a demonstrated benefit to research quality, efficiency, or accountability. I urge OMB to withdraw these provisions and instead engage the research community in developing reforms that preserve the integrity, stability, and independence of federally funded science. Christopher Miller Associate Professor, Medicine/Oncology Washington University in St Louis