Comment from Anonymous

I am a third year PhD candidate at Boston University being funded by an R01 NIH grant. I have many concerns regarding the OMB’s Proposed Federal Financial Assistance Rule and will specifically discuss section 200.340 titled “Grant termination” in this comment. Firstly, many people, including myself, rely on grant money as our source of income. My research is being funded for five years which gives me five years of confirmed income. This reduces stress and allows for a long term plan to complete the project within the time period of the grant. Taking away these grants without warning will halt progress, create a rushed environment and waste money. First, if many researchers are starting on research projects under grants that get taken away part-way through, they then lose all of that time and have to re-start. Personally, if my grant got taken away, I may have to find a new lab or figure out new funding. This would mean potentially restarting my five year PhD program. As a third-year, this would take away nearly half of my progress getting this degree plus additional time to find new funding before I can restart. For Principal Investigators, if they lose funding that is supporting their income, their whole lab could shut down until they can find new funding, which would impact every single person in that lab. Principal Investigators spend a lot of time making sure that they line up funding and applying for grants to make sure that their labs are supported. If grants start getting removed randomly, this can impact the whole ecosystem of how the lab functions and is able to support its members. Second, if everyone is worried that their grants will get taken away at any given time, it shifts the mentality from doing the work in the most efficient, effective way that completes the work on time to rushing through the work to try to get it done as quickly as possible before the money gets taken away. This fear could lead to people cutting corners or not taking the time to do the best quality work. I believe that this could lead to even more issues with reproducibility and falsification solely because people feel pressure to get work done before the money is gone. I want to feel like I have the time needed to do the best quality work that is reproducible and organized. Finally, these grants give out large amounts of money. If that money is used to produce data used in downstream analyses, most of that money will be used right away. If all of that money gets put into projects that cannot be completed, the majority of that money is now wasted. I think the system of being diligent about who receives grants is important because it is a lot of money to give. However, once the money is given, grants should only be removed in an extreme case of falsification of results, unsafe practices or use of the money on something not agreed upon receiving the grant. As a third year student, I was on another training grant my first year and have now been on my current grant for a year. In one out of five years, all of the data has been generated and the storage space has been paid for. This is a large portion of the grant money that would be wasted if my grant were to be cut. Overall, the threat of grant termination will lead to greater falsification and mistakes due to people feeling rushed, breakdown of lab funding, wasted money and time, and overall halt in progress and productivity. Already, the decrease in grant funding has delayed progress in research. I fear that grant termination will continue to delay progress of scientists going through training and reduce the speed that we are putting out new findings. The United States has been a leader in scientific discovery. It would be a shame for us to lose that title. It would decrease our greatness and our position as one of the leading counties in the world.