Comment from Bryan Mckiver

The Office of Management and Budget ,I am a postdoctoral researcher at Yale University where my work is focused on developing a novel nucleic acid-based anti-cancer therapy and identifying unique DNA damage response pathways that can be targeted for anti-cancer therapy. As a multidisciplinary researcher I believe sections §200.202 and §200.220 of the proposed rules could significantly hinder collaboration between expert researchers across various fields simply based on geographical location of their research institutions. Particularly in a time when international relations are constantly in flux, a friendly relationship today could be a perceived threat tomorrow and back to friendly the following week. This level of instability already puts patients participating in life saving clinical trials in harm, which these new rules have the potential to further exacerbate. Section §200.205 which states that discretionary awards are supposed to “advance the President’s policy priorities” is exceptional vague, given that the president has not directly laid out any policy to advance scientific research efforts, but has instead focused on emphasizing privatization, cost-cutting, and deregulation. As a cancer researcher, I believe that section §200.300 could be particularly detrimental to research focused on breast and urogenital cancers, as these diseases possess sex-dependent impacts on the nation’s population. This could lead to significant challenges in treatment if we as researchers are unable to discuss the impact of uterine cancer on women’s health or the impact of testicular cancer on men’s health in grant applications because they specifically identify the critical need for novel therapeutic approaches treat cancer in a particular group of patients. Lastly, section §200.340 would create an atmosphere of tremendous uncertainty in the field of scientific research at both the academic and private sector levels. The bulk of biomedical research and innovation conducted in the US relies on government funding to sustain institutions, which in turn provide employment opportunities for working class Americans (like myself). Even more so these institutions provide hope for American patients suffering with a variety of acute / chronic diseases (also like myself) that one day there will be a solution that helps them to live a happier and healthier life. Based on these assessments, I urge OMB to withdraw this proposed rule.BryanConnecticut