Comment from Anonymous

I am a senior research associate and doctoral candidate at an R1 university, writing in opposition to OMB's proposed rule, OMB-2026-0034, Office of Management and Budget Regulation for Federal Financial Assistance. I strongly urge the agency to withdraw this proposal, which would politicize scientific research, hinder the work of scientific researchers, and damage U.S. research innovation and global relevance. In particular, provisions of the proposed rule related to political review of research funding decisions, international collaboration, grant terminations, and publication and public engagement are gravely concerning. Requiring political review of funding decisions by senior appointees [200.205] subverts the established peer review process and undermines researchers’ ability to conduct meaningful research that advances our collective knowledge and understanding of the world. While the peer review process is not perfect, it is an integral part of the scientific process and helps ensure that proposals are evaluated by experts within the scientific and research community who are equipped to understand their merits. Subverting this process by instead emphasizing political review in order to ensure projects “advance the President’s policy priorities” flies in the face of rigorous standards for scientific methodology and practice and infringes on the political independence that separates research from propaganda. Curtailing international collaboration [200.202] limits U.S.-based researchers’ ability to maintain relevance in an increasingly global era and hinders national competitiveness and innovation. The ability of scientific researchers to work together across international borders promotes scientific progress and ensures that researchers in the U.S. benefit from the expertise of their peers in other countries. Many of the greatest research achievements have been the product of work that spanned nations. Threatening such collaborations jeopardizes the U.S.’s standing in the international research landscape and increases the likelihood that researchers choose to conduct their work in other places where such restrictions are not in place, depriving U.S. institutions of valuable skill and expertise. Rigorous scientific research takes time to carry out, and requires multi-year planning in order to ensure successful completion. Allowing multi-year grants to be cut at any time for political convenience [200.340] precludes completion of the work and risks reducing the ability of researchers to produce meaningful findings. The security of multi-year grants permits researchers to propose and undertake ambitious projects that increase our collective knowledge. Multi-year federal grants are also part of what has made the U.S. a research powerhouse and attracted scholars from around the globe. Artificially creating instability within this structure not only makes the U.S. less attractive to current researchers, it also disincentivizes research as a career path for current students. Finally, proposed limitations on coverage of publication costs [200.461] and concerning language related to participation in “issue advocacy or public messaging that promotes or opposes a particular social, political, or public policy position” [200.450] curtail one of the most essential roles that researchers fill – that of communicators who help ensure that the knowledge they generate can be translated into meaningful action. Like many of my peers, I have pursued a career in research out of a desire to address real problems faced by my community. Sharing what I learn in my research, whether through publishing articles and ensuring that they are available open-access, or by presenting my work in formal and informal settings, is a vital part of that. Restricting how and when researchers can disseminate their findings conflicts not only with the purpose of research, but with tenets of free expression that are central to the U.S. constitution. The proposed rule would have broad and long-ranging impacts that will damage both U.S. research and the nation’s reputation for generations. Strong investment in research, in the form of non-partisan, non-politicized funding mechanisms, is a hallmark of American innovation and competitiveness. Jeopardizing long-established practices that have enabled researchers to conduct rigorous, impactful work is a grave mistake. I urge the OMB in the strongest possible terms to withdraw the proposed rule.