Comment from Anonymous

I am a Federally funded faculty member at a public research university conducting biomedical research. While I support the aspiration to maximize researcher time spent on research and the benefits of public research investment, I strongly believe that the rule as proposed will have the opposite effect. Here are a few specific examples: The Executive Summary states: “§ 200.202, the proposed regulation encourages the use of multi-year awards, thereby reducing the frequency of applications and individual awards that are generated each year.” In the reality experienced by my colleagues, multiyear awards do not lead to any reduction in reporting or grant-management paperwork, since funding is still reviewed and released year-by-year even when awarded on a multiyear basis. Instead, the net effect of multiyear funding has been to reduce the total number of awards made during the transition period. As a result, NIH award success rates have decreased to the lowest level in history. The lower the success rates, the greater the number of grant proposals researchers must submit to maintain their odds of being funded. This has already led to investigators spending more time than ever on crafting, submitting, and resubmitting grant proposal, and less time than ever on doing research. This has led the NIH to implement, for the first time, a cap on the total number of proposals that one investigator can submit per year. It is now capped at 6 proposals per year. In my experience, preparing each proposal takes approximately 100 hours of an investigator’s time. Much of this time is not scientifically productive. The Executive Summary describes the purpose of § 200.205 as “to strengthen requirements for agency merit review.” In reality, it will weaken merit review by letting political appointees overrule the professional judgements of peer reviewers and program officials. It will also make it much easier for current or future political appointees to attach political requirements unrelated to the merit of the research. Section 200.340 describes the purpose as providing “additional clarity regarding reasons available to Federal agencies for discretionary terminations of Federal awards.” In reality, it will give agencies even more power to terminate awards made through the rigorous peer-review process at any time and for virtually any reason. Far from increasing clarity, this rule will increase uncertainty and anxiety around the availability and sustainability of funding. It will put even more pressure on investigators to constantly apply for new awards in case the current ones are arbitrarily and unpredictably cancelled. Moreover, it would make researchers afraid to publish any findings that contain any real or perceived challenge to an established consensus and/or the governing political ideology. The effect of such self-censorship and incentivized conformity would be disastrous for the progress of American science, technology, and medicine. Section 200.432 states that “costs for attending conferences are allowable only if participation in the conference is expressly approved by the agency and included in the terms and conditions of the award.” In practice, this will further increase the amount of paperwork and time that investigators and program staff must devote to grant management post-award. It will also disincentivize travel to scientific conferences, which remain the best way for researchers to exchange ideas and form and maintain professional networks. US researchers are prominently represented at international scientific conferences today, which makes American research labs and research directions highly attractive for global scientific talent and influential at home and abroad. By undermining the exchange of ideas, international representation, and the ability to shape global research directions, this rule will hamper American researchers and cede scientific leadership to other countries.