Comment from Claire Riggs

Claire RiggsOpposeAcademic
Summary: A biology professor at a small liberal arts college opposes the proposed regulations, arguing that they allow for abrupt award terminations and prioritize political interests over scientific merit. The commenter expresses concern that these rules will erode trust in federal funding, waste research resources, and curtail the ability to conduct rigorous science.
I am a biology professor at a small liberal arts college and have just finished my first year. I teach classes in animal physiology and cell biology, and run a research program on cellular mechanisms of the stress response. My lab is currently funded by the NIH. Since January of 2025 I have been devastated to watch the destruction of science as Ive known it in the US. In April 2025 the NIH program my grant is part of was terminated and I was informed that anticipated subsequent years of funding would not be possible. My funding was, fortuitously, reinstated through legal action; though this was not the case for everyone. Having experienced this first-hand, I am extremely concerned by 200.340. This rule would permit such wrongful and abrupt award termination. The potential for grants to be terminated at any time due to changes in priorities threatens scientific progress as it removes the stability necessary for successfully planning and performing research. I plan and carry out experiments with the funding timeframe in mind. The notion of priorities changing so quickly that an award must be terminated during an award period is distressing. How are we, as scientists, supposed to propose and conduct quality research if the government may strip us of our funding at any moment? Impracticalities aside, 200.340 will erode trust in federal funding agencies and tank scientific morale. If my award is terminated in the middle of the award period I will have to terminate lab personnel and leave projects unfinished, wasting the initial funds and effort invested. And - even when I have funding, I will live every day with the fear of it disappearing overnight, which will make me question and hesitate to make essential long-term plans, like hiring. I am similarly very concerned by 200.205 federal agency review of merit proposals. Inserting political appointees into the funding decision process sidelines relevant expertise and allows science to be vetoed if the administration or president dont like the proposal. The explicit requirement for proposals to demonstrably advance the Presidents policy priorities and remove anything deemed to promote anti-American values is vague and dangerous. It is the job of trained, experienced scientists to assess the merit of scientific proposals through peer review. This, like 200.340, breaks trust in scientists and threatens to corrupt science in the US. Again, how are we, as scientists, meant to do good science if proposals must cater to political winds? Scientific merit, and the expertise to assess it, must not be superseded by political interests if the US wishes to maintain progress and integrity in its scientific enterprise. I am also concerned by 200.206 (denying grant applications based on organizational affiliation), 200.202e (prohibiting awards with international components), 200.432 (Conference attendance requirements), 200.454 (Journal subscription costs), and 200.461 (Publication and open-access costs). All of these restrictions curtail researchers ability to conduct impactful and rigorous scientific research that is essential to progress in the US.

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