Comment from Samantha Farro
Samantha FarroOpposeAcademic
Summary: A psychologist and research scientist at the University of Colorado opposes the proposed revisions to 2 C.F.R. Part 200, arguing they threaten scientific integrity and independence. The commenter specifically criticizes the move toward political oversight in peer review, the classification of journal costs as unallowable, and the proposed ban on DEI-related research as a form of censorship that will hinder scientific progress.
I am psychologist and research scientist at the University of Colorado. The Office of Management and Budget's proposed revisions to 2 C.F.R. Part 200 represent a profound and dangerous threat to the independence, integrity, and productivity of federally funded science, and three provisions in particular demand urgent opposition.
§200.205 - The proposed revision to §200.205 to replace expert scientific peer review with ideological gatekeeping by political appointees fundamentally corrupts the peer-review system that has made U.S. science and research the envy of the world. The politicization of the grant process directly undermines the merit-based system that has driven my research and all US scientific leadership for decades. Research priorities would be dictated not by scientific promise but by political alignment, which would reduce innovative inquiry and deter the best researchers further away from federal funding and U.S. institutions.
§200.454 & §200.461 — Journal Subscriptions and Publication Costs as Unallowable
Making journal subscriptions and publication costs unallowable under §200.454 and §200.461 would be devastating to research institutions and scientists like myself. This would cripple the basic infrastructure of scientific research. Access to the scientific literature and the ability to publish peer-reviewed findings are not administrative luxuries — these are operational necessities. Barring these costs would cut scientists off from the cumulative knowledge their work depends on, prevent dissemination of taxpayer-funded discoveries, hinder scientific advancement, and ultimately bury results that the public has already paid to produce. This would erode the very transparency that U.S. federal funding is supposed to promote.
§200.218 & §200.300 — Ban on DEI Research
The prohibition on DEI-related research under §200.218 and §200.300 would eliminate broad categories of legitimate, rigorous science — including health disparities research, demographic studies, and social science inquiry — based purely on political objection to the subject matter. This is not oversight; it is censorship. The inevitable result will be a skewed evidence base that blinds policymakers to the real factors driving inequality in health, education, and economic outcomes, causing measurable harm to the very public that federal research is meant to benefit.
The prohibition on DEI-related research under §200.218 and §200.300 would eliminate entire fields of legitimate scientific inquiry — from health disparities research to social science — based purely on political objection to the subject matter. This is not oversight; it is censorship. Researchers studying race, gender, inequality, or population health face the prospect of losing funding not because their science is flawed, but because their questions are disfavored. This will limit discovery of critical insights into the factors shaping human outcomes and create a chilling effect that will hollow out disciplines, skew the evidence base that informs public policy, and ultimately harm the communities that science is meant to serve.