Comment from Christopher Huynh

Christopher HuynhOpposeAcademic
Summary: A doctoral candidate in Industrial-Organizational Psychology opposes the proposed regulations, arguing that they undermine scientific rigor by allowing political appointees to override expert peer review. The commenter also expresses concern that the rules would jeopardize long-term research stability, restrict essential scholarly activities like conference participation, and create barriers to international collaboration.
To the Office of Management and Budget: I am a doctoral candidate in Industrial-Organizational Psychology at Virginia Tech whose research focuses on artificial intelligence, machine learning, psychometrics, organizational behavior, and the development of evidence-based approaches to workplace assessment, learning, and inclusion. My work has been published in outlets such as the Journal of Applied Psychology and Industrial and Organizational Psychology, supported by competitive grants, and disseminated through national and international scientific conferences. I strongly oppose the proposed changes in docket OMB-2026-0034 because they would undermine the scientific processes that make federally funded research rigorous, innovative, and globally competitive. Section 200.205 is particularly concerning because it would permit political appointees to override expert peer review in funding decisions. My research relies on highly specialized evaluation by subject-matter experts in areas such as machine learning, natural language processing, psychometrics, and organizational science. These are technical fields where methodological quality and scientific merit can only be appropriately assessed through independent peer review. Allowing political considerations to supersede expert evaluation risks diverting federal resources away from the most scientifically sound proposals and toward projects favored for ideological reasons rather than empirical quality. I am also deeply concerned about Section 200.340, which would allow discretionary termination of grants at any time. Many of my projects involve multi-year research programs, including longitudinal measurement development, systematic reviews, meta-analyses, AI model development, and educational interventions. Such work requires long-term planning, research assistant support, software development, participant recruitment, and sustained collaboration among investigators. The possibility that funding could be terminated without traditional scientific justification would discourage ambitious research and make it significantly harder for early-career scholars to pursue innovative projects. Additionally, Sections 200.432, 200.454, and 200.461 would severely restrict conference participation, scholarly subscriptions, and publication costs. These activities are not peripheral expenses; they are central mechanisms through which scientific knowledge is evaluated, improved, disseminated, and translated into practice. My own research program depends heavily on presenting findings at conferences such as the Society for Industrial and Organizational Psychology and the Academy of Management, maintaining access to scholarly literature, and publishing peer-reviewed research. Restricting these activities would slow scientific progress and reduce the return on federal research investments. Finally, Section 200.220 would create barriers to international collaboration at a time when AI, organizational science, and data-intensive research increasingly depend on global partnerships. Scientific leadership is strengthenednot weakenedby responsible international collaboration. I respectfully urge OMB not to implement these provisions. Collectively, these changes threaten scientific independence, weaken peer review, discourage innovation, impede dissemination, and diminish the integrity and global competitiveness of American research. Federal research policy should strengthen evidence-based decision-making, not replace it with political uncertainty and administrative barriers. Thank you for considering my comments.

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