The Office of Management and Budget has proposed a sweeping set of revisions to the Guidance for Federal Financial Assistance. Below I am posting the comment I left. I have a separate blog post explaining the links I used to write this comment, here.
I owe almost everything I have in life to the opportunities afforded to me by federally-funded scientific research in the United States. Enlisting in the “science army” that fully paid for my education gave me a second chance in life that I am eternally grateful for. I want nothing more in life than to contribute back. That is why I oppose the three categories of proposed revisions I outline below, with references to specific sections for each. I can see clearly these changes would utterly destroy scientific research in the United States. The revisions would deny me the opportunity to pursue my own dreams, and deny similar opportunities to a broad swath of Americans.
First of all, I strongly oppose the changes that would take grant-awarding power out of the hands of scientific experts. This is the reason I oppose revisions to §200.205 that require pre-issuance review of every grant by a political appointee. Such a revision would allow appointees to defund the kind of fundamental research I did as a graduate student, on the neural basis of song learning in the songbird brain. Comparative studies like these have revealed brain mechanisms conserved across species, an advance that is critical for treating neurodegenerative diseases such as Parkinson’s and Alzheimer’s at a time when we face an epidemic of such diseases. Likewise, I oppose revisions to §200.430 that allow grant termination without cause, that would similarly allow political appointees to derail fundamental research. Such research moves on timescales much longer than administrations. I know from firsthand experience that we must constantly maintain a fertile soil of fundamental research if we hope to cultivate translational medicines, like the well-known GLP drugs derived from basic research on Gila monster venom. Similarly, I oppose the proposed revision to §200.204, that would allow agency heads to keep grant competitions off public sites whenever they decide it serves the “national interest”. If it had been instituted at the time, this revision could have prevented me from working after graduate school at a small R&D company funded by DARPA programs on AI security. The likelihood of such a scenario is underscored by current events unfolding between the Department of War and frontier AI companies. Thus, the revisions to §200.204 would decimate the long tail of small businesses that often hire scientists like myself who struggle to find work because of the limited number of academic positions.
Second, I strongly oppose changes that prohibit broad categories of research and collaboration. I oppose revisions to §200.202 stating that “programs must align with political priorities of the administration”. Most of the research I have participated in would have been paralyzed if scientists leading it had to find new justifications every four years to satisfy an incoming administration. For similar reasons, I oppose the changes to § 200.220 that would prohibit spending any federal funds on collaboration with “covered foreign countries”. As written, this revision is so broad it would have needlessly prevented a wide range of collaborations in every laboratory I have worked in, with scientists from Denmark to Japan.
Lastly, I strongly oppose revisions that would put restrictions on sharing results. Again, most of the opportunities I have had in adult life are due directly or indirectly to networking with scientists while sharing results. It would have been much less likely that I would have enjoyed any of these opportunities if I had had to do the following: obtain pre-approval for conference attendance, as proposed revisions to §200.432 would require; obtain pre-approval for scientific journal subscriptions and professional memberships, as proposed revisions to §200.454 would require; and find alternate finding for publication because such costs would not be allowed under revisions to §200.461. While I share the frustration of many scientists with for-profit scientific publishing, the changes to §200.461 would do nothing to fix or replace that system, and seem likely to exacerbate the current issues.
In summary, the proposed revisions I outlined above would consist of a scorched earth attack on the research infrastructure of the United States, causing the hard-won scientific advances of my colleagues to wither on the vine before they can bear fruit. I have made every effort to self-edit my own feelings and instead focus on the real effects these changes would have. But I cannot imagine any rationale for these self-destructive revisions beyond some sort of poisonous hatred of the United States and its position as a scientific superpower. If instituted, the proposed revisions would end any hope I have that I can one day as an independent researcher give back to the system that gave me a second chance in life, and they would rob the same opportunities, unique to our country, from an uncountable number of Americans.