my omb proposed rule burnbook

There’s a rulebook most scientists have never heard of, and it decides almost everything about how their grants actually work: 2 CFR Part 200.

It’s not exciting. It’s not supposed to be. It’s the uniform administrative guidance behind every NSF and NIH award in the country — the fine print nobody reads until someone tries to change it.

Someone tried to change it.

The proposed revisions would let agencies layer political review on top of expert scientific peer review, terminate active grants based on shifting interpretations of “the national interest,” restrict researchers from talking publicly about their own federally funded work, and disallow the publication costs that make federally funded research public in the first place.

So I did the extremely thrilling, deeply bureaucratic thing available to me. I submitted a public comment.

what was actually on the table

Four provisions worried me enough to write something down.

§200.205 would add political review on top of expert scientific peer review, without ever defining the standard being applied.

§200.340 would let agencies terminate active, competitively awarded grants over evolving interpretations of “national interest” — after the science has already started, careers have already been staked on it, and students are already mid-PhD.

§200.421 would restrict the public communication and outreach that grant-funded researchers do.

§200.461 would disallow publication costs, while federal agencies simultaneously require the public-access compliance those costs pay for.

Read together, these don’t look like four unrelated line-item edits. They look like one argument: that federal science funding should answer to political winds instead of expert review, and that the public doesn’t necessarily get to see what its money paid for.

the comment, in full

I am writing in strong opposition to the proposed revisions to 2 CFR Part 200.

I submit this comment in my personal capacity and not on behalf of any institution or organization.

I am a computational biologist and early-career biomedical researcher whose training has been supported through federally funded research and training programs, including the National Science Foundation Graduate Research Fellowship Program (NSF GRFP) and the National Institutes of Health Initiative for Maximizing Student Development (NIH IMSD). My research focuses on understanding how the three-dimensional organization of the genome responds to environmental stress, work that depends on stable federal investment, long-term planning, interdisciplinary collaboration, and the open dissemination of scientific knowledge.

Federal investment in my training has extended far beyond my own research program. The opportunities provided through these programs have enabled me to dedicate my career not only to scientific discovery, but also to expanding public access to science. I have founded a nonprofit organization focused on science communication and public engagement, developed programs that connect researchers with local communities, trained scientists to communicate effectively with policymakers and the public, hosted a podcast highlighting the diverse pathways into science, and worked extensively in science policy and outreach. These efforts were made possible because federal investments gave me the stability, mentorship, and professional development needed to build initiatives that serve communities well beyond my own laboratory. They represent exactly the kind of broader societal impact that federal research investments are intended to create.

Because my work spans research, mentorship, science communication, nonprofit leadership, and science policy, I have seen firsthand how federal funding strengthens not only scientific discovery but also the public trust, workforce development, and community partnerships that allow science to benefit society. These experiences have given me a broad perspective on how the proposed rule would affect not only individual investigators, but the research ecosystem that supports scientific discovery and innovation in the United States.

I am particularly concerned by the proposed changes to §200.205, which would increase political involvement in funding decisions while diminishing the role of expert scientific peer review. Scientific merit review exists because evaluating complex research proposals requires technical expertise. Peer reviewers assess whether projects are rigorous, feasible, innovative, and likely to produce meaningful advances. Introducing political review based on undefined standards creates uncertainty that researchers cannot reasonably anticipate or plan around. The strength of the American research enterprise has long rested on funding the best science through expert evaluation, not on shifting political priorities.

I am also deeply concerned about the proposed revisions to §200.340, which would allow agencies to terminate active grants based on changing interpretations of the national interest. Modern biomedical research is inherently long-term. My own research required years of experimental development, computational analysis, and collaboration before producing publishable findings. Graduate students, postdoctoral researchers, and research staff make career decisions based on the expectation that competitively awarded grants will remain stable so long as investigators fulfill their obligations. Allowing awards to be terminated for reasons unrelated to scientific performance creates uncertainty that discourages ambitious research, disrupts training, and makes it substantially more difficult to recruit and retain the next generation of scientists.

The proposed revisions to §200.461 are equally troubling. Federal agencies increasingly require researchers to make federally funded research publicly accessible so taxpayers, clinicians, educators, policymakers, and other scientists can benefit from publicly funded discoveries. Publication costs are often a necessary component of fulfilling these public-access requirements. Disallowing publication costs while simultaneously expecting researchers to comply with federal public-access policies creates conflicting expectations and ultimately limits the dissemination and impact of federally funded research.

As someone who has dedicated much of my career to improving communication between scientists and the public, I am particularly concerned by the proposed restrictions on public communication under §200.421. Scientific research provides its greatest value when discoveries extend beyond academic journals and reach patients, educators, community leaders, policymakers, and the public. Throughout my career, I have worked to develop innovative approaches to public engagement that help communities better understand and participate in science. Restricting grant-supported communication and outreach would make it more difficult for researchers to explain their work, build public trust, and ensure that taxpayers see the value of the research they support. Public engagement should be recognized as an essential component of federally funded research rather than treated as a peripheral activity.

More broadly, I worry that these proposed revisions move the federal research enterprise away from the principles that have made the United States a global leader in science and innovation. American scientific leadership has been built through rigorous peer review, stable long-term investment, open collaboration, transparent communication, and the ability of researchers to pursue evidence wherever it leads. Policies that increase political uncertainty, discourage communication, and reduce the stability of research funding risk slowing scientific progress at a time when the nation faces increasingly complex challenges in public health, national security, biotechnology, artificial intelligence, energy, and environmental resilience.

My professional work has convinced me that public trust in science is strengthened through transparency, openness, accountability, and meaningful engagement with the communities that science serves. These goals are best achieved by empowering researchers to conduct rigorous science, communicate their findings openly, and collaborate broadly, not by introducing additional barriers to research, publication, and public engagement.

For these reasons, I respectfully urge the Office of Management and Budget to withdraw the proposed rule. At a minimum, I request that the provisions described above, especially including §200.205, §200.340, §200.421, and §200.461, not be finalized. Preserving an independent, merit-based, and transparent federal research enterprise is essential to maintaining the United States’ leadership in scientific discovery, innovation, and public service.

Respectfully,

JP Flores, Ph.D.

why bother writing a public comment at all

Public comments are, technically, part of the administrative record. Agencies are required to consider them.

Practically, most people assume nobody reads them, so nobody writes them, so eventually that assumption becomes true on its own.

I don’t know if one more comment moves anything.

I do know that if the record only contains silence, silence gets read as consent.

So: for the record.