Regulation for Federal Financial Assistance

Dear Director Vought:

Thank you for the opportunity to comment on OMB-2026-0034. I am an associate professor, and I actively conduct and participate in social science and social work research. I submit these comments in opposition to OMB's proposed rule revising 2 C.F.R. Part 200 (Docket OMB-2026- 0034). I believe this policy change would negatively impact scientific inquiry. I comment specifically on the following provisions: 200.205 (Political Pre-Issuance Review) and 200.202(e) and 200.220 (International Collaboration Restrictions).

200.205 - Political Pre-Issuance Review: Separating federal research funding from political interference is of utmost importance to protect scientific objectivity from political judgment and interference. The proposed pre-issuance review provision (200.205) creates a means through which unbiased, scientific peer review recommendations can be overruled by political appointees. In other words, a peer review process that examines the scientific viability of a research process and its results could be overruled by political agendas. This undermines the credibility of the peer review process, and by extension, American federally funded science. That credibility is built on a system of trust between researchers, institutions, international partners, and the public.

200.202(e) and 200.220-International Collaboration Restrictions: The proposed restrictions on international collaboration would isolate American science and social science research. Social problems and issues are ubiquitous, yet they are experienced differently in different contexts. For example, investigating health and mental disparities, comparative experiences of large-scale social problems and/or cross-national studies, provide needed research in how to most effectively address them. Moreover, exploring and understanding these differences results in more nuanced and holistic responses to complex issues that directly benefit American communities. Isolating American research does not strengthen it; instead, it undermines the ability of the United States to respond to global challenges such as disease and environmental threats.

In closing, this rule would significantly undermine a trusted research process that has earned American research, global respect. By politicizing decision-making, this policy change risks eroding public trust, isolating American research, and undermining scientific objectivity. I urge OMB to withdraw or substantially revise 200.205, 200.202(e), and 200.220 as proposed.

Sincerely,

Beverly Wagner, EdD, MSW, LCSW

Associate Professor of Social Work