Anonymous comment on CFTC-2026-1157, CFTC-2026-1157-0001

Anonymous AnonymousOpposeAdvocacy
Summary: The commenter, an executive director of a small healthcare nonprofit, opposes the proposed rule because it would restrict access to medically necessary transition-related health care and stifle scientific research. They argue the rule promotes viewpoint discrimination, undermines scientific rigor, and creates barriers to sharing federally funded research.
As a nurse practitioner and executive director of a small nonprofit working within healthcare and health and science communication, I am writing to express my deep concern regarding the proposed rule, which, if implemented, would have decades-long deleterious impacts on providers, researchers, patients, and the general public health of the United States (U.S.). By conditioning eligibility for Federal awards on withholding medically necessary and evidence-based transition-related health care (TRH); ending the promotion and discussion of this care; and ending the positive affirmation of trans people’s identities, the proposed rule would widen extant barriers to lifesaving care for transgender, nonbinary, and gender nonconforming (hereafter trans) individuals, particularly youth. This broad prohibition on the “promotion, subsidizing, and facilitation” of TRH or the very existence of trans people is not only contradictory to scientific and medical consensus. It also demands that providers and researchers abandon these populations to maintain funding eligibility. The proposed rule would condition the receipt of critical funds not on the demonstration of rigor and the ambition to serve the public interest, but on alignment with discriminatory political agendas. There are also epistemic harms to the proposed rule’s intentions to promote discrimination against trans youth in research. Health disparities will be further widened by the proposed rule’s impacts on the research infrastructure necessary to develop, evaluate, and improve evidence-based medical care. The resulting reduction in scientific knowledge would disproportionately affect such populations who already experience elevated rates of adverse health outcomes. All scientific and public health research should be driven by evidence, rigor, and public health needs—not by political and ideological biases held by those in power. The proposed rule restricts speech, innovation, and freedom of association by excluding certain viewpoints from eligibility for federally funded awards, effectively mandating viewpoint discrimination. The proposed rule undermines established best practices in scientific rigor, replacing them with a mandate to conform to discriminatory agendas. This includes granting political appointees — who are beholden to the agendas of the current administration, rather than to principles of integrity, objectivity, curiosity, and scientific rigor — the authority to override and ignore peer-review evaluations. By making funds subject to the threat of termination at any time based on discriminatory ideas of “national interest”, researchers and institutions are faced with an untenable uncertainty in planning and sustaining programs. This will discourage vital research out of fear of institutional instability, impacting the careers of countless professionals and the infrastructure of countless research institutions. Its requirements for the consideration of applicants' affiliations risk penalizing researchers based on their associations or viewpoints rather than merit. Modern science depends on the exchange of knowledge through collaboration and the exchange of information, which are essential for evaluating, disseminating, and advancing scientific understanding. The proposed rule's restrictions on publication and travel costs, requiring case-by-case agency approval, would create significant barriers to sharing federally funded research and could widen existing knowledge gaps in minority health. For these reasons, I strongly oppose the rule and urge its withdrawal in its entirety.

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