Comment on FR Doc # 2026-08940
Amanda HendrixOpposeAcademic
Summary: The commenter, identifying as the Director of a research organization, argues that the proposed clause is problematic due to its unclear compliance requirements. They express concern that the language could be used to easily terminate scientific contracts and suggest that related legal debates should be settled before the policy is implemented.
As the Director of a research organization, I can state that clause 52.222-90 is problematic for a number of reasons, in particular because of the unclear description of compliance. How will the Contracting Office demonstrate compliance by the Contractor? Compliance needs to be more clearly outlined than "The Contractor will furnish all information and reports, including providing access to books, records, and accounts." As currently written, this seems to be simply one more path via which the Administration seeks to easily terminate scientific contracts and grants in this country. Furthermore, the related Executive Order is currently being debated in a number of lawsuits, which should be completed and settled before any related language or policies go into the FAR.