Comment from Kimberly Lamm

My name is Kimberly Lamm. I am a professor at Duke University in Durham, North Carolina. My research is in the humanities, though these changes are primarily aimed at the sciences, these proposed changes would be detrimental to the fields in which I work. My research has benefited from the many scholars who have received the National Humanities Grants, as they have furthered and deepened scholarly conversations. The proposed changes undermine academic freedom. The materials indicate that the federal government can cancel already awarded grants if it determines that they are “inconsistent with program goals or agency priorities,” even if peer review process has already made a selection. Section 200.339 further undermines academic independence, as it allows private individuals to sue awardees if they are perceived to be out of keeping with those terms and conditions, and allowing the federal government to add the weight of the Department of Justice behind those lawsuits. This is a real threat to free expression and the exchange of ideas. We have seen the glaring absence of knowledge when it came to DOGE. There are already mechanisms within Federal agencies to make awardees comply with their terms and conditions, and the proposed guidance could be easily used as a tool of political harassment. This proposed guidance threatens the integrity of the funding process, which has relied on the processes of peer review, which are foundational to research. In addition, the proposed new criteria would prevent federal funds being used for many professional activities that are key to research and publication in the humanities. They would make it difficult to use funds for membership dues or conference attendance unless conference funding is requested years in advance of the research completion, which would be an undue burden. Membership and timely conference participation are key to professional community engagement and peer review of research. My work has benefited enormously from the process of presenting my work to others at conferences. Funds would no longer be used to contribute to the costs of publication, which will make it challenging to comply with the requirements to make research publicly available. It seems clear that routine publication costs, which support peer review and work that guarantees the integrity of research outputs, would be generally unallowable under federal awards. Neither would subscription costs be allowable, which would jeopardize researchers’ access to peer reviewed scholarly sources and undermine the viability of academic journals. I am particularly concerned with Section 200.202 of the proposed rule, which would require that all federally funded projects be designed around a “domestic-first framework” and demonstrate that they are “in the national interest of the United States.” These terms are not defined, and it isn't clear how they would be measured or assessed. All scholars in the humanities—not just those who focus their research outside of the United States—are enriched by international exchanges. State-sponsored intellectual exchanges came about in the aftermath of World War II and during the Cold War, when the United States promoted international education with the goal of sharing knowledge across national borders. These exchanges strengthen international ties and promote global stability. My work in art practices that arise out of the Middle East and Korea has benefited enormously from international exchanges among scholars. These proposed changes impose political litmus tests on research at every stage, from the early stages of speculation and exploration to the final publication of research findings. They will be detrimental to every academic discipline. I urge OMB to withdraw these proposed changes, reject 200.339 and 200.202 and not finalize this rule in its current form. Sincerely yours, Kimberly Lamm