Comment from Jacob Nason

I am a PhD Candidate in Social Work at Michigan State University; I am a published scholar in the field of sexual violence prevention and response, and have published in peer-reviewed academic journals such as the Journal of Child Sexual Abuse, the Journal of American College Health, the Journal of Interpersonal Violence, and the Journal of Sex Research. I am writing in STRONG OPPOSITION of the proposed rule by OMB because I am deeply concerned that the possibility that the proposed rule, as written, would 1) have a deeply negative impact on efforts to advance science in the US while 2) facilitating an increased likelihood that taxpayer dollars are wasted. As written, the policy mandates that scientists hold viewpoints that align with the president's policy priorities - on its face, this position is clearly discriminatory and an affront to the notion of "viewpoint diversity" that is referenced multiple times in the rule. This violation of scientists' freedom of expression will harm scientific progress in that it requires that scientists align with a particular political perspective in order for their work to be done. That is not how science works - while federal agencies have long dictated funding priorities, it sets a dangerous precedent to enact a rule that allows unelected federal appointees who are not accountable to American citizens to unilaterally cancel previously allocated scientific funding due to a perceived misalignment of political priorities. The result will create a research ecosystem in which politics - and not merit or evidence - prevail. The current rule does not appear to consider the chance that a future federal administration may cut off a scientific study during the middle of a funding period. However, this will certainly occur - regardless of the current administration's priorities, the next administration may have differing perspectives. This rule creates the opportunity for future administrations to cancel projects funded by the current administration (indeed, the current administration did this to many projects funded by previous administrations), without any accountability to taxpayers. In doing so, the current rule nearly guarantees that the politicization of science will lead to wasted taxpayer dollars. While my concerns and expertise primarily are those related to the federal funding of research grants, these concerns apply to other federally funded projects, which could lead to a significant amount of wasted taxpayer dollars and incomplete projects in certain states or areas of the country, based on federal priorities. For these reasons, I urge OMB to withdraw the present rule.