What is your favorite molecule?

Is it RNA? Is it chromatin? Is it “membrane protein”? 

The reason I ask this question is because I was chatting with a student this week, and I brought up the Office of Management and Budget (OMB) proposed rule on Federal Financial Assistance. The student replied, 

Yes, I heard something about that, but I’ve been busy in the lab and haven’t really had the time to understand what the big deal is. Plus, I’m just tuning out politics these days so I can concentrate on my science. 

Well, here’s the big deal: among many other bad things that could happen, section (§200.340) of the OMB proposed rule will allow a political appointee to do a grant search using your favorite molecule as the query and then summarily cancel that grant – immediately – without notice. Poof! Gone! 

You might not be so concerned if you are part of union that guarantees your stipend, but you still need funds to buy reagents and pay for instrument time and maintenance, and that money needs to come from somewhere. There is no magical money tree raining down dollars for these expenses at any research institute that I know. Your PI cannot magically fix this either. 

Even if you are among the lucky ones and the grant that supports you is not summarily cancelled, do you want to present your research findings at a conference? Section (§200.432) requires prior approval for using funds for each specific conference you might want to attend. Like, years in advance of when you might have a discovery and want to present your awesome work at a conference that has not even been announced yet, you will be required to obtain prior approval. OK, yes. OMB left the door open to ask for approvals once a grant is funded, but this will be an onerous administrative burden on granting agencies and is likely to result in fewer in-person data-sharing and networking opportunities.  

Or maybe you want to publish your paper in a high-quality journal? Section (§200.461) of the OMB proposal disallows the costs to do so. Are you going to pay these publication charges out of your own pocket? 

None of this is hypothetical. This OMB rule proposal is a Five Alarm Fire. 

This OMB proposed rule needs a big response from the scientific community. That means you need to act. In fact, we all need to act. And we need to recruit our non-science families and friends to act as well.  

Here is what you can do right now: Inform yourself and submit Comments. 

The full Devastation of Science that could take place is embodied in the OMB 422-page proposal. The OMB “plain language’ summary is 108 pages. More power to you if you have time to read either of these documents, however our BPS policy folks have distilled these down to a simple 4-page summary memo here. 

BPS also held a webinar with policy experts to walk you through the proposed changes. A replay of that webinar can be viewed here.  

BPS has partnered with the American Physical Society (APS) to use their submission tool, which makes submitting comments that cite the Code of Federal Regulation (CFR). Our policy experts believe that is very important to cite the CFR, and the APS tool makes this easy peasy. If you have submitted a comment elsewhere without this citation, consider submitting it again with the CFR. 

The link to the APS tool can be found here. 

 

• For maximum effectiveness, your comments need to be unique to you. For this reason, the BPS has not provided you with any kind of template to just copy and paste. If you do that, your comment will be lumped together with all other similar copy and paste comments and will only count as 1 comment in the eyes of OMB. 

• If you want to keep a copy of your comment, compose it using a writing app on your computer so you’ll have a local, backup copy. 

• Comments are limited to 5000 characters. But you can comment as many times as you want. And if you like to write, you can submit a longer comment in PDF form. Longer comments are not necessarily better, though, and a short, effective comment is better than no comment at all. Strive for good, not for perfect.  

• A good strategy is to use the APS tool and submit a focused, personalized comment for each of the CFR sections. 

• Keep in Mind: Most institutions will want you to use your personal email address when you submit your comments, so that you do not “represent the institution.” Check with your institution for guidance relevant to your situation. 

• You can submit anonymously. Are you  worried you will be targeted? Do you have a fellowship and worry that it will be taken away? Do not shy away from commenting. Just comment anonymously.   

• Explain this Five Alarm Fire to your nonscience friends and family. Here’s a guest article in the New York Times that makes the case for discovery-based, curiously driven research and shows examples of its real-world effectiveness.  

 

If we each do our part, together we can ensure that scientific excellence, deep innovation, and discovery continues to thrive in the US. The deadline for comments is one week from today on July 13th. Act now. 

 

--Karen G. Fleming