To preserve American scientific innovation, Brown urges revisions to proposed grant regulations

PROVIDENCE, R.I. [Brown University] - In a formal comment submitted to the White House Office of Management and Budget (OMB), Brown University called on the federal government to preserve longstanding policies that have helped make the United States the global leader in scientific research and innovation.

On Friday, July 10, Brown Provost Francis J. Doyle III and Vice President for Research Greg Hirth submitted the comment in response to OMB's proposed revision of the federal Uniform Guidance - regulations that govern how universities and other organizations administer federal research funding each year.

"Since World War II, the federal government and the nation's leading research universities have partnered to make the U.S. the global leader in scientific progress and innovation," Doyle and Hirth wrote. "This federal-university research partnership has led to cutting-edge medical procedures and cures, produced defense technologies that advance national security, set the stage for future scientific discovery, and trained researchers who make breakthroughs that benefit society and everyday quality-of-life."

That longstanding partnership works because federal agencies set public goals, experts evaluate the science, and universities make the people, facilities, systems and long-term commitments needed to carry the work through, they argued - and the proposed rule, as drafted, would make the partnership less stable.

"It would introduce standards that shift after awards are made, reduce the role of expert reviews, impose blanket administrative requirements without regard to recipient risk, restrict ordinary dissemination of research findings, and allow performing awards to be suspended or terminated without the procedural protections needed to correct errors before research is interrupted," Doyle and Hirth wrote.

Brown's comment noted that the University fully supports OMB's stated goals of improving transparency, accountability and oversight in federal research awards, ensuring that public funds are used for their intended purposes, and upholding compliance with federal law. The question is not whether federal awards should be subject to strong oversight - they should, Doyle and Hirth said - but whether the specific revisions proposed in the new rule are necessary, legally justified and reasonably respond to those stated purposes.

On that question, the proposed rule falls short, they asserted, before providing detailed responses to provisions in the proposed rule around six principal concerns:

• the administrative burden the rule, if finalized, would impose on federal award recipients;
• its chilling effect on federally supported research across disciplines;
• its displacement of expert scientific merit review by political judgment;
• its reliance on standards too vague to administer consistently;
• its disregard for the reliance interests of institutions carrying out active multi-year awards;
• and its denial of basic procedural fairness.

Brown's full comment is available on the University's website.