It's long. It's wonky. It has a lot of footnotes that I hope are correctly formatted à la Blue Book.

Most importantly: It's submitted!

There's a lag between submission and posting because there's an approval process, so I'm sharing it now. (If you're reading this in your email inbox, click the big green button below to see it on the web.)

Author note: this is a LaTeX --> Markdown conversion via script that I have cleaned up by hand; apologies for any new errors introduced. I have already found old errors that are in the submission, so that just goes to show a real human wrote it, I guess?

Full Comment on OMB-2026-0034, July 11, 2026

I submit this comment on Docket 2026-0034 solely in my personal capacity. Although I have served in leadership, advisory, and volunteer roles within professional societies, academia, Congress, and the National Science Foundation, the views expressed here are my own and should not be attributed to any employer, agency, professional society, or affiliated organization. To contextualize my comments and establish my credibility, here are important biographical details.

• I am a Professor of Mathematics and Statistics, and the Director of the Data Science Program Committee, at Hamilton College. Hamilton is a primarily undergraduate institution (PUI) with a strong record of preparing students for careers in science, technology, engineering, and mathematics (STEM).

• As a professor, I have been a federal grant recipient and beneficiary, having served as co-PI, key personnel, a research mentor, and a supported participant on multiple federally funded research, conference, workforce development, and professional development projects, including National Science Foundation (NSF) supported workshops, conferences, research experiences for undergraduates (REUs), and primarily educational initiatives. I have also served as a merit review panelist for the NSF.

• While in graduate school, I was supported by federal investments in STEM talent development. From 2007-2013, I was one of many University of Nebraska-Lincoln graduate students supported by NSF programs like: Mentoring through Critical Transition Points in the Mathematical Sciences; the Robert Noyce Teacher Scholarship Program; Graduate STEM Fellows in K-12 Education; Graduate Assistance in Areas of National Need; and other federally funded training and professional-development opportunities via conference grants and my advisor's research grants. ¹

• From 2022--2023, I served as an American Association for the Advancement of Science (AAAS) Congressional Science and Technology Policy Fellow on the Majority Staff of the U.S. Senate Homeland Security and Governmental Affairs Committee under Chairman Gary C. Peters. My portfolio included federal financial assistance policy, including grants and cooperative agreements.

• From 2023--2024 and then into 2025, I served first as an AAAS Science and Technology Policy Fellow and later as a (part-time) federal expert within NSF's Division of Information and Intelligent Systems (IIS) in the Directorate for Computer and Information Science and Engineering (CISE). In those roles, I helped develop funding opportunities and partnerships intended to advance national (and especially congressional) priorities in artificial intelligence, computing, and scientific research.

• I am also a resident of New York's 22nd Congressional District, where federal grants and cooperative agreements support educational institutions, nonprofits, local governments, scientific research, workforce development, and community services.

These experiences give me an unusual platform from which to observe federal financial assistance: as a student, researcher, educator, grant recipient, reviewer, congressional staff member, NSF employee, and citizen. My comments are therefore informed both by direct experience administering and participating in federally funded activities and by professional experience examining the policy and oversight frameworks that govern them.

The following pages enumerate my concerns with the proposed changes (and offer constructive alternatives) through the lenses of "Administrative Burden" and "Chilling Effects on U.S. Research and Scientific Workforce."

About NY-22

In fiscal year 2022, federal grants provided $265 million in project grants and cooperative agreements (with $21 million coming from the National Science Foundation alone) to NY-22. ² This is a huge influx of money to a district where the median household income is $75,000; it works out to roughly $800 per district household. ³ These awards support local governments, tribal entities, colleges and universities, school districts, nonprofit organizations, hospitals, community organizations, research institutes, workforce development initiatives, infrastructure projects, and public services. For a small town like mine in NY-22, receiving a modest grant from FEMA (with equally modest administrative and compliance expectations) can be the difference between a deadly fire and a fire suppressed thanks to grant-funded training and equipment. ⁴

Section-Specific Comments

National Science Foundation (NSF).

[Chapter XXV].

The NSF's merit review system is the result of deliberate congressional design. While national priorities appropriately inform agency investments, Congress did not establish NSF as a mechanism for political review of scientific ideas. To the extent the proposed rule requires funding decisions to be driven by political or ideological considerations rather than expert scientific review, it is inconsistent with the structure Congress established for NSF programs. Indeed, Congress has spent decades directing NSF to identify talent wherever it exists, strengthen research capacity in under-served regions, broaden participation in STEM, and develop the scientific workforce needed for national competitiveness. ⁵ The cumulative effect of the proposed provisions and heavy-handed micromanagement of federal agencies will move NSF in the opposite direction.

My career has intersected with NSF from nearly every angle available to an academic mathematician. I was supported as an undergraduate through NSF-funded programs. I later participated in NSF-funded research and conference activities, served as a proposal reviewer, organized NSF-supported workshops, mentored students supported by NSF programs, worked on congressional oversight of federal programs (including 2 C.F.R. 200) as an AAAS Congressional Fellow in the United States Senate, worked within NSF as an AAAS Science and Technology Policy Fellow, and was subsequently retained as an expert to continue working on my portfolio until the mass dismissal of NSF experts in February, 2025.

These experiences have given me an unusual opportunity to observe the federal research ecosystem from multiple perspectives. My concerns about this proposal arise not from opposition to accountability or oversight, but from concern that the proposed changes will weaken the mechanisms that have historically allowed NSF to identify talent, foster discovery, and maintain American leadership in mathematics and data science---using under 10 cents per dollar on its own infrastructure in order to pass more than 90 cents per dollar to grant recipients. The civil servants who make this happen are incredible people, motived by the desire to serve their country, fulfill NSF's mission ("To promote the progress of science; to advance the national health, prosperity, and welfare; to secure the national defense; and for other purposes," as written in the NSF Act of 1950, P.L. 81-507), and build productive, mutually accountable relationships with their recipient communities. The rule-making process that NSF uses to turn the guidance in the current 2 C.F.R. 200 into agency rules is already effective, and they achieve the same high-level goals that the proposed changes seek to address (oversight, recipient burden, accountability). The proposed changes would be unnecessarily disruptive.

I oppose the proposed OMB changes to NSF-specific operations. Furthermore, I urge OMB to consider my section-by-section comments below to the changes in federal financial assistance administration, particularly 2 C.F.R. 200.

Administrative Burdens

Because of my previous work involving federal grant administration and oversight, I strongly support accountability and responsible stewardship of taxpayer funds. I applaud public transparency tools such as USAspending, NIH RePORTER, and NSF Award Search, which already provide meaningful public oversight. My concern is that several provisions of the proposed rule would increase administrative burdens, reduce predictability, and discourage participation in federal programs without meaningfully improving accountability. Many of the oversight and compliance functions contemplated by these changes are already performed within federal agencies by experienced staff with the requisite expertise, contextual awareness, and discretion to administer these programs effectively.

[100.1, 200.106, Subtitle B].

OMB repeatedly states that one objective of these revisions is to reduce burden on recipients, but the drafted provisions belie this claim. Instead, they unnecessarily complicate federal financial assistance administration. As the First Branch, Congress determines how public funds are appropriated and which agencies are responsible for administering federal programs. These revisions would shift substantial discretion over those programs to the Executive Office of the President (EOP), altering the balance Congress deliberately established. For this reason, I would not want any administration to empower EOP in this way.

Changing 2 C.F.R. Part 200 from guidance to binding regulation for agencies removes much of the discretion currently exercised by agency program officers and grants management professionals, who best understand their recipient communities, award mechanisms, and programmatic goals. Future revisions to Part 200 would become mandatory government-wide without allowing agencies to balance risks and benefits, account for mission-specific needs, or undertake their own notice-and-comment rulemaking. Agencies necessarily maintain different risk tolerances based on their statutory missions, and a uniform regulatory approach would reduce their ability to fine-tune their spending portfolios for maximum impact.

The current Uniform Guidance emphasizes opportunity for public participation. Under existing practice, revisions to Subtitle B are implemented through agency-specific rulemaking, allowing recipients, subject-matter experts, and the public in general to provide input before changes take effect. The proposed revisions would instead centralize that process, reducing opportunities for agency-specific public review and feedback.

Finally, treating Part 200 as binding regulation rather than agency guidance would increase administrative and legal complexity for both agencies and recipients. Greater compliance burdens require additional administrative infrastructure. Agencies would devote more resources to compliance and enforcement, while recipient institutions would spend more time and overhead managing regulatory requirements rather than carrying out the activities Congress intended to support. To achieve the same outcomes under the proposed changes, Congress would need to appropriate more funds to agencies for internal operations and increased recipient overheads.

[200.101(b), 200.101(c)].

In the 1970s, Congress recognized the distinct need for grants and cooperative agreements in statute because they are not like contracts. ⁶ To this day, federal grants are not treated like contracts because they are carried out without government input beyond the initial funding, and, while cooperative agreements have government involvement, they are issued to aid the recipient. The proposed revisions erode the distinction that Congress intentionally created.

Even without that distinction, introducing FAR-style provisions to the world of federal financial assistance adds an incredibly complicated administrative apparatus incommensurate with the relatively small amount the U.S. government spends on project grants and cooperative agreements ($0.3 trillion obligated in FY 2025) compared to acquisition, procurement, and direct payments ($4.0 trillion obligated in FY 2025). Before undertaking sweeping reforms to grants management, OMB should prioritize government-wide financial management challenges identified in GAO's most recent fiscal audit, including deficiencies in federal accounting, improper payment detection, and information systems. Effective reform depends on reliable fiscal data, including accurate measures of waste, fraud, and abuse across CFO Act agencies. ⁷ Furthermore, Filling the position of Controller of the Office of Federal Financial Management---even on an acting basis---is necessary for institutional accountability. A dedicated Controller will ensure that changes to federal financial assistance policy are informed by sustained subject-matter expertise.

The proposal's elimination of fixed-amount awards is unwarranted. Fixed-amount awards provide recipients with the flexibility and stability needed for long-term planning, particularly for research activities such as supporting graduate trainees, maintaining specialized equipment, or carrying out multi-year projects. Existing policy already protects taxpayers by requiring unobligated funds at the end of an award period to be returned to the U.S. Treasury rather than the awarding agency, ensuring that neither agencies nor recipients benefit from excessive or wasteful funding.

For these reasons I oppose the proposed changes to these sections.

[200.303, 200.407, 200.454(a)-(b), 200.461].

The changes to each of these sections either introduce new administrative burden incommensurate with the oversight benefits they intend to achieve, or they are reduplicative of agency functions that produce the same oversight benefits without the time- or personnel-costs the federal government would accrue because of the compliance burdens in the changes.

Requiring all recipients to participate in E-Verify will impose a new administrative condition unrelated to the scientific or educational merit of federally supported research. This requirement adds compliance obligations for colleges, universities, nonprofits, and smaller recipients that do not currently use E-Verify. For primarily undergraduate institutions and small organizations like mine, additional employment-verification requirements consume the same limited administrative capacity needed to support students, researchers, and federally funded programs.

The current administration has criticized universities as being bloated and inefficient; the proposed changes will worsen that problem. To respond to the changes, large research universities will need to hire additional compliance personnel. Smaller institutions that cannot easily do so will pass the burden to the grant recipients themselves. At primarily undergraduate institutions, regional institutions, and smaller nonprofit organizations, these responsibilities frequently fall on faculty members, department chairs, principal investigators, and a small number of grants administrators. Overall, this leads to poorer research return-on-investment, not leaner universities.

Rather than rewriting 2 C.F.R. 200, a more productive approach would be for OMB to reconvene the Council on Financial Assistance Reform (or its successor, the Council on Federal Financial Assistance). ⁸ This would ensure that agencies are following the guidance in 2 C.F.R. 200 carefully without introducing undue burden on recipients. Furthermore, instead of attempting to overregulate federal financial assistance, OMB would better serve the U.S. public by completing the implementation of existing laws like the GREAT Act aimed at reducing burden and standardizing agency practices for easier management and oversight. ⁹ Indeed, the Government Accountability Office has identified many fruitful ways for OMB to improve federal financial assistance in its Government Operations recommendations database. ¹⁰ Further considerations about access to federal financial assistance, with an emphasis on reducing recipient burden, were brought to light during Senate Hearing 118-68 and subsequent draft legislation. ¹¹

Chilling Effects on U.S. Research and Scientific Workforce

My comments here are related to scientific research grants rather than federal project grants or cooperative agreements more broadly.

[200.205, 200.340].

I am deeply concerned with the introduction of political review of awards and expanded termination authority.

Political review of scientific proposals, rather than expert merit review, creates uncertainty for applicants without improving accountability. Combined with expanded termination authority, these provisions would destabilize the research enterprise by making awards less predictable and long-term planning substantially more difficult. Consider how the extensive termination (by non-experts) of grants and related programs has already led to destabilization, to the extent that these decisions have been walked back. Indeed, in late June, NSF announced that it will reverse course on removing the instruments supporting the Ocean Observatories Initiative in response to extensive expert criticism. ¹²

As a researcher, I rely on transparent and predictable evaluation systems to understand whether my work meets an agency's scientific standards and programmatic goals. The strength of the federal research enterprise rests on expert peer review. Although agencies appropriately establish priorities through political leadership, this proposal substantially expands political review before and after expert evaluation, reducing the role of scientific judgment in funding decisions.

Research requires long-term commitments to students, personnel, equipment, and collaborations. Expanded termination authority creates risks that cannot be managed through ordinary project planning. At a small primarily undergraduate institution, those burdens fall directly on faculty. Every additional administrative obligation reduces the time available for the research and mentoring that grants are intended to support.

As a mathematician, I am particularly concerned because many of the most important advances in mathematics could not have been justified through short-term political priorities; it would be difficult for a non-expert to understand the research program and its necessity to future innovations. For example, results proved by Euler and Gauss (giants of mathematics in the 18th and 19th centuries!) found their first practical applications in 1978 (and still underpin the security that Regulations.gov uses for collecting these comments). ¹³ which now secures everything from online banking to Regulations.gov itself. Likewise, many techniques underlying modern data science and artificial intelligence originated in exploratory research with no immediate commercial or strategic application. Expert peer review, not short-term political priorities, made those advances possible.

For these reasons I oppose the proposed changes.

[200.218, 200.202].

Sections 200.218 and 200.202 will stifle legitimate, public-serving research, especially in statistics, data science, education, public policy, and social science. Research on disparate impacts is not inherently unlawful discrimination. Researchers working on this topic blend statistical, legal, empirical, and policy approaches to answering important questions relevant to our society and the interests of any administration. Prohibiting federal funds from supporting work connected to theories of disparate-impact liability risks discouraging lawful research into inequality/inaccessibility and the measurable effects of policy choices, especially those that are unintended (and even undesirable). This kind of research helps determine when policies, even those intended to promote the well-being of a federally-protected class, create new barriers for that group of people or undesirable barriers for other groups.

All of that is to say, restrictions that politicize the study of data are bad for everyone. Data scientists should be able to analyze patterns, disparities, outcomes, and institutional effects without fear that certain conclusions or frameworks are categorically disfavored. Helping students understand the mathematical, statistical, and computational tools used to conduct disparate impacts research gives them the tools they need for the future to discern for themselves what truths are purely partisan. It also helps them become the architects of future policies that don't have undesirable outcomes by giving them a framework with which to test their ideas. I understand this well, and I have authored pieces that discredit unrigorous methods used to support in-vogue theories, even when they align with my political preferences. ¹⁴ I rely on researchers to continue to update the literature so that my classes are timely and relevant. In my classes, I help students test policies, like the Gingles test for racial gerrymandering, or mathematical metrics, like the efficiency gap for partisan gerrymandering, so that they can think in a nuanced way about what math can---and can't---do for us.

For these reasons, I oppose the proposed changes.

[200.220, 200.202].

Similarly, section 200.202's domestic-first framework for research and development risks narrowing international scientific collaboration even when collaboration is essential to the work. Mathematics and data science are global enterprises. A policy that treats international elements suspiciously will discourage collaborations, workshops, shared software, shared datasets, and formative student opportunities. Together, these provisions don't just regulate grant administration. They shape what questions researchers are willing to ask. One of the long-running collaborative research projects that puts more "I" in "AI" is managed through NSF with cofunding from several institutes and centers at NIH, the Department of Energy, and international scientific funding counterparts in France, Israel, Japan, Germany, and Spain. U.S. program officers, informed by the U.S. research community reception to the proposals, shape the funding decisions that this multi-lateral collection of research funders make. ¹⁵

The proposed changes create uncertainty regarding future collaborations, participation in future research symposia, and the ability of the U.S. to maintain a presence in the international research community. These uncertainties present their own administrative burdens. Researchers and institutions will be forced to devote additional resources to compliance review, legal review, and risk management. For large research universities, these costs may be absorbed by existing administrative offices. For smaller institutions, including primarily undergraduate institutions like mine, these burdens fall directly on faculty members (and, if we're lucky, a small number of administrators will be able to help).

International collaboration is a core part of how mathematical knowledge is created. My most recent international collaborator has highly specialized knowledge; it has taken over ten years to lay the foundation of trust, mutual respect, and timely communication needed for this collaboration to succeed. I've learned a lot from the globally respected commutative algebra community in Genoa, Italy; the internationally famous homological algebra community in Bielefeld Germany, and I've had the opportunity to contribute to the growing algebra research community in Kathmandu, Nepal. Many research communities, like mine, are globally distributed with expertise in highly specialized areas concentrated among a relatively small number of researchers located in different countries. Some of the most influential gatherings of researchers in my field take place at the Mathematisches Forschungsinstitut Oberwolfach in Oberwolfach, Germany, the Banff International Research Station in Banff, Canada, and the Centro de Investigación en Matemáticas in Guanajuato, Mexico. Institutes attached to U.S. research institutions also host gatherings that draw world-renowned experts to the U.S. to the benefit of the domestic mathematical research community (including students and trainees).

Data science is also inherently collaborative and international. Some research projects involve distributed teams working across institutions and national boundaries. The proposed restrictions create uncertainty regarding participation in collaborative software development, shared data resources, benchmarking activities, and joint research projects. Again, this uncertainty will discourage collaboration even when no actual prohibition exists. Institutions will naturally adopt conservative compliance interpretations to minimize risk, thereby reducing participation in international scientific communities. At smaller institutions like mine, we are running a Data Science program for the benefit of students. It weights heavily on my mind as the program's director that if it becomes too burdensome to make sure students have access to opportunities during (and after) college, my employer may need to retire the program. This isn't the way to ensure that the U.S. is the leader in data science or that U.S. values permeate the field internationally.

For these reasons, I oppose the domestic-first framing and the proposed expansion of restrictions relating to foreign collaborations in these sections.

[200.329-332].

Many data science projects depend on complex collaborations involving multiple institutions. Increasing subrecipient oversight requirements will also substantially increase administrative burden when applied across large collaborative projects. Additionally, the proposed transfer of risk to prime awardees discourages partnerships and reduces participation by smaller institutions (like mine) that lack robust, dedicated grants-management infrastructure.

For these reasons, I oppose the changes proposed in these sections.

[200.432].

Conferences build scholarly communities. In mathematics, research happens when collaborators connect at a conference (in my experience, it's a necessary, intensive in-person collaboration opportunity that brings projects to conclusion). Ideas are disseminated and transferred across institutional and geographic boundaries. Important technical skills are taught, and researchers with cognate interests devote time to learning new technical skills (like how to write code for mathematical research systems; in my field, these look like Macaulay2 developer conferences). ¹⁶ Agencies like NSF encourage researchers to apply for and host research symposia in areas that Congress or other federal parties have identified as critical. To move a research community in a direction that supports the goals of policymakers, an agency needs to have comparatively inexpensive incentives to draw together researchers with complementary experience, including provisions for travel to conferences as they emerge in relevant areas (even if it's after the original proposal's budget was approved).

For these reasons, I oppose the proposed changes to this section.

[200.300].

I believe diversity, equity, and inclusion efforts leading to a more expansive vision of science and the kinds of questions worthy of pursuing are beneficial to science itself, beneficial to the United States, beneficial to taxpayers, and beneficial to the practitioners of mathematics and data science---especially those who have been historically excluded. I disagree with the administration's apparent premise (implicit in the proposed change) that efforts to broaden participation in STEM are inherently suspect or contrary to the public interest. As a mathematician, data science program director, and educator, I believe diversity, equity, and inclusion efforts have been beneficial to the U.S. citizenry as well as its scientific productivity. These are workforce-development initiatives. Part of my own journey through mathematics was funded by NSF workforce programming in graduate school and professional development aimed at keeping talented women in the mathematics pipeline. The United States faces increasing demand for expertise in mathematics, statistics, artificial intelligence, data science, cybersecurity, and advanced computing. At the same time, many capable students continue to encounter barriers to participation in these fields. This phenomenon is called the "Missing Millions": talented individuals (millions of them!) who could contribute to scientific and technical fields but who never receive the opportunities, mentoring, encouragement, or support necessary to enter those professions. From this perspective, reducing support for participation-focused programs is not a cost-saving measure. It's a form of self-imposed brain drain. The U.S. cannot simultaneously claim that it needs more scientists, mathematicians, engineers, data scientists, and AI researchers while discouraging programs designed to identify and cultivate talent from the broadest possible population.

Again, as someone who benefited from federally supported educational opportunities and who now works with students pursuing similar paths, I view investments in broadening participation as investments in national scientific capacity. As a student at a primarily undergraduate institution, I benefited from programs specifically designed to expand opportunities in mathematics. Those opportunities helped me become a mathematician, researcher, professor, department chair, and director of a Data Science program; later, those skills translated into science policy work through two nationally competitive fellowships where the investments into my knowledge became directly useful to the U.S. via contributions in Congress and at the National Science Foundation, helping to connect regulatory frameworks lawmakers proposed to the scientific advances that would be needed to make them implementable; conversely, I helped convey the reasons that some legislative goals aren't yet achievable because of the way in which certain algorithms work (and the investments that would be needed to expand the scientific research community to push algorithms, models, and other tools forward to the next generation). The return on investment in my mathematical preparation far exceeds the costs of the programming that supported my training.

Today I mentor students whose backgrounds, experiences, and educational pathways differ substantially from those traditionally associated with students who pursue STEM careers. They are exceptionally talented. Some are the first in their families to pursue advanced study in quantitative fields. Some come from high schools with limited STEM courses. Some belong to groups that remain underrepresented in mathematics and computing. Each student with a nontraditional path to mathematics sees applications and research questions that others with traditional backgrounds would overlook. One such talented student has designed a closed system that would reduce the fresh water used to cool data centers, motivated by a desire to see more infrastructure for AI without the downsides that communities like his would face as potential sites for future data centers.

The question before policymakers is straightforward: should the United States attempt to cultivate such talent, or should it allow that talent to go undeveloped? The answer is obvious. Every capable future mathematician, statistician, software developer, data scientist, and researcher who leaves the STEM pipeline represents a loss not only for that individual but for the nation as a whole.

Federal funding agencies have been successful participants in recruiting and retaining talent. They have helped identify students from rural communities, first-generation college students, students at primarily undergraduate institutions, women in mathematics, and many others whose abilities might otherwise have gone unnoticed. Even international students are drawn to the U.S.---and stay in the U.S.---to contribute to science shaped by U.S. values and priorities. When programs designed to broaden participation are weakened or viewed with suspicion, the nation risks losing not only individual success stories but also scientific discoveries, technological innovations, educational leaders, and future generations of researchers.

For these reasons I oppose the changes proposed in this section.

Conclusion.

Speaking as a mathematician and educator, I recognize that federal research funding is not intended to guarantee personal fulfillment. However, I believe it is worth remembering a broader U.S. principle: the Declaration of Independence identifies among our nation's aspirations the creation of a society in which individuals are free to pursue lives of meaning and purpose. For many Americans, that pursuit takes the form of entrepreneurship, public service, artistic creation, community leadership, or family life. For some of us, it also takes the form of intellectual inquiry.

Mathematicians devote years, and sometimes decades, to understanding and solving difficult problems whose applications may be decades (or centuries) in the future. Scientists investigate important questions whose answers are not only unknown but possibly unknowable. Students choose demanding educational paths not because they are easy, but because they find joy and purpose in discovery. The federal research enterprise has historically reflected an understanding that these pursuits are valuable. It has helped create conditions in which talented individuals can contribute to human knowledge while also generating long-term benefits for society.

Vannevar Bush, whose landmark report Science---The Endless Frontier laid the out the argument for creating an agency like the National Science Foundation, wrote, "Scientific progress on a broad front results from the free play of free intellects, working on subjects of their own choice, in the manner dictated by their curiosity for exploration of the unknown. Freedom of inquiry must be preserved under any plan for Government support of science in accordance with the Five Fundamentals listed on page 35." ¹⁷ The first among Bush's Five Fundamentals is a commitment to stable, multi-year funding. He explains, "Basic research is a long-term process---it ceases to be basic if immediate results are expected on short-term support. Methods should therefore be found which will permit the agency to make commitments of funds from current appropriations for programs of five years duration or longer." ¹⁸

At the most fundamental level, my concern with this proposal is that it places additional obstacles and uncertainties in front of people who are already choosing difficult paths. The challenge of discovering new mathematics is sufficient. The challenge of training future scientists is sufficient. The challenge of building new knowledge is sufficient.

Public policy should not make those endeavors unnecessarily harder. For these reasons, I oppose the proposed changes and urge OMB to withdraw this proposal and start anew.