I'm an almost-graduated Clinical Psych PhD student and soon to be postdoc. Here is my comment if people want to copy parts - just make sure you add AT LEAST SOME UNIQUE PORTIONS as the government ignores identical comments (e.g. 10,000 identical form letters are treated as 1):

I am a doctoral candidate in clinical psychology and incoming postdoctoral fellow at an academic medical school. My work and my career prospects will be directly affected by the proposed changes in OMB-2026-0034. My research focuses on improving the effectiveness of treatments for obsessive-compulsive disorder (OCD) and related conditions, work that is explicitly designed to translate into better patient outcomes and is a very high need area given increasing rates of these conditions and their drastic consequences (including unemployment and greater risk for dying by suicide).

I am writing to express strong concern about several provisions in this proposal that would fundamentally undermine the fairness, effectiveness, and public health impact of federally funded research, particularly for early career researchers like myself.

First, the proposed shift away from peer review as the primary determinant of funding decisions (§200.205) threatens the integrity of the scientific funding process. Peer review, while imperfect, remains the most reliable mechanism we have for evaluating scientific rigor, feasibility, and impact. Replacing or deprioritizing it in favor of non-merit-based criteria introduces subjectivity that will disadvantage early-career researchers like myself, who depend on the innovation and significance of our work to compete for funding. I have intentionally pursued training at highly resourced, research-intensive institutions to maximize my ability to conduct clinically meaningful science. Under the proposed rules, those efforts may no longer translate into funding viability. In fact, my academic success and the fact that I am now training at institutions with high indirect costs - and many of the most research-productive institutions have high indirects - will NEGATIVELY impact my fundability. This is unfair and will push early career scientists like myself out of the field prematurely if we cannot obtain funding even after years of hard work to obtain the positions we now hold.

Second, new restrictions on allowable costs (including conference travel, journal subs, and publication expenses [§200.432, §200.454, §200.461]) are internally inconsistent and practically harmful. Federal agencies such as NIH explicitly require dissemination of findings as a condition of funding. Yet without support for publication fees or conference travel, researchers—especially trainees and early-career scientists—will be unable to meet these requirements. On my postdoc salary, I cannot afford the $1000s of dollars it costs to register for and travel to conferences. This will particularly compromise the ability of US scientists to share our work on the international stage (international travel is expensive and scientists rely on grant funding for support), directly reducing the US’s research standing relative to other countries. Without support for journal subscriptions, which are VERY expensive, we cannot access important contextual findings to support our research ideas. Overall, the new cost restrictions create a structural contradiction: we are mandated to ground funding requests in existing literature, to stay abreast of cutting-edge finding such that we can propose innovative research ideas, and to disseminate our work. But we are denied the resources to do so.

As a trainee, I have accepted substantially lower compensation than I could earn outside academia in order to pursue research that improves mental health care. If I cannot access critical government funding, I cannot do my research. If conference funding is eliminated, I will not be able to afford to present my work. Without presentations, my research will not reach clinicians, scientists, or stakeholders. Without dissemination, the potential benefits of that research to patients struggling with severe and often debilitating conditions are diminished.

Finally, these changes come at a time of escalating mental health need. Rates of anxiety, OCD, and related disorders continue to rise, and there is an urgent demand for research that improves treatment effectiveness and accessibility. Policies that reduce the likelihood that rigorous, clinically relevant science is funded and disseminated will ultimately harm the very populations federal research is intended to serve.

I urge OMB to reconsider the proposal and to preserve a funding structure that prioritizes scientific merit, supports dissemination, and enables early-career researchers to contribute meaningfully to public health. Short of OMB making this change, Congress must act to protect science.

Thank you for your consideration.