ºÚÁÏÕýÄÜÁ¿

The Honorable Michael Kratsios Director, White House Office of Science and Technology Policy 1600 Pennsylvania Ave NW Washington, D.C. 20500

Re: Notice of Request for Information; Accelerating the American Scientific Enterprise—Docket ID Number OSTP-TECH-2025-0100

Dear Mr. Kratsios,

On behalf of the ºÚÁÏÕýÄÜÁ¿ (ASM), thank you for the opportunity to respond to this request for information (RFI) on Accelerating the American Scientific Enterprise. As one of the largest life science societies with over 38,000 members in the U.S. and around the world, ASM’s mission is to promote and advance the microbial sciences and their role in addressing humanity’s most daunting—and evolving—challenges. This letter summarizes ºÚÁÏÕýÄÜÁ¿members’ responses to the RFI. 

While ºÚÁÏÕýÄÜÁ¿strongly supports a renewed focus on American innovation, none of this can happen if we do not invest in foundational research, data and physical infrastructure, and a strong scientific workforce. American investment in research and development as a proportion of our economy is decreasing as the global science and engineering landscape grows. To accelerate innovation, we must sustain our commitment to robust and predictable funding for federal agencies and programs that underpin the scientific enterprise of the U.S.

What policy changes to Federal funding mechanisms, procurement processes or partnership authorities would enable stronger public-private collaboration and allow America to tap into its vast private sector?

There are myriad opportunities for the federal government to explore policies to increase academic-to-industry collaboration, especially at the state, local and regional levels. ºÚÁÏÕýÄÜÁ¿concurs with the of the Society for Industrial Microbiology and Biotechnology for a precompetitive knowledge base for researchers and industry to share what works and does not work in developing bio-based products. 

ºÚÁÏÕýÄÜÁ¿members also recommend: 

• Policies on private industry contributions to public sector research at a level that is commensurate with their benefit from federally funded research.
• Policies to incentivize private sector internship opportunities to graduate students to facilitate capacity building and practical skill development within industry and postsecondary education. 
• Policies that encourage biotechnology academic/industry fusion in every region of the U.S. through networked and interoperable regional testbeds.

What reforms will enable the American scientific enterprise to pursue more high-risk, high-reward research that could transform our scientific understanding and unlock new technologies, while sustaining the incremental science essential for cumulative production of knowledge?

As noted above, our members support mechanisms to increase private sector engagement and buy-in for fundamental research, including high-risk, high-reward research. However, for many microbial innovations, the U.S lacks a consistent and dependable pathway to commercialization, creating a risk-averse culture that stifles innovation. ºÚÁÏÕýÄÜÁ¿and our members urge the Administration and Congress to:

• Create a funding pipeline for outcomes studies for new technologies to demonstrate clinical value. 
• Shorten the timeline from discovery to implementation through clear regulatory pathways that are harmonized across agencies to the extent possible.
• Replicate models of successful federally funded programs that have a strong record of promoting innovation like the Department of Energy’s Bioenergy Research Centers. Between 2003 and 2011, the Bioenergy Research Centers produced 21 patents for every $100 million in research funding.
• Reauthorize and strengthen SBIR/STTR programs. 

How can the Federal government leverage and prepare for advances in AI systems that may transform scientific research—including automated hypothesis generation, experimental design, literature synthesis and autonomous experimentation? What infrastructure investments, organizational models and workforce development strategies are needed to realize these capabilities while maintaining scientific rigor and research integrity?

As a scientific publisher, ºÚÁÏÕýÄÜÁ¿acknowledges that the current landscape of AI tools is complex and ever changing. As these tools continue to evolve and further embed into scientific research, ºÚÁÏÕýÄÜÁ¿encourages the federal government to engage scientific publishers to develop consensus guidelines for authors using AI tools.

How can Federal programs better identify and develop scientific talent across the country, particularly leveraging digital tools and distributed research models to engage researchers outside traditional academic centers? 

Advances in computational biology mean that researchers and citizen scientists across the country are generating more data than ever. At the same time, artificial intelligence tools are unable to accurately analyze biological data when data is not standardized and not shared. Findable, Accessible, Interoperable and Reusable (FAIR) standards, training and data sharing platforms allow scientists to access, analyze and share data more effectively.

• ºÚÁÏÕýÄÜÁ¿encourages the federal government to invest in data infrastructure to store and share biological data produced by federally funded research. This includes additional support for federal programs that strengthen data inputs and standards, like the National Microbiome Data Collaborative within the Joint Genome Institute at DOE.

What specific Federal statutes, regulations or policies create unnecessary barriers to scientific research or the deployment of research outcomes? Please describe the barrier, its impact on scientific progress and potential remedies that would preserve legitimate policy objectives while enabling innovation. 

Biological research and innovation are inherently international. For example, microbes that hold the key to new cures and bioproducts may be found in remote parts of the world. Likewise, international collaboration catalyzes research and development. ºÚÁÏÕýÄÜÁ¿and our members urge the Administration and Congress to: 

• Revisit federal policies that discourage or create insurmountable barriers to international collaborations or the United States’ ability to attract scientific talent from around the world. 
• To keep top scientific talent in the U.S., maintain the “duration of status” rule to allow for completion of studies and strengthen pathways for international graduate students to obtain legal residency in the U.S. after they graduate.

How can the Federal government strengthen research security to protect sensitive technologies and dual-use research while minimizing compliance burdens on researchers?

Scientists conducting work with sensitive technologies and agents have a responsibility to ensure that there is negligible risk from the work in which they are engaged. Research security standards should allow for adapting the risk benefit calculus to allow researchers to pursue understanding of novel and imminent threats, while continuing to minimize risk. Overly rigid standards that do not allow us, as a nation, to anticipate the next threat will slow our ability to respond and develop countermeasures. ºÚÁÏÕýÄÜÁ¿and our members encourage the Administration and Congress to:

• Develop guidelines with expert input from researchers and institutional biosafety experts. 
• Provide resources required to support the training, laboratory infrastructure and access to expertise that will be required to implement research security measures.

U.S. health security is inextricably linked to global health security, and we must use every tool at our disposal to work with our international partners to ensure research is both conducted at the appropriate biosafety levels and keeps the safety of the public top of mind. There is a strong precedent for diplomacy in this space, which is essential to safety and success.

Conclusion

Discovery and innovation hinge on stable investments, strong infrastructure and a diverse scientific workforce. Thank you for the opportunity to respond to this request for information. If you have any questions, please contact Nicole Zimmerman, Senior Federal Affairs Officer, at nzimmerman@asmusa.org.

Thank you,

Amalia Corby
Director of Federal Affairs
ºÚÁÏÕýÄÜÁ¿