º£½ÇÖ±²¥

Dr. Jay Bhattacharya Director National Institutes of Health 9000 Rockville Pike Bethesda, Md. 20892

Re: Request for Information (RFI): Inviting Comments and Suggestions on a Framework for the NIH-Wide Strategic Plan for Fiscal Years 2027-2031

Dear Dr. Bhattacharya,

On behalf of the º£½ÇÖ±²¥ ( º£½ÇÖ±²¥), thank you for the opportunity to respond to this request for information on the National Institutes of Health (NIH) Strategic Plan. º£½ÇÖ±²¥ is one of the oldest and largest life science societies with over 38,000 members in the U.S. and around the world. Our mission is to promote and advance the microbial sciences. The National Institutes of Health is a significant funding agency for º£½ÇÖ±²¥ members, who conduct research spanning from basic research on host-microbe interactions to developing new drugs and treatments for infectious diseases.

º£½ÇÖ±²¥ is working to advance phage therapy, connect microbiome science to clinical care, accelerate innovation in diagnostics and more through º£½ÇÖ±²¥ Health. º£½ÇÖ±²¥ welcomes partnership with NIH on these topics. º£½ÇÖ±²¥ also encourages NIH to continuously engage with the public on the process and results of biomedical research and to support and encourage NIH-funded researcher participation in public engagement activities. Engagement is key to restoring public trust in science. 

NIH's investments in the scientific enterprise should prioritize scientific engagement and collaborations across the globe. Microbes know no borders and global collaborations are often essential to prevent future outbreaks and pandemics.

As NIH drafts an updated strategic plan, º£½ÇÖ±²¥ encourages NIH to take the following comments on the NIH strategic plan framework into account:

Priority 1: Research Areas

• Goal 1: Advance Foundational Knowledge of Human Health and Disease.
• Goal 2: Prevent Disease and Promote Health Across the Lifespan.
• Goal 3: Advance and Optimize Interventions, Treatments and Cures.

Microbes both threaten health and play a critical role in everything from fighting infections to managing chronic diseases—and hold immense potential to improve human, animal and environmental health. However, foundational research gaps remain in our understanding of how microbes interact with their hosts and their indigenous microbial communities, how microbes evolve and how scientists and other innovators can effectively translate this work into real-world health solutions. 

º£½ÇÖ±²¥ has identified key focus areas that align with the proposed NIH research goals: 

• Advancing our understanding of the human microbiome is a key priority area for the current Administration, and is an area that is ripe for discovery and innovation with strong potential to inform disease prevention, diagnostics and therapeutics.
• Collaborations across human, animal and environmental health using a One Health approach present a consistent funding challenge. º£½ÇÖ±²¥ recommends that NIH collaborate with other science funding agencies to develop suitable funding and coordination mechanisms for research projects that span human, animal and environmental health. 
• Through its multi-omics and diagnostics initiatives, º£½ÇÖ±²¥ is working to enable cross-sector surveillance, data integration and clinical interpretation. However, current NIH funding mechanisms do not adequately support shared infrastructure (e.g., registries, standards and coordinated data systems) needed for these efforts. 
• Bacteriophage therapy offers life-saving potential against drug-resistant infections but remains limited by scientific and clinical complexity and uncertainty. Through the Phage Therapy Coordination Network, º£½ÇÖ±²¥ is addressing these barriers by convening stakeholders to align on clinical pathways, regulatory expectations and data-sharing frameworks. Targeted NIH investment could accelerate these coordinated efforts.
• Fostering adoption and integration of novel technologies into health-related research. This includes artificial intelligence but also targeted approaches like pathogen agnostic, multi-omics systems that could rapidly address surveillance gaps. We also encourage NIH to support clinical outcomes studies to validate the use of novel diagnostics and ensure that these tests reach clinical settings.
• Inter- and transdisciplinary research are fundamental to these areas of research, and existing funding streams frequently do not support this type of research. Increased collaborations between NIH, other federal agencies and private foundations could support inter- and transdisciplinary research.
• Increasing evidence links infectious diseases and microbiomes to chronic conditions across the lifespan. Through its microbiome to medicine and multi-omics initiatives, º£½ÇÖ±²¥ is helping to define these connections and translate them into actionable diagnostic and prevention strategies. Targeted NIH investment on the connections between infectious diseases and chronic disease across the lifespan would enable earlier intervention and improved long-term health outcomes.
• Foundational pathogen research is key to understanding the mechanism of infection. Recent policy uncertainties have created a chilling effect on scientific discovery, particularly in virology research. This puts us all at risk. We strongly encourage the NIH to coordinate with the Administration, Congress and stakeholders to develop a clear and consistent approach to dual-use research and gain of function research. 

Priority 2: Research Capacity

Goal 1: Develop and Sustain an Interdisciplinary Research Workforce

º£½ÇÖ±²¥ appreciates NIH’s work to support an interdisciplinary scientific workforce. Maintaining a pipeline of microbiologists across career stages and helping early career scientists enter the field is essential to the continued viability of the microbial sciences and biomedical research more generally. º£½ÇÖ±²¥ has identified the following actions to support the research workforce:

• Supporting training programs across geographic areas helps drive heterogeneity of participation in the science community. º£½ÇÖ±²¥’s branches across the country partner with the IDeA Networks of Biomedical Research Excellence (INBRE) institutions to support recruitment and training. We encourage NIH to scale up pilot projects like this partnership that recruit and train the next generation of scientists and broaden participation across the One Health research community.
• Standardize policies and deadlines for K awards across NIH institutes and centers (ICs) to level the playing field across NIH-supported fields. Inconsistent policies for K awards across in NIH ICs create obstacles and disadvantages as scientists apply for tenure-track positions.
• Sustain support for K and T awards to maintain the research workforce.
• Partner with scientific societies to build a robust pool of scientists in the workforce in NIH-funded fields.

Goal 2: Build, Improve and Sustain Research Resources and Infrastructure

º£½ÇÖ±²¥ concurs that support for research infrastructure is essential, especially as the U.S. faces complex biological threats and researchers adapt to biology in the age of artificial intelligence (AI). º£½ÇÖ±²¥ has identified the following research infrastructure needs:

• Protecting biosecurity and biosafety requires state-of-the-art facilities and a highly trained workforce. Additional support is needed for Institutional Biosafety Committees to ensure that these have appropriate resources to implement NIH biosafety policies.
• Invest in research on biosafety measures, biorisk management training, occupational medicine services, improved facilities and protocols and personal protective equipment at NIH-funded institutions.
• Support for common infrastructure for storing and sharing data about microbes, infectious diseases and omics and genomics is needed, particularly as AI can be applied to different forms of biological data and models.

Priority 3: Research Operations

Goal 1: Enhance Scientific Stewardship and Decision-Making
Goal 2: Foster Transparency and Accountability to Improve Public Trust in Science

As NIH adapts new funding strategies and policies, º£½ÇÖ±²¥ requests the following measures to increase transparency and accountability:

• Publish annual reports about the factors and data used to make funding decisions and implement safeguards to minimize bias in funding decisions.
• Regularly communicate the review framework to the scientific community, noting how the "competitive but not discussed" designation is used and how review group recommendations ultimately factor into final funding decisions. 
• Regularly review, identify and respond to identified research gaps that may not be adequately addressed through investigator-initiated applications.  
• Regularly evaluate and communicate the outcomes of funding strategies.
• Evaluate the impact of the shift of forward funding of grants to ensure that the strategy does not result in an abrupt decrease in grants. If the shift to forward funding does result in lower success rates, work with Congress to increase NIH funding accordingly. 
• Continue support for international research collaborations with appropriate guardrails to protect research security. NIH should continue to provide guidance to the grantee community about using the PF5 mechanism and track the impacts of the shift away from foreign subawards for international collaborations.
• Open access publication ensures that researchers, policymakers and the public can freely access and build upon the latest discoveries. NIH can support open access by allocating funds specifically for covering publication fees in open-access journals and by encouraging grantees to publish in open-access venues. 
• Scientific societies journals have long track records of publishing high quality, peer reviewed science. º£½ÇÖ±²¥ urges NIH to invest in existing journals and not create its own journals, which may be subject to political pressures from bipartisan administrations.

Conclusion

º£½ÇÖ±²¥ thanks NIH for its leadership in biomedical research, and we stand ready to work with the agency to shape future of the microbial sciences and build the scientific workforce and infrastructure necessary to develop new cures, treatments and diagnostics. If you have any questions, please contact Nicole Zimmerman, Senior Federal Affairs Officer at nzimmerman@asmusa.org.

Thank you,

Margie Lee, DVM, M.S., Ph.D.
Chair, º£½ÇÖ±²¥ Public and Scientific Affairs Committee