HHS-OASH-2026-0397-4513
https://www.regulations.gov/comment/HHS-OASH-2026-0397-4513

Public Comment Submitted to the U.S. Department of Health and Human Services

Advocacy for Neuro Rights Inc. (A4NR) respectfully submits the attached white paper, Pathway to Freedom: A Neuro-Rights Framework for Emerging Brain-Computer Interfaces, Artificial Intelligence, Wireless Body Area Networks, Physiological Telemetry Systems, and Emerging Neurotechnologies.

This submission is based upon years of advocacy, case management, registry development, multidisciplinary evidence review, public-health analysis, and support provided to individuals reporting complex neurological, physiological, sensory, toxicological, and legal concerns. Through this work, our organization identified recurring questions involving informed consent, participant protections, cognitive liberty, mental privacy, neuro-autonomy, physiological monitoring technologies, and future governance of emerging neurotechnologies.

The purpose of this submission is not to establish proof of a specific technological mechanism, device, exposure source, or causal relationship. Rather, it seeks to encourage proactive public-health discussion, scientific inquiry, and ethical oversight concerning rapidly evolving technologies, including artificial intelligence, brain-computer interfaces, physiological telemetry networks, Medical Internet of Things systems, Wireless Body Area Networks (WBANs), and future neurotechnologies.

The attached white paper proposes that the foundational principles established within the Belmont Report remain highly relevant but may require modernization as emerging technologies become increasingly capable of collecting, processing, transmitting, and analyzing physiological and neurological information. It further recommends consideration of cognitive liberty, mental privacy, neuro-autonomy, informed consent modernization, enhanced protections for vulnerable populations, and increased transparency regarding technologies capable of interacting with human biological systems.

Advocacy for Neuro Rights respectfully recommends continued discussion regarding:

Cognitive Liberty
Mental Privacy
Neuro-Autonomy
Brain-Computer Interface Governance
Artificial Intelligence Accountability
Physiological Telemetry Oversight
Wireless Body Area Network Governance
Medical Internet of Things Transparency
Human Subject Protection Modernization
Federal Neurotechnology Policy Development

The goal of this submission is to support a future in which scientific innovation advances alongside human dignity, informed consent, participant protections, transparency, public trust, and fundamental rights.

Public Submission Disclaimer

This submission is provided as part of a public Request for Information process. All observations, recommendations, and conclusions are presented for scientific, ethical, public-health, and policy discussion purposes.

No original participant files, medical records, protected health information (PHI), personally identifiable information (PII), or confidential client records are included in this submission.

Any organizational observations referenced within the attached materials are presented as de-identified registry observations, analytical summaries, and policy-oriented findings intended to support discussion regarding public health, human-subject protections, neuro-rights, and emerging technology governance.

The submission does not establish proof of a specific technological mechanism, device, exposure source, or causal relationship. Rather, it identifies research gaps, governance considerations, ethical questions, and areas that may warrant additional scientific investigation and public-health review.

Respectfully Submitted,

Lewis Scott Rowe
 Chief Executive Officer
 Research Director
 Advocacy for Neuro Rights Inc. (A4NR)
 ORCID: 0009-0008-4947-2558