The Council on Governmental Relations (COGR), representing 188 prominent U.S. research institutions, submitted comments to the National Institutes of Health (NIH) in response to its draft report on reducing administrative burden for researchers involved in laboratory animal care and use. COGR acknowledged and supported multiple agency initiatives aimed at streamlining regulatory and reporting requirements while maintaining strong animal welfare protections, as mandated by the 21st Century Cures Act. Among the actions endorsed were proposals for harmonized annual reporting to the NIH and the USDA, clarification and updating of guidance on protocol reviews and reporting requirements, support for best-practices repositories, and the development of simplified protocol forms. COGR also advocated for the adoption of definitions and processes that avoid rigid, unwarranted administrative procedures—such as recommending "complete reviews" every three years over potentially more burdensome "de novo reviews"—and highlighted the importance of explicitly communicating the non-binding status of agency guidance where appropriate.
Additionally, COGR called for further consideration of several recommendations not fully addressed in the draft report. These included revising requirements for reporting alternative strategies, reducing unnecessary congruency verifications between protocols and grants, increasing flexibility in protocol reviews (such as expedited review for low-risk studies), simplifying the Institutional Assurance process for accredited institutions, and amending statutory mandates for IACUC inspections to decrease redundancy. The organization emphasized that external engagement with institutional oversight experts would assist in the effective and practical implementation of regulatory reform. Overall, COGR reiterated its commitment to collaborative efforts that reduce unnecessary administrative work in animal research oversight, thereby allowing researchers to focus more on scientific inquiry while upholding high standards of animal welfare.
