The Council on Governmental Relations (COGR), which represents nearly 200 major U.S. research universities and related institutions, submitted formal comments in response to the National Institutes of Health (NIH) Notice NOT-OD-22-064, seeking input on supplemental guidance for data management and sharing, especially regarding research involving American Indian and Alaskan Native (AI/AN) communities. COGR acknowledges the importance of fostering research participation by underrepresented groups, recognizing both the historical mistrust AI/AN communities may hold toward the scientific enterprise and their sovereign rights to control research in their jurisdictions. COGR expresses support for NIH’s intent to build more equitable partnerships with AI/AN communities and underscores the necessity of incorporating community perspectives and respecting tribal sovereignty in research conduct and data sharing practices.
In its specific feedback, COGR asks NIH to clarify that recommended approaches for establishing mutual understanding of data management and sharing goals—such as presenting findings to communities and securing tribal pre-approvals—are suggestions, not mandatory requirements, and that other suitable methods may also be appropriate. COGR highlights the potential for mismatches between tribal regulations and researcher or funding agency expectations, recommending that any substantive differences be identified and addressed proactively, ideally before research proposals are submitted. For data sharing limitations, COGR appreciates NIH’s acknowledgment of tribal authority and community values but requests greater clarity on which data sharing restrictions are acceptable under NIH policy, to better aid researchers and tribes in negotiating mutually agreeable arrangements. The letter concludes with COGR’s strong support for efforts to enhance positive research collaborations among NIH, Tribal Nations, and the academic community.
