The Council on Governmental Relations (COGR), representing 190 U.S. research universities and related institutions, submitted comments to the National Institutes of Health (NIH) in response to RFI NOT-OD-20-145 on semiannual animal facility inspections. COGR underscores its commitment to animal welfare but emphasizes the need for a balanced approach to regulations, referencing the 21st Century Cures Act and the subsequent “Reducing Administrative Burden” report, which found minimal changes in noncompliance associated with semiannual inspections. COGR advocates for shifting from semiannual to annual facility inspections to decrease administrative burden, citing improvements in oversight and compliance, though it recognizes that such a change would require legislative action.
Addressing specific flexibilities described in the RFI, COGR generally supports measures that provide Institutional Animal Care and Use Committees (IACUCs) with greater discretion but notes that the flexibilities offer limited relief from the cumulative inspection demands, as most facilities undergo at least three inspections annually. COGR provides detailed feedback on several flexibility items, such as advocating for clearer conflict of interest guidance, greater institutional autonomy regarding SOP review, more explicit acknowledgment of the scope of field studies, and clarification of requirements related to AAALAC accreditation visits. The letter concludes by affirming the importance of reducing administrative burden without compromising animal health and safety, and offers to continue engaging with NIH on these issues.
