The Council on Governmental Relations (COGR), representing numerous major U.S. research universities and institutes, submitted comments to the National Institutes of Health (NIH) in response to a Request for Information regarding the grant to protocol congruency review requirement (“Congruency Requirement”) for animal research. COGR argues that this requirement, which mandates a comparison between grant proposals and IACUC-approved protocols to ensure alignment before research funding is awarded, offers minimal value in terms of either animal welfare or administrative oversight. Instead, COGR points out that the main safeguard for animal research integrity—the IACUC review of all protocols and significant amendments—is already robust and sufficient to protect research animals.
COGR references the precedent set by the Office of Human Research Protections, which eliminated a similar review for human subjects research without reducing protections, and contends the Congruency Requirement similarly consumes institutional resources without commensurate benefit. The letter critiques clarifications provided in the RFI, maintaining that shifting the review to other administrative units or limiting its timing does not meaningfully reduce burden. COGR further requests clarification from NIH to explicitly state that documentation of the Congruency Review need not be submitted, only proof of IACUC approval. In conclusion, COGR urges NIH to eliminate the Congruency Review, thereby reducing unnecessary administrative requirements without compromising the welfare of laboratory animals, and expresses a willingness to collaborate further on effective regulatory reform.
