The memorandum, sent jointly by several major associations representing higher education and research institutions, addresses the Office of Research Integrity (ORI) regarding the recently published Notice of Proposed Rulemaking (NPRM) on Public Health Service Policies on Research Misconduct. The associations express their commitment to upholding research integrity and acknowledge ORI’s efforts to update the regulations based on nearly two decades of experience since the last revision in 2005. However, they raise concerns about the limited 60-day window provided for public comment on these extensive and impactful regulatory changes, noting that this timeframe overlaps with the Thanksgiving holiday period, further limiting stakeholder participation.
Given the scope and significance of the proposed revisions, the organizations argue that a thorough review involving multiple stakeholders—such as researchers, research integrity officers, and administrative personnel—is essential. They emphasize the necessity for sufficient time to analyze the regulatory changes both in terms of procedural and financial implications before submitting informed feedback. Therefore, the memorandum formally requests a 45-day extension of the comment period, suggesting a new deadline of January 19, 2024, to ensure the regulated community can conduct an adequate analysis and provide comprehensive comments. The signatories thank ORI for its consideration and anticipate a favorable response to their request.