COGR Responds to RFI on Flexibilities for Streamlining IACUC Review of Protocols and Significant Changes (NOT-OD-23-152)

COGR submitted formal comments in response to the NIH’s Request for Information (RFI) regarding flexibilities for streamlining Institutional Animal Care and Use Committee (IACUC) review processes. COGR emphasizes the importance of maintaining animal welfare and research integrity while advocating for efficient regulatory frameworks that minimize unnecessary administrative burdens, as mandated by the 21st Century Cures Act. However, COGR expresses disappointment that the RFI mainly reiterates existing flexibilities rather than introducing substantive new revisions to reduce administrative load. They specifically critique the Office of Laboratory Animal Welfare (OLAW) for allowing IACUC members to call for full committee review (FCR) at any time before protocol approval, arguing that this policy undermines the effectiveness of streamlining efforts and fails to deliver meaningful administrative relief. COGR offers detailed feedback on each proposed flexibility, generally supporting provisions such as clearer documentation, increased autonomy in reviewer assignment, and the use of established guidelines for protocol review. Nevertheless, the organization notes that many of the RFI’s suggestions represent reaffirmations of prior policies rather than true innovations. COGR encourages OLAW to permit enforceable, reasonable timeframes for FCR requests and to develop new policies that more effectively reduce procedural burdens for researchers and administrators. In conclusion, COGR urges OLAW to move beyond reiteration of established practices and to adopt broader, more impactful reforms that would enable research institutions to focus more efficiently on scientific work and animal program oversight, in keeping with the intent of the Cures Act.