The Council on Governmental Relations (COGR), representing 190 U.S. research universities and associated institutes, responded to the NIH’s request for input on enhancing rigor, transparency, and translatability in animal research (Notice NOT-OD-20-130). COGR emphasizes that while additional mechanisms like pre-registration of protocols may improve rigor and transparency, such systems should be thoroughly piloted before broad implementation to ensure added value rather than imposing undue administrative burdens. They note that more effective enforcement of existing reporting guidelines (e.g., ARRIVE, PREPARE) and greater use of tools for experimental design could be beneficial, but caution against duplicating peer review processes and highlight challenges such as concerns over intellectual property and the potential misuse of pre-registration information to malign researchers.
COGR further underscores the need to better educate the public about the importance and oversight of animal research to improve transparency, especially regarding large animal models, which are vital for key biomedical advances but face logistical and cultural barriers. In addressing translatability, COGR advocates for increased NIH support for robust, basic animal research and cross-species studies prior to clinical translation, arguing that overemphasis on rapid translational research can undermine the reliability of findings. They also encourage a research culture that values all outcomes—positive and negative—and recommend stronger training in experimental design and statistics. The organization concludes by advising that any new policies prioritize improvements to existing review systems over the creation of additional administrative requirements, ensuring reforms are both effective and minimally burdensome.
