The document is a formal letter from Katharina Phillips, President of the Council on Governmental Relations (COGR), addressed to Colonel Kenneth A. Bertram of the U.S. Army Medical Corps. It highlights escalating concerns within the university research community regarding revised requirements imposed by the Army Medical Research and Material Command for the management and reimbursement of costs arising from research-related injuries or illnesses in human subjects. COGR points out that universities are struggling to comply with the Army’s new prohibition against using subjects’ health insurance to cover these costs, which has made budgeting and securing appropriate insurance coverage nearly unmanageable. Universities report that identifying insurance carriers able to provide the required coverage is virtually impossible, as evidenced by correspondence from the University of Colorado Health Sciences Center’s insurance broker. Further, some liability insurance options available specifically exclude direct medical payments, necessitating legal action by injured subjects to recover costs—an outcome viewed as unacceptable.
The letter criticizes the Army’s lack of flexibility and slow resolution of issues related to existing and future grant agreements, noting that no other federal agencies impose similar requirements. COGR advocates for the Army to directly reimburse universities for reasonable and allowable injury-related expenses without requiring up-front cost estimates or prohibiting the use of third-party payers such as Medicare, Medicaid, or private insurance. The letter warns that without timely resolution or policy modification, a significant portion of research-intensive universities will be compelled to decline participation in Army-funded research, limiting both the scope and willingness of institutions to engage—especially for higher-risk, valuable projects. The communication concludes with a call for collaborative dialogue between the Army and research universities to find a workable solution that supports vital medical research without unduly burdening universities or compromising subject protections.
