1. Why are we checking congruence between grant proposals and animal activity protocols?
The Public Health Service (PHS) expects all animal activities proposed in a grant to be approved by an organization's Institutional Animal Care and Use Committee (IACUC) prior to the beginning of those activities. Ensuring congruence between grant funded activities and IACUC-approved activities is an ongoing process. In order to accept PHS/NIH funds, the awardee must verify that it has reviewed and approved the grant's proposed animal activities. In addition, if the grant-funded animal activities need to be modified during the duration of funding or at the time of renewal, the IACUC must first approve these modifications to the animal activities. Failure to follow these practices will result in noncompliance with PHS/NIH polices and could jeopardize current and future funding.
Public Health Service (PHS) policy states that awards may not be issued unless the awardee's IACUC "provide[s] verification that the IACUC has reviewed and approved those sections of the application that involve use of vertebrate animals,... ." ". If an application is selected for award and the verification of IACUC review has not been submitted, the awarding office will contact the organization with instructions for negotiating an assurance or submitting the IACUC verification."
Although other funding agencies may adopt different polices, UTHSC applies PHS/NIH standards for the use of all live vertebrate animal research. This is because the NIH Office of Laboratory Animal Welfare (OLAW) discourages multiple standards of review, approval or compliance measures for different funding sources.
Further guidance is provided in other sections of PHS and NIH policies and in NOT-OD-10-027 (Instructions for Completion and Peer Review of the Vertebrate Section (VAS) in NIH Grant Applications and Cooperative Agreements and a slide presentation by the OLAW Director).
The IACUC is not responsible for notifying the NIH of changes in scope; rather the Principal Investigator (PI) and the Authorized Organizational Official (AOO) are responsible for requesting approval of a change in scope. The request for a change in scope must be made in writing to the Grants Management Officer (GMO) of the NIH Institute or Center (IC) that funds the grant (the funding component). The request must be made no less than 30 days before the proposed change and must be signed by both the PI and the AOO.
For further information please review these relevant FAQ's from the OLAW website.