Dear Mr. Moore: The Council on Governmental Relations (COGR) is an association of 183 research universities and affiliated academic medical centers and research institutes. COGR concerns itself with the impact of federal regulations, policies, and practices on the performance of research conducted at its member institutions. The amendments proposed by the Public Health Service (PHS) to the Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought are significant changes that will alter the relationship between a research institution and its investigators and the institution and PHS.

Dear Mr. Moore: The Association of American Universities, the Association of American Medical Colleges, the American Council on Education, and the Association of Public and Land-grant Universities appreciate the opportunity to submit comments in response to the Notice of Proposed Rulemaking concerning Responsibility of Applicants for Promoting Objectivity in Research for Which Public Health Service Funding Is Sought and Responsible Prospective Contractors.

Dear Mr. Moore: The Association of American Universities (AAU) represents 60 leading U.S. research universities who together perform nearly 60 percent of all federally funded university-based research and annually award more than half of all Ph.D. degrees earned in our country.

Dear Ms. Conte: I write to you on behalf of the Association of American Universities (AAU) to comment on the Supplemental
Standards of Ethical Conduct and Financial Disclosure Requirements for Employees of the Department of Health and Human Services (5 CFR parts 5501 and 5502, Federal Register, February 3, 2005, p. 5543). AAU is composed of 60 of the leading U.S. and two Canadian research universities; its U.S. members perform 60 percent of federally funded university research and grant nearly half of all Ph.D. degrees awarded nationally.

Dear Mr. Pascal: This letter presents comments of the Association of American Medical Colleges (AAMC), the Association of
American Universities (AAU), the Council on Governmental Relations (COGR), and the National Association of State Universities and Land-Grant Colleges (NASULGC). The AAMC represents the nation’s 126 accredited medical schools, over 400 major teaching hospitals and health systems, and 94 academic medical societies representing nearly 105,000 faculty members. The AAU is an organization of public and private research universities devoted to maintaining a strong system of academic research and education, and consists of 60 U.S. and 2 Canadian universities. COGR is an association of 150 research intensive universities, affiliated hospitals and research institutes in the United States organized to work with federal agencies to develop a common understanding of the impact that policies and regulations may have on the research conducted by its membership. NASULGC is a voluntary association of public universities, land-grant institutions and many of the nation's public university systems, and member campuses are located in all 50 states, the U.S. territories and the District of Columbia.

WASHINGTON, D.C.—The Association of American Universities, which represents 63 leading North American research universities, today released a report that makes specific recommendations for strengthening universities' oversight of potential financial conflicts of interest in research. The goal of the report is to help universities sustain public confidence in their research activities in a time when commercialization of university research is becoming more common.

Dear Colleagues: The AAU Task Force on Research Accountability has just completed its report on individual and institutional conflict of interest. The report is intended to identify ways in which presidents and chancellors can help ensure the integrity of their institutions, and thereby bolster the public's confidence in research universities.

Dear Dr. Koski, The Office of Human Research Protection (OHRP) recently placed a document on its website with a request for comment. The document, labeled "draft interim guidance," is entitled "Financial Relationships in Clinical Research: Issues for Institutions, Clinical Investigators, and IRBs to Consider when Dealing with Issues of Financial Interests and Human Subjects Protection." (referred to hereafter as Guidance). Our three associations, which represent key segments of the academic community concerned with regulatory compliance in this area, provide comment on this unusual interim (effective "when?") draft guidance document because of the seriousness of the issue. We are concerned for substantive as well as procedural reasons.