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AAU-APLU Comments on Changes to NIH Grants Policy Statement

AAU and APLU submitted brief comments today to the National Institutes of Health regarding updates to the NIH Grants Policy Statement, Section 15.2, on proposed requirements for consortium/subaward agreements on NIH-funded grants (notice: NOT-OD-23-133). Our comments requested that NIH improve alignment between the proposal’s broader definition of scientific data to comport with the data and supporting information required to substantiate research outcomes; that NIH provide further parameters of the necessary foreign subaward data and documentation required to ensure that requirements are consistent with international standards on confidentiality; and that NIH provide clarification and alignment of the retention, storage, and accessibility expectations between the scope of “scientific data” required by NIH’s 2023 Data Management Policy and the current proposal.

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