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AAU Comments on Interim Final HHS Ethics Rule

As an association of research universities, AAU does not have standing to comment on HHS regulation of its civil service employees.  However, we do believe that the new and significantly tighter financial disclosure requirements should be considered carefully.  In developing such standards, NIH should evaluate their prospective impact on the agency’s ability to recruit and retain the best scientific talent.  Recent responses to the newly implemented reporting and divestiture requirements suggest that they are harming NIH’s capacity to attract and retain such highly-qualified individuals.  NIH should implement standards that allow it to maintain public confidence in its operations, but it should avoid standards that exceed requirements for public accountability and impair its ability to attract the exceptional talent that the agency needs for its critical mission.  

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