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the revised bill text, which are attached for your reference, as well as high-level bullets (see email chain below).
ACTION: By 10a Thursday (10/17), please provide any new edits/comments in the attached "HHS points" document.
Please let us know if you have any questions.
Thanks,
Chase
From: Crawford, Chase (NIH/NIAID) [E]
Sent: Monday, September 30, 2024 2:31 PM
To: NIAID BUGS
@niaid.nih.gov>; NIAID DEA DART
@mail.nih.gov>; NIAID DIR-OCGR <NIAIDDIR-
@mail.nih.gov>; NIAID DCR-OCGR
@mail.nih.gov>; Nealy, Michael (NIH/NIAID) [E]
@nih.gov>; Auchincloss, Hugh (NIH/NIAID) [E]
@niaid.nih.gov>; Harper, Jill (NIH/NIAID) [E]
@niaid.nih.gov>; Parker, Marie (NIH/NIAID) [E]
@niaid.nih.gov>; Billet, Courtney (NIH/NIAID) [E]
@niaid.nih.gov>
Cc: NIAID OCGR Leg
@mail.nih.gov>; Erbelding, Emily (NIH/NIAID) [E]
@nih.gov>;
Holland, Steven (NIH/NIAID) [E]
@niaid.nih.gov>; Hanson, Christopher (NIH/NIAID) [E]
@niaid.nih.gov>; Poe, Kelly (NIH/NIAID) [E]
@nih.gov>; Gilles, Sharon (NIH/NIAID) [E]
@nih.gov>; DDSM Correspondences
@mail.nih.gov>
Subject: FYI - Update on TA for revised bill text for Risky Research Review Act
FYI - Bldg. 1 has asked NIAID to provide a few top line bullets outlining the types of comments that were submitted on
the redline version of the bill. NIAID plans to share the below bullets and indicate that NIAID shares many of the concerns
raised by OER, ORS, and OSP (their top line bullets are copied further below). We will request a copy of the consolidated
NIH TA and share it with you if/when we receive. Please let us know if you have any questions at this time. Thanks, Chase
NIAID
NIAID notes that, to avoid confusion, the definitions in the bill pertaining to scientific and/or current policies should
be consistent with definitions in science and those policies, including the USG Policy for Oversight of DURC and
PEPP (https://www.whitehouse.gov/wp-content/uploads/2024/05/USG-Policy-for-Oversight-of-DURC-andPEPP.pdf). Further, as written, some definitions are overly broad and could slow research in critical areas, including
research on antimicrobial resistance and the H5 influenza outbreak in dairy cattle.
NIAID also notes that, as written, the proposed Board may lack essential expertise in infectious diseases and
biosecurity.
NIAID notes that it is unclear if it is the drafters' intent to prohibit funding for an entire award prior to Board
approval or only work related to potential "high-risk" research. Similarly, there is a later provision that would
require a pause in research due to a change in circumstance, but it is unclear if such a pause would apply to an
entire award or only work related to potential "high-risk research.
OER
It is unclear what added value the Board may have over current processes. The Board seems redundant with
existing/current efforts and/or those being implemented following OSTP's mandate on DURC/PEPP.
The Board's scope is very broad and may apply to a variety of research areas. We defer to OSP on the included
research definitions.
The Board will have significant control over funding decisions, which may interfere with existing statute on NIH
funding activities.
We have concerns about the Board reaching out directly to applicants/recipients, which is outside traditional NIH
reporting procedures.
The required timeline of some Board activities is unclear.
Flagged in previous TA, we have concerns about the confidentiality of application information and recommend
more details be provided on how such information will be used or protected.
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Records on this page
| Record | Date | Type | Pages |
|---|---|---|---|
| FYI - Update on TA for revised bill text for Risky Research Review Act | 2024-09-30 | 148–150 | |
| reading_room:email:00147 | 2024-10-11 | 147–148 |