Dr. Harold Varmus, NIH
Dr. William Raub, HHS

Dear Drs. Varmus and Raub:

We, the undersigned organizations, want to express our strong support for the recommendations of the Institute of Laboratory Animal Research (ILAR) study, Approaches to Cost Recovery for Animal Research.

Animal research facilities provide laboratory space for researchers who use animal models. With respect to cost accounting, they should be treated like laboratories and not like specialized service facilities. We urge the government to adopt the ILAR committee's recommendation that the Facility and Administrative (F&A) costs associated with animal research facilities should be treated like F&A costs of other research labs.

The current government policy of requiring direct cost recovery of all F&A costs of animal research facilities has several significant negative consequences. It is a hindrance to progress on diseases and questions that require animal models because it makes proposals using animal models appear to be disproportionately expensive and therefore less competitive. Scientists will become reluctant to pursue important lines of research involving animal models out of concern that their research has less chance to be funded.

The direct cost recovery policy also has implications for quality of animal care. We are committed to the highest standards of animal care, and the current policy tends to compromise this commitment by creating a financial incentive to house animals outside the central animal facilities. Keeping animals in satellite locations undermines efficient delivery of quality animal care and could undermine the reliability of the research results.

It should also be noted that charging animal research facility F&A costs through per diem rates represents a significant accounting burden for the facility and does not seem to offer any cost-saving to the government.

From our perspectives as patient advocates, research scientists, animal care experts, and research facility administrators, we believe that it is in the public interest to use the cost recovery approach ILAR has recommended. We therefore urge you to support government adoption of this position.

Sincerely,

[sent as one of the signatories by:]

Name/Title: Glen A. Jones, Assistant Director
Research and Sponsored Programs
Organization: Wright State University
Address: 3640 Colonel Glenn Hwy.

Phone: (937) 775-4461
Fax: (937) 775-3781
Email: gjones@wright.edu