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Research Compliance

Making charges to grants during an expiration period

Reader Question: I just learned that my institution's Animal Welfare Assurance with OLAW expired a couple of months ago but is now renewed. I'm concerned about the lab-animal research costs I charged to my grant during that expiration period. Will they be allowed?

Expert Comments: If an Animal Welfare Assurance (Assurance) renewal is submitted to the Office of Laboratory Animal Welfare (OLAW) prior to the expiration date and is undergoing negotiation with an Assurance Officer, the institution remains fully Assured and continues to be listed on the OLAW Web site as an Assured institution. An institution may continue to draw down funds from the grant for animal activities during this time.

However — as seems to be the case in this situation — if an institution with current PHS funding allows their Assurance to lapse by not submitting the renewal prior to the expiration date, funding on all current grants involving live vertebrate animals is affected.

In this case the institution may not draw down grant funds for animal activities until the Assurance has been renewed.

In cases like yours, where charges have been made to the grant during the unauthorized period, appropriate adjustments must be made to the grant to remove those charges. OLAW recently issued an announcement on this subject.

Part of that announcement reminds grantees that all awards involving live, vertebrate animals require a valid Assurance and approval by your Institutional Animal Care and Use Committee (IACUC) dated within the last three years. Regarding cases where activities were conducted without a valid Assurance, there might be some leeway for funding only for the care of animals during such periods.

The announcement states: "Institutions are required to report such situations to the Institute/Center (IC) supporting the award. NIH expects grantees to continue to maintain and care for animals during these periods. Funding components may allow expenditure of NIH grant funds for maintenance and care of animals on a case-by-case basis."

If an institution without current PHS funding allows its Assurance to lapse by not submitting the renewal, the Assurance will be allowed to expire and is considered inactive. If future animal research activities are considered for PHS funding, a request for reactivation of the Assurance must be submitted to OLAW.

Comments from experts at NIH's Office of Laboratory Animal Welfare (OLAW).

Feel free to submit your early-bird comments

This eAlert is brought to you as an informational training tool by the Principal Investigators Association, which is an independent organization. Neither the eAlert nor its contents have any connection with the National Institutes of Health (NIH), nor are they endorsed by this agency. All views expressed are those personally held by the author and are not official government policies or opinions.