Grant Proposals: Why IACUC Needs Them

The Institutional Animal Care and Use Committee (IACUC) requires investigators to provide a copy of their grant proposal when an animal use protocol (AUP) is submitted. Because failure to provide the proposal can result in significant delays in processing AUPs, here is some information which should assist investigators in meeting this requirement:

Why does the IACUC need a copy of my grant proposal?
The IACUC must assure your granting agency that all the animal work described in your grant proposal has been approved. Upon approval of an AUP, the Committee generates a letter stating that the animal research described in the AUP is approved. This same letter is forwarded to your granting agency (e.g., NIH, NSF, USDA, AHA, etc.) as verification that the IACUC has reviewed and approved the animal work described in the grant proposal. Without a copy of the grant proposal, IACUC has no way to determine whether the animal work described in the AUP corresponds to that described in the proposal, and therefore can not with certainty provide the approval sought by the granting agencies. An accompanying proposal can also assist IACUC reviewers in understanding the rationale and scientific approach of the project, facilitating approval. IACUC needs to know the funding agency for your proposal because the review and reporting requirements differ among agencies. Attaching the proposal is the most effective way to ensure that IACUC is fully cognizant of the regulatory requirements governing each animal project.

How should I submit my AUP and proposal to the IACUC?
Each AUP which requests approval for animal research described in a grant proposal must arrive at the IACUC office with the proposal attached. IACUC’s standard practice is to compare the AUP to the grant proposal. Review can therefore not begin until a copy of the grant proposal arrives at the IACUC office. The most effective way to ensure that this happens is to have the campus office submitting the proposal (Texas A&M AgriLife, TEES, etc.) package the AUP with your proposal and forward them both to the IACUC office as part of the grant submission process. Please do not submit your AUP directly to the IACUC office if there is an accompanying proposal being processed by another campus office. This only causes confusion when the campus routing office submits a duplicate copy. Investigators can be most effective in speeding AUP approval by ensuring that the campus office submitting the proposal has received their AUP and has forwarded it to the IACUC.

What if I have no grant proposal?
AUPs for teaching animal use can be submitted directly to the IACUC office. AUPs for research animal use where no proposal exists (internal funds, start-up, etc.) should indicate this on the AUP form. If funding is internal, say so and submit the AUP directly to the IACUC office. If you write NIH or Research Foundation in the AUP form and no proposal exists, substantial time will be lost while the nonexistent proposal is sought. Graduate students submitting AUPs for their graduate research should attach a copy of their thesis/dissertation proposal.

Do federal agencies require IACUC to obtain grant proposals?
They strongly recommend it. In a commentary in Lab Animal (28:21,1999), Nelson Garnett of OLAW (NIH) and Ron DeHaven of USDA, the directors of the animal welfare compliance offices of their respective agencies, stated: "The [NIH] 398 grant application form certifies, among other things, that the IACUC has reviewed and approved all animal-related activities associated with that grant application. The signature of an authorized institutional official on the 398 indicates the organization’s intent to comply with the laws, regulations, and policies to which the grant is subject, including applicable public policy requirements. ...there is a requirement that the IACUC review and approve all PHS-supported animal activities. One excellent way to prevent problems of inconsistency...is to implement a procedure for direct comparison of the grant application with the protocol."