Comments and Letters
An archive of comments and letter the APS has issued on a variety of science policy issues.

APS Response to NIH RFI on Coordinating and Harmonizing Regulations and Policies

Comments by APS on NIH’s March 14, 2018 RFI (NOT-OD-18-152) seeking information to improve the coordination of regulations and policies with respect to research with laboratory animals as required by the 21st Century Cures Act.

On NSF Sexual Harassment Reporting Requirements

APS response to NSF's request for public comment on new reporting requirement for sexual harassment, other forms of harassment, or sexual assault

Letter to Appropriations Leadership on NIH FY 2018 Funding

Letter from APS President Dennis Brown to the Chair and Ranking Member of the Senate appropriations subcommittee that handles NIH funding. A similar letter was also sent to the corresponding House subcommittee leadership.

Letter to Appropriations Leadership on NSF FY 2018 Funding

Letter from APS President Dennis Brown to the Chair and Ranking Member of the Senate appropriations subcommittee that handles NSF funding. A similar letter was also sent to the corresponding House subcommittee leadership.

APS Statement on Taxation of Graduate Student Tuition Waivers

The APS urges Congress to preserve the current tax exempt status of tuition waivers for graduate students who serve as teaching or research assistants.

APS Letter on Canine Research at VA

Letter from APS President Dennis Brown to the chairs of the House and Senate Appropriations subcommittees responsible for VA funding that underscores the importance of research with dogs as part of efforts to develop treatments for serious medical conditions affecting veterans.

APS Letter on the FACT Act

APS letter to Rep. Ken Calvert (R-CA) about the The Federal Accountability in Chemical Testing (FACT) Act, which aims to encourage non-animal methods of testing and research but would not effectively result in improved animal welfare.

APS Urges Congress to Reject Proposed Cuts to Research

APS issued a statement March 16 urging Congress to reject President Trump’s plan for drastic NIH budget cuts.

APS Statement on the March for Science

Our statement on the March for Science

APS Letter to Gene Dodaro

APS President Jane F. Reckelhoff challenged recent Congressional requests for an investigation of animal research at federal agencies in a letter to the head of the Government Accountability Office (GAO).

APS Responds to NIGMS RFI on Strategies for Modernizing Biomedical Graduate Education

In response to an NIGMS RFI on Modernizing Biomedical Graduate Education, the APS Science Policy and Education Committees jointly developed a response that emphasized the need for students to develop a range of core skills that will serve students well in their future careers.

APS Suggests Ways for USDA to Reduce Regulatory Burden

The APS submitted these comments in response to a request for information by the USDA (Docket USDA-2016-0001-0001) on regulatory burden.

APS Statement on International Regulation of Ketamine

APS comments on FDA request for comments on a proposed scheduling change of ketamine.

APS Responds to RFI on Amending USDA Reporting Requirements

APS tells USDA that proposed changes to research animal reporting requirements would not benefit animals but will increase administrative burden.

APS Urges USDA to Reject New Nonhuman Primate Standards

The APS submitted comments urging USDA to reject a request from several animal rights groups to develop specific ethologically appropriate standards for nonhuman primates in research. The APS noted that the supporting evidence for this request consisted of a biased review of outdated reports about the treatment of nonhuman primates in research. In fact, research facilities provide social housing for the majority of nonhuman primates and otherwise ensure their psychological well-being by providing foraging opportunities, manipulanda, and sensory and cognitive stimulation, as well as positive reinforcement training and other kinds of behavioral management.

APS Comments on NIH Strategic Plan Framework

On July 22, 2015, the NIH issued a request for information on the framework for their first ever agency-wide strategic plan. The NIH’s goal in this effort is to identify cross-cutting research priorities and outline a set of unifying principles to guide the NIH. The APS provided comments on the framework, endorsing the emphasis on fundamental science and developing a diverse workforce and offering suggestions to broaden the scope of the document.

APS Urges Senate to Authorize NIH Funding Increases

APS offered the Senate Health, Education, Labor, and Pensions (HELP) Committee suggestions on reauthorizing programs at the NIH. APS underscored basic research as the foundation for the development of cures and urged easing burdensome regulations.

APS Comments on Alternatives Search Requirements

APS's full comments on the USDA’s RFI regarding a petition asking the agency to issue new regulations on the consideration of alternatives to procedures that may cause pain or distress to laboratory animals.

APS Suggests Ways for USDA to Reduce Regulatory Burden

The APS submitted these comments to the USDA providing examples of regulations that could be modified, streamlined, expanded, or repealed to reduce regulatory burden in response to a request for information (RFI) by the USDA.

APS Comments on Sustaining the Research Enterprise

APS provided these comments in response to an NIH request for information (RFI) on strategies to optimize the impact and sustainability of biomedical research.

APS Comments on Field of Degree Question

In response to a request for comment from the United States Census Bureau, APS spoke out in support of retaining a question about undergraduate field of degree on the annual American Community Survey. The data gathered in response to this question is used by the National Science Foundation to prepare their Science and Engineering Indicators and Women, Minorities, and Persons with Disabilities in Science and Engineering reports. The National Science Board has also submitted a letter opposing the removal. For more background on this issue, including the politics that led to the proposed elimination, see this article in ScienceInsider.

APS Advises NIH on Sex as a Biological Variable

On September 11, 2014 NIH issued a Request for Information (RFI, NOT-OD-14-128) to assist NIH develop policies for the inclusion of sex as a biological variable in pre-clinical research studies involving animals and cells. The APS response recommends starting with accurate reporting of the sex of animal subjects and organisms from which biological materials were derived. NIH should provide training for investigators and reviewers before implementing the policy. APS also said additional resources will be needed to implement this policy without detriment to ongoing research.

On Proposed NIGMS Program

In response to a request for information from the National Institute for General Medical Sciences, APS submitted comments on the proposed Maximizing Investigators’ Research Award (MIRA). This award would be a grant in support of all of the research supported by NIGMS in an investigator’s laboratory.

The American Physiological Society Statement on H.R. 4879

The American Physiological Society (APS) supports the efforts of Representative Cooper and the cosponsors of this legislation to promote high quality research through H.R. 4879, the “Research for All Act of 2014.”

On Benefits of SEPA Program

In a letter to the NIH Scientific Management Review Board’s working group on pre-college engagement in biomedical science, APS President David Pollock shared the many benefits experienced by teachers participating in programs supported by the science education partnership awards (SEPA). Dr. Pollock urged the working group to consider including SEPA in future plans to foster the next generation of researchers. (PDF)