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<h1>Federal Relations<font color="#000080"><br>
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<h3>Joint Letter from NASULGC and AASCU on OMB Circular A-110</h3>
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<p>March 24, 1999</p>
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<p>Mr. F. James Charney<br>
Policy Analyst<br>
Office of Management and Budget<br>
Room 6025<br>
New Executive Office Building<br>
Washington D.C. 20503</p>
<p>Dear Mr. Charney:</p>
<p>This letter is submitted on behalf of the National Association of State Universities
and Land-Grant Colleges (NASULGC) and the American Association of State Colleges and
Universities (AASCU) representing over 500 public colleges and universities on the
proposed revision to OMB Circular A-110 published in the Federal Register of February 4,
1999. </p>
<p>It is not a simple task to balance the nation&#146;s commitment to responsible
cutting-edge research and the public&#146;s appropriate demand for the free-flow of
information especially when it is funded by the taxpayer. Developing a responsible federal
data sharing policy as addressed in A-110 is of extreme importance to our member
institutions. We, therefore, are pleased to have the opportunity to comment on proposed
A-110 and be a part of the process to balance our joint goals.</p>
<p>First, we register strong support for freedom of information. Without question, the
public deserves access to research that its taxes have funded. Conducting research and
making it of use to the citizenry is one of the primary goals of our institutions. In our
own self interest, universities and researchers want maximum dissemination of all research
and appropriate credit for their efforts. </p>
<p>Secondly, we register an equally strong commitment to research integrity. Sound
research conducted efficiently serves the taxpayer best. It is a reasonable expectation of
the researcher and the public that federal law support responsible and reliable research.
Further, we feel that it is a university responsibility to protect research integrity.</p>
<p>&nbsp;You will receive many letters from research universities and associations that
relay concrete examples of possible unintended ramifications of proposed A-110. In
particular, we register our support for the well-documented and thoughtful letter from the
Association of American Universities. We believe that several general points are worth
reiteration:</p>
<u><p>Timing concerns</u> -- The premature release of research data (that is, release
while research is ongoing) can potentially result in under informed and faulty
interpretations by observers; constrictions on the research process that could impact the
quality of a research project; and delays in the research process resulting from responses
to requests.</p>
<u><p>Intellectual Property concerns</u> -- Because publicly disclosed information is not
eligible for foreign patents, U.S. scientists would be put in at a unique disadvantage if
results are prematurely disclosed. Additionally, the willingness of business and industry
to form research partnerships with universities could decrease due to questions that would
certainly be raised regarding the ownership of intellectual property. This problem is
magnified because federal funding increasingly requires business and industry
partnerships. </p>
<u><p>Confidentiality conflicts</u> -- Some medical and psychological protocols require
the collection of confidential data. If this confidentiality is lost, the pool of subjects
could shrink to the point that some research projects became unreliable.</p>
<p>We believe that these potential problems would be unintended consequences of the
proposed A-110 revisions. This is a set of complex issues that are of great importance to
research universities and, ultimately, the public. We, therefore, join in supporting the
recommendation that the National Academy of Sciences study the federal data sharing policy
issue and report back with recommendations that take into account freedom of information
and research integrity.</p>
<p>Thank you for this opportunity to comment and your attention to these concerns. </p>
<p>Cordially,</p>
<p>James B. Appleberry
&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp; C.
Peter Magrath<br>
President, AASCU
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NASULGC</p>
<p>CPM/jw</p>
<p>Attachment</p>
<p>cc: Nils Hasselmo, Association of American Universities<br>
Stanley Ikenberry, American Council on Education<br>
Bruce Alberts, National Academy of Sciences</p>
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