Why a Congruency Review is Needed

The principal funding source for live vertebrate animal research at Yale  is the U.S. Department of Health and Human Services (HHS), primarily through the Public Health Service (PHS) and the National Institutes of Health (NIH).  PHS and NIH Grants Policy requires the institution to verify, before award, that the institution’s IACUC has reviewed and approved the animal work outlined in the proposal.  Specifically, “It is an institutional responsibility to ensure that the research described in the application is congruent with any corresponding protocols approved by the IACUC.”  (NIH Policy Statement 10/12)

Therefore, a congruency review is required for all funding that uses live vertebrate animals to ensure that the work described in the proposal comports with an active, approved protocol. At Yale, DoRC conducts a side by side direct comparison of the proposal and the IACUC protocol.  For program consistency and to maintain the highest standards for compliance, DoRC applies these rules to all funding proposals, regardless of source.  Additionally, any award involving animal work requires IACUC congruency review and approval before Yale Grants and Contracts (GCA) will release funds associated with that award. (Excerpts from both the PHS and NIH Grants Policy Statements can be found below.)