Many people in the DEB community work with vertebrate animals, and therefore require approval from their Institutional Animal Care and Use Committees (IACUCs) to conduct their research.

Since NSF does not oversee or regulate animal research, it is important for investigators to know that a project’s IACUC approval must be adequately documented before program officers can recommend an award for funding. In this blog post we offer answers to common questions regarding the NSF documenting procedures for IACUC protocols to help you to efficiently comply with the existing policy.

1. Where can I find information on NSF guidelines regarding IACUCs?

The NSF Proposal & Award Policies & Procedures Guide (PAPPG) contains the official policy on how to document your IACUC approval in your proposal (Part I, Chapter II Proposal Preparation Instructions, D. Special Guidelines, 4. Proposals Involving Vertebrate Animals).

2. Where in the proposal is IACUC approval documented?

On the proposal cover page there is a box that should be checked if the proposal includes research with living vertebrate animals. Immediately following there is a space to provide the IACUC protocol approval date as well as the Public Health Service (PHS) Approved Animal Welfare Assurance number.

3. How do I know if my institution already has PHS assurance?

Institutions proposing to use vertebrate animals in an NSF-funded project are required to list their single and unique PHS assurance number on the NSF proposal cover sheet. If there is no PHS assurance number listed, check the NIH/OLAW website for the current list of PHS assured institutions: http://grants.nih.gov/grants/olaw/assurance/300index.htm. For the IACUC approval to be accepted by NSF, the organization must have a current PHS Approved Assurance. If your institution doesn’t have a current PHS Approved Animal Welfare Assurance number, please list it as “pending” on submission. If NSF intends to make an award to your institution, it will submit a direct request to NIH/OLAW to start the assurance process.

3. What if I have a current IACUC protocol that encompasses the type of work that I am proposing to do in the NSF proposal that I am submitting?

If the box for vertebrate animals is checked, and an IACUC approval date and PHS Assurance number are provided on the proposal cover page then no additional IACUC documentation is required for the proposal to be recommended or an award processed. When the officer from your institution’s Sponsored Research Office (SRO) signs off on the proposal, they are affirming that the approved protocol exists and is congruent with the work outlined in the NSF proposal. It is important to note that this IACUC protocol must still be current at the time of the proposal submission and an approved protocol for the project must be maintained for the duration of the award (most IACUC protocols expire after 3 years).

4. What if I do not have an approved IACUC protocol for the proposal I am submitting?

If your IACUC protocol is not yet approved, you can indicate that the IACUC approval is “pending” on the cover page. If you fall in this category, here are a few things to keep in mind:

• IACUC committee tend to meet at a pre-set schedule throughout the year. If you have not yet started the IACUC approval process, please be aware of these timelines and recognize that awards cannot be processed at NSF without IACUC approval.
• Once granted, NSF must receive a signed IACUC approval from your institution, that must explicitly reference the proposer’s name, the title and number of the NSF proposal, and the date of IACUC approval.

5. What if the research I am proposing to do will take place outside of the United States?

Projects involving the care or use of vertebrate animals at an international organization or international field site also requires approval of research protocols by the US grantee’s IACUC. Often, local approval from an international institution will also be necessary. Always ask the IACUC at your institution about how they handle international projects that involve living vertebrates.

6. If the NSF proposal is for a fellowship or for an individual (e.g. postdoc), how is the documentation for the IACUC different?

For fellowships and proposals to individuals, a signed letter from the institution must still be submitted to NSF prior to an award action even if there is an IACUC approval date and PHS Assurance number documented on the proposal cover page at the time of submission. The letter must include the IACUC approval date, the institution’s PHS Assurance number, and it must specifically reference the proposer’s name, the title and number of the NSF proposal, and the date of IACUC approval.

7. What if I am applying for a fellowship or award to an individual and I plan to conduct this work outside of the United States?

If the proposal is to fund an individual (not an institution) and the proposed work is to take place outside of the U.S., then a signed letter from the appropriate official at the foreign institution must be submitted to NSF that confirms that the work will comply with applicable laws in that foreign country and that it will adhere to the International Guiding Principles for Biomedical Research Involving Animals.

8. If I am applying for an REU (or any other award supplement) will I need to submit IACUC documentation?

Supplements to existing awards generally do not require a separate IACUC approval letter unless the IACUC approval on the parent award is more than three years old or the scope of the project has changed substantially.

If the scope of the work has changed, in lieu of resubmitting an entirely new IACUC protocol an amendment to your existing IACUC protocol may suffice. An amendment is typically much easier to prepare than a new protocol. Check your institution’s IACUC policies to see what types of revisions are recognized as appropriate for a protocol amendment.

9. If I am submitting a collaborative proposal with multiple institutions will each institution need a separate approved IACUC protocol?

Each institution that proposes to conduct research with living vertebrates must have their own current and approved IACUC documentation – this includes work conducted by a non-lead collaborative institution and work conducted under a subaward.

10. My proposed research entails using multiple species of living vertebrates, and/or multiple locations. Will one IACUC protocol be sufficient?

Depending on the nature of the work, one IACUC may not be sufficient to cover the entire scope of your work. Please confirm with your institution’s IACUC that all of the work is being covered.

11. I am submitting a proposal to NSF, but I am not sure if the vertebrate animal work in the proposal requires IACUC approval (e.g., the research involves only observations of vertebrates in the field).

Ask your institution’s IACUC whether the proposed work warrants IACUC approval. If the IACUC does not think one is needed, we recommend that you procure an email from the chair of the IACUC committee (using their institution email) stating that IACUC approval is not necessary for the scope of the proposed work. It is always safer to have the committee make this decision rather than making the decision on your own. Usually, such email can be obtained ad hoc, outside of your institutions regular IACUC meeting and review schedule.

12. What about preserved specimens — will I need an IACUC to work with non-living vertebrate animals from a natural history collection?

IACUC approvals are only necessary for research with living vertebrate animals.

13. My proposal doesn’t include vertebrate animals in a research capacity, but my broader impacts and/or outreach activities do involve vertebrate animals. Will I still need IACUC approval?

Most likely IACUC approval is still necessary in this circumstance. Please contact the NSF animal welfare officer for additional information.