Accounting for the costs of an animal research facility has been a source of confusion and inconsistency causing friction among researchers, animal care providers and administrators. The principal issue in the debate is which of the costs of an animal research facility are direct costs that are to be charged to the investigator and which are indirect costs (facilities and administrative, or F&A costs) that are to be charged to the indirect cost pool.
Principles for determining the allocation are set forth in an Office of Management and Budget (OMB) policy, Circular A-21. Federal agencies have interpreted this policy to mean that all costs associated with an animal research facility must be recovered as direct costs through animal per diem charges. However, if a researcher keeps animals in the laboratory, the F&A costs are recoverable from the indirect cost pool and often the researcher can avoid paying the institution's animal per diem charges. That interpretation of Circular A-21 encourages investigators to house animals in research laboratories - a practice that impedes institutional oversight, leads to inefficient and sub-optimal care and compromises research results. Good science depends upon good animal care, which can be delivered most efficiently and economically in centralized animal research facilities. Thus, some observers believe that the current interpretation of Circular A-21 is contrary to good science. The National Center for Research Resources, National Institute of Health asked the National Research Council (NRC) to appoint a committee to study this issue.
The members of the Committee on Cost of and Payment for Animal Research were chosen by the National Research Council to represent a wide range of views on the interpretation of Circular A-21. The Committee 's charges were to develop recommendations to enable federal auditors and research institutions to allocate research animal facility costs congruently to the direct or F&A cost categories and to project the anticipated financial and scientific ramifications of implementing these recommendations at PHS funded institutions. Some members had worked for OMB or the Department of Health and Human Services and, in the past, may have supported the federal government's interpretation of Circular A-21; others, from industry or the Department of Defense, felt that the level of accounting detail required by the current interpretation of federal auditors was excessive and counter productive; university researchers endorsed efforts to promote high quality science while minimizing per diem charges; and animal research facility managers favored a Circular A-21 interpretation that fostered the support and development of centralized animal facility resources to provide efficient, flexible and inexpensive animal care in an environment conducive to high quality research. These views were sufficiently divergent that at the outset there was a serious question as to whether it could reach the goal of consensus. However, this report does represent such a consensus, lending considerable weight to the conclusions drawn and the recommendation made.
This report has been reviewed by persons chosen for their diverse perspectives and technical expertise in accordance with procedures approved by the Research Council's Report Review Committee. The purposes of this independent review are to provide candid and critical comments that will assist the authors and the Research Council in making the published report as sound as possible and to ensure that the report meets institutional