Statement of Joint Council of Allergy and Immunology Presented before the Committee on Energy and Commerce Subcommittee on Health and the Environment

Institute--and not to the management and policy arm of the NIH.
Are we so clear about the impact of the proposed modifications, and
that they will improve the execution of AIDS related research, that
we are prepared to overturn a 105-year precedent that has served
many diseases in good stead?
The amendment indicates that all new funds will be allocated
by the Office of AIDS Research. We believe that this may slow the
commitment of funds to research, not expedite it. The ICD's begin
planning and budget negotiations for new initiatives almost 18
months before they are awarded. If the funds for new initiatives
are appropriated to the Office of AIDS Research and allocated at
their discretion, the ICD's do not have any assurance that programs
planned one to two years in advance will actually be funded.
Further, in that it takes almost eight to nine months for the
drafting of an RFA; its release; response time from the extramural
community; review; and awarding of a specific grant; unless the
Office of AIDS Research were to release all of the new funds within
the first quarter, it is likely that any new research would not be
able to be funded within the fiscal year.
Yet, there is a more fundamental question here that will have
a far greater impact on the ability to proceed with new initiatives
that clearly highlights the added bureaucracy of the proposed
amendment. At the present time, new scientific initiatives must be
put forth for concept clearance to the advisory councils of the
categorical Institutes, as that is where the oversight of the
science base of each ICD's occurs. In order to request funding for
a new initiative through the Office of AIDS Research, the
categorical Institute's advisory council would have to approve of
the initiative. Would a second approval have to be obtained from
the Office of AIDS Research Advisory Council? If so, this would
add another layer of bureaucracy to seeking funding for and
initiating new research initiatives: prolonging the commitment of
funds and impeding the execution of research.
Discretionary Fund
The proposal for establishing a discretionary fund of up to
"25 percent of the funds available of the excess of the amount of
baseline AIDS research spending during the previous fiscal year" is
of concern. This provision is unclear since the definition of
baseline AIDS research is nebulous. With the federal government
likely facing a tight fiscal scenario for the foreseeable future,
significant appropriation increases are unlikely. If it refers
only to the increase for a given year, the 25 percent set-aside
would effectively limit any new initiatives in other research.
Peer Review
The JCAI is strongly supportive of the peer review process and
would be opposed to any proposal that would take the responsibility
for peer review out of the purview of the current process.
Therefore, we are unsure about the intent of the current amendment