It is understandable that the Vice Provosts for Research (VPRs) of the four Great Eastern campuses want the authority as Institutional Officials (IOs) to allocate resources as they see fit for their individual programs rather than allowing a single IO to represent all campuses. Having one IO per campus can work well as long as each campus maintains a separate Animal Welfare Assurance, registration with the US Department of Agriculture (USDA) and accreditation with the Association for Assessment and Accreditation of Laboratory Animal Care International (as applicable to their programs).
The real question, then, may be what acceptably counts as an institution requiring an Assurance or USDA registration, noting that the Public Health Service Policy for the Humane Care and Use of Laboratory Animals1 and Animal Welfare Act2 offer institutions wide latitude to define and organize themselves. The regulations do not preclude one individual from serving as chief executive officer (CEO) or IO of multiple institutions or prohibit a single campus from being divided into multiple Assured or registered entities, so long as all activities requiring institutional oversight are, in fact, overseen. Designating the four Great Eastern campuses as separate institutions will allow greater local control of their individual programs.
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