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UC Comments on the Notice of Proposed Regulation Adoption: Addition of Section100505 (CIRM Award Management Policy) to Chapter 5 of Title 17 of the California Code of Regulations
Abstract
This comment letter responds to the California Institute for Regenerative Medicine (CIRM)'s proposed adoption of Section 100505 (CIRM Award Management Policy). The University of California (UC) generally supports the proposed policy but recommends revisions to ensure facilities and indirect cost reimbursement accurately reflects the true costs of conducting research, simplify implementation timelines for existing awards, clarify liability and indemnification provisions, and provide more practical requirements for returning unobligated funds, in order to promote fair, efficient, and sustainable research administration.