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3. What is the scope of the data that can be reached under the revised Circular A-110?

Background:

The April 1999 OMB proposal mentioned availability of data "... first produced under an award" as well as requests for data " ...relating to published research findings produced under an award that were used by the Federal Government in developing policy or rules." Questions have been raised as to how the revised Circular would impact data produced under a combination of government grants and private funds. Others have questioned whether a federally-funded reanalysis of data would open up the underlying data to FOIA requests, even if the original research was conducted exclusively with private funds.

OMB offered a definition of "data" in its August 11 reproposal intended to allow for public access necessary to duplicate the study findings, but which would exclude materials necessary to protect intellectual property medical privacy rights.