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CRE Analysis

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

Comment by Council of State and Territorial Epidemiologists

CRE Response:

CRE recommended in its initial comments that OMB adopt a definition of data that was broad enough, at a minimum, to allow for replication of the research study results, and we are pleased that this suggestion was adopted in the August reproposal.

CRE also notes that OMB has clarified that the August 11 reproposal excludes "preliminary analyses, drafts of scientific papers, plans for future research, peer reviews, or communications with colleagues [and] physical objects (e.g., laboratory samples)". The reproposal would therefore seem to address CSTE's concern regarding the possible disclosure of "meeting notes, laboratory samples, secondary sources, etc."