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Materials Transfer in Academia

Author: COGR

Published Date: 09/01/2003

20MaterialsTransferinAcademia

COGRCOUNCIL ON

GOVERNMENTALRELATIONS

September, 2003

Questionsand

Answers

Council on Governmental Regulations

Page 2

COUNCIL ON

GOVERNMENTAL

RELATIONS

The Council on Governmental Relations (COGR) is anassociation of leading research-intensive universities.COGR’s primary function consists in helping to developpolicies and practices that fairly reflect the mutualinterests and separate obligations of federal agencies anduniversities in federal research and training. COGR dealsprimarily with policies and technical issues involved inthe administration of federally-sponsored programs atuniversities. It keeps under continuing review theproblems potentially inherent in the development offederal policies, regulations, and other federal initiatives.

This brochure attempts to provide relevant informationabout the transfer of materials in academia. It does notclaim to be a manual of university technology transfer,nor does it offer model policies. This brochure shouldnot be taken as formal legal advice, and COGR cannotand does not warrant the legal sufficiency of the answersto the questions discussed in the brochure.

Copyright © 2003Council on Governmental Relations

1200 New York Avenue, Suite 320Washington, DC 2005

(202) 289-6655

While COGR encourages copying of this brochureto enable broad usage, reproduction for sale or

profit is strictly prohibited.


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TABLE OF

CONTENTS

20Introduction .............................................................. 4Under what circumstances is an MTA needed? .. 8From the University perspective, what MTA terms

frequently raise problems? ............................ 9How do agreement terms restrict academic

freedom? ........................................................ 10Why is there concern about ownership rights? . 12What is meant by “reach-through rights” and

when are they justified? ................................ 13What Are Some Desirable Definitions of Terms in

Biological MTAs? ........................................... 15How is ownership of combination materials

determined? ................................................... 17Is there an option for an institution to forego

ownership rights? .......................................... 18What is indemnification, and what is the

importance of limiting indemnificationrequirements? ............................................... 20

Why is it useful to use MTAs when materials arebeing sent to academic colleagues? ............ 21

Can MTA agreements be expedited throughstandardization? ............................................ 22

Who has the authority to sign MTAagreements? .................................................. 23

Are MTA agreements ever enforced? ................ 24Is it reasonable to charge fees for the transfer of

the material? .................................................. 25Are there other means of getting materials when

the obstacle is time and effort? .................... 26What are the implications of NIH’s “Principles and

Guidelines...”? ................................................ 27Are there special requirements for transferring

human embryonic stem cells? ..................... 29Are there special requirements for transferring

“special” biological material? ....................... 30Is an export license needed to transfer materials

outside the United States? ............................ 31Are there special regulations regarding the

transfer of toxic biological agents? .............. 32Acknowledgments ................................................ 34For Notes ............................................................... 35


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The transfer of materials and research tools is anessential aspect of scientific research. The typesof materials exchanged are varied and are utilizedin all areas of research including chemistry,biology, physics, computer science, andengineering but the vast majority of thesetransfers occur in the life sciences. Although thisbrochure will focus on transfers of biologicalmaterials, most of the concepts and issuesdiscussed are relevant to all forms of materialexchanges.

A transfer between provider and recipient mayserve to facilitate the confirmation of researchfindings or may provide a unique material tofurther a new line of investigation. The openexchange of commonplace and nonproprietarymaterials between academic scientists usuallyoccurs without risk or concern. When thematerial is of a unique or proprietary nature, theprovider may wish to preserve its control of howthe material is used and limit its furtherdistribution. This is most common when theproviding organization is a commercial, for-profitcompany.

A materials transfer agreement (MTA) is thecontractual instrument used to define the termsand conditions for the exchange of materials.While MTAs are not funding agreements, manyof the issues usually associated with a researchcontract can apply to these transfers and can havea dramatic impact on future research efforts. AnMTA typically sets forth rights to use the materials

Introduction


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and may allocate rights that result from their use.Often MTAs address such issues as publication,involvement of students, limitations on the useof the materials, and the intellectual propertyrights of the provider and the recipient in theresults of the research in which the materials areused.

Transfers from industry to academia arecomplicated due to the different objectives ofthe two parties. From the perspective of industry,no transfer can be made that will compromisethe company’s interest in a proprietary product.This may lead to MTA terms that substantiallyrestrict use of the materials and give the companyall rights to any new invention that results fromtheir use. Academia, on the other hand, cannotcompromise its objective to disseminateknowledge widely to the scientific community.Because of these differing objectives, universitiesoften need to negotiate the MTA terms to ensurethat they do not undermine the university’smission.

Given that money is rarely associated with thesetransfers, MTAs may be perceived by some to beinconsequential transactions. However, they arebinding legal agreements that can impact aresearcher’s current and future research. Thus, itis important that researchers and administratorsalike understand the issues and complexitiesinvolved in these transfers, especially given thelarge volume of MTAs that are being negotiatedin the research community. While standard MTA


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agreements (e.g., Uniform Biological MaterialTransfer Agreement (UBMTA) and the NationalInstitutes of Health’s (NIH) recommendedSimple Letter Agreement) exist, MTAs withwidely varying terms and conditions haveproliferated, particularly between universities andindustry.

We hope that that the “Twenty Questions andAnswers” format of this brochure will assist theuniversity administrator and/or the academic researcherin understanding some of the critical issues arising underthese legal agreements and promote greater standardizationof MTA terms and conditions.

University administrators and researchers shouldacquaint themselves with their institutions’policies and procedures governing materialtransfers and should obtain assistance from theappropriate university office to negotiate MTAterms and conditions. Because the MTA doesnot usually provide funding for the researchutilizing the transferred materials, the MTA oftenneeds to be reviewed jointly with any pre-existingfunding agreements in order to ensure that theterms of these agreements do not conflict withone another. NIH’s Principles and Guidelines (seeQuestion 16 for more details) provides additionalguidance to recipients of NIH funding withrespect to transferring research materials andtools.


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20Questionsand

Answers


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1 Under whatcircumstances is an

MTA needed?

The provider of material or data may feel anMTA is needed in the following circumstances:

! The material and/or information isproprietary;

! The material or information is beingmaintained as a trade secret;

! The material is infectious, hazardous orsubject to special regulations;

! The provider is concerned about potentialliability; and/or

! The provider wishes to obtain rights tothe results of the research in which thematerial or information is to be used.


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2From the Universityperspective,what MTA terms frequentlyraise problems?

Universities typically avoid terms that:

! Restrict academic freedom, such asrestrictions on publication;

! Assert excessive rights of ownership in theresearch results;

! Ask for inappropriate indemnification bythe university; and/or

! Create conflicting obligations (with othersources of funds or materials).


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How do agreement termsrestrict academic freedom?3The most problematic restriction on academic

freedom is a limitation on the ability to publishthe results of research in a timely manner. Thisis of particular significance becausedissemination of information is an integral andrequired aspect of the institution’s existence asa non-profit entity. Many agreements, especiallythose from for-profit providers, require theinvestigator to provide an advance copy of anymanuscript or proposed public disclosure ofresults obtained with the material. Generallyspeaking, this requirement is not unreasonableprovided it does not result in an excessive delay.However, more restrictive publication provisionsmay be unacceptable. For example, the providermay seek the right to approve publications, tohave unrestricted pre-publication editorial rights,or to impose excessive publication delays. Inaddition, as discussed in greater detail below,granting the provider certain ownership rightsin the results of the research may also limit therecipient’s ability to publish, to continueresearch, or to utilize the fruits of research freely.

Signing agreements with restrictions on the rightto publish or the ability to conduct futureresearch can have catastrophic effects. As anexample of the problems associated with suchrestrictions, consider the graduate orpostdoctoral student whose research project islinked with the transfer of a material receivedunder an MTA. If that MTA prevents orimpedes their ability to publish — especially a


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thesis or dissertation — or to use the researchresults to continue a line of inquiry, it maydramatically alter the course of their career. Toensure that providers cannot impose suchlimitations, universities typically have policiesthat prohibit these restrictions. Universitiesfrequently face the challenge of aligning thesepolicies with limitations that industry seeks toimpose.


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Why is there concernabout ownership

rights?4Some providers attempt to require thatrecipients and users of their materials relinquishall claims to ownership of any new materialscreated by the recipient or inventions madethrough the use of the provided materials. Thisrequirement may apply regardless of whethercreation of the new materials is dependent onthe use of the provided materials. This not onlyrepresents a loss of intellectual property rights,but also may prevent the recipient fromcontinuing a line of inquiry because he/she nolonger has the right to use his/her researchresults. Relinquishing ownership of inventionsand copyrights can have potential repercussionsbeyond the loss of the right to use researchresults. The university has a duty to ensure thebroadest possible application of its research inthe public interest. Failing to retain ownershipof intellectual property makes it unlikely thatthe university can meet this obligation. Inaddition, when federal funding is or may beinvolved, the university must ensure it can meetits obligations under the Bayh-Dole Act [PL 96-517]. For this reason MTAs must acknowledgethe rights of the federal government regardinginventions and copyrighted materials that maybe made with the material.


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What is meant by“reach-through rights”and when are theyjustified? 5Reach-through rights can mean differentthings. In exchange for the material, therecipient must:

! grant the provider licenses or optionsto improvement or modifications ofthe material or to inventions made inthe course of the research in which thematerial is used; or

! pay fees or royalties on productsdiscovered through the use of thematerial even though the material is notpart of the product or necessary tomanufacture the product.

The first example is common in transfers ofmaterial from a for-profit to a non-profit; thecompany feels it is providing something of valueand thus should get something in return. Theissue for the university is whether the rightsgranted are reasonable under the circumstances.

The second example relies on the “but for”principle — but for the use of the providedmaterials, a development would not have beenmade and thus the provider feels entitled toshare in the proceeds of the commercializationof the resulting development. In its Principlesand Guidelines regarding research tools, NIH isclear that NIH-funded research tools shouldbe provided to other non-profit entitieswithout such reach-through rights. Whentransferring NIH-funded research tools to for-profit entities for their internal research use,


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NIH encourages grantees to do so withoutseeking royalties on such “but for” products.

The NIH Principles and Guidelines offers examplesof language regarding reach-through rights thatcould be included in MTAs and in sponsoredresearch agreements with for-profit sponsors toaccomplish the intent of the Principles andGuidelines as well as to meet the spirit of theBayh-Dole Act.


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6What Are Some DesirableDefinitions of Terms inBiological MTAs?

Material: Strictly speaking, the physicalsubstance being transferred. However, providersmay seek to include other items, including otherforms of the material which may arise frommodifications of the material made in therecipient laboratory (see below: Progeny,Unmodified Derivatives, and Modifications).

Progeny: Generally defined as the descendantcopies of the material that are produced in therecipient laboratory as a result of replication(e.g., cell division, DNA copying). Theimplication is that progeny material is anessentially unchanged copy of the originallyprovided material, and thus is appropriatelyprovider-owned.

Unmodified Derivatives: Usually meansproducts of the originally transferred material(e.g., monoclonal antibodies secreted by ahybridoma cell line or parts of the originalmaterial), and these are also considered to beprovider-owned. When the term “derivatives”is used in a contract, it should be clarifiedwhether or not this term includes more thanunmodified derivatives.

Modifications: Typically means modifiedderivatives (cf.: Unmodified Derivatives) of theoriginal material (e.g., an original provider-owned DNA molecule or a fragment thereofnewly embedded in a recipient-ownedexpression vector and using a recipient-ownedpromoter). Modifications with new utility that


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include material from both the provider and therecipient may be inventions with ownershipvesting solely with the recipient or in both theprovider and the recipient as the specific factsindicate.


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7How is ownership ofcombination materialsdetermined?

Equitable ownership of combination materialsis determined in much the same way asownership of any other physical property. Forexample, the owner of the expression vectorwith unique characteristics and the owner ofthe newly-cloned gene that is to be inserted intothat vector are co-owners of the resultingengineered material. Similarly, when the ownerof a catalyst collaborates with another party toproduce a modified or specially processed formof the catalyst, joint-ownership may occur. Itis common in such situations that the servicesof an experienced patent attorney will be utilizedfor an exact determination of the relativecontributions of each party. Ownership ofinventions, as opposed to physical materials,should be determined by U.S. patent lawgoverning inventorship.


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8 Is there an option foran institution to

forego ownershiprights?

Although it is possible under limitedcircumstances to have some flexibility when itcomes to ownership of inventions andcopyrights, investigators who are supported byawards from the federal government and theirinstitutions are obligated to report inventionsunder the Bayh-Dole Act and its implementingregulations [37 CFR 401]. If title to inventionswill not be claimed by the awardee institution,the government requires sufficient notice to beable to take title itself and file patents whenwarranted [37 CFR 401.14(c) and (d)]. Moreover,a non-profit organization may not assign titleto an invention without the express approvalof the funding agency except to an organizationone of whose primary purposes is themanagement of inventions [37 CFR401.14(k)(1)]. With respect to data or softwarefirst developed with government funding, thegovernment obtains a royalty-free, non-exclusive, irrevocable, worldwide license to use,disclose, reproduce, prepare derivative works,and distribute copies for governmentalpurposes. Thus the institution cannot “giveaway” rights that it has previously agreed eitherto claim itself or grant to the federalgovernment.

Even if permitted, waiving ownership to a thirdparty may have a dramatic impact on the futureresearch of the academic researcher, since it maybe necessary for the researcher to secure alicense in order to subsequently use the


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invention or materials. In most cases theprovider’s concerns can be met through anappropriate license agreement, rather than thetransfer of ownership. It also is important torecognize that journal publishers require that theauthor(s) make the materials described in theirpublications easily and reasonably available toother researchers in order for the publishedresults to be verified. Without ownership andthe ability to make the materials available toother researchers, a researcher’s publication maynot be accepted for publication.


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9What is indemnification, andwhat is the importance of

limiting indemnificationrequirements?

Indemnification is the legal concept of assumingfinancial responsibility for certain acts and/oromissions arising under a contract. An MTAmay require that the recipient institutionindemnify the provider against any damage thatmay occur through use of the material. At aminimum, such liability should be limited to therecipient’s own actions (i.e., any damage that mayoccur through the recipient’s use of the material)and should exclude damages that result fromthe provider’s negligence or unlawful actions.State institutions may be prevented by state lawfrom even assuming this limited liability.


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10Why is it useful to useMTAs when materialsare being sent toacademic colleagues?

There are numerous issues that may beimportant to both the providing institution andthe providing scientist that are appropriatelyhandled through an MTA. Issues includingliability, academic credit, loss of control of thematerial, and access to information havedemonstrated the wisdom of using an MTAeven with academic colleagues. In addition, inthe rare instance where a dispute arises, a simpleMTA can easily resolve a large percentage ofdisagreements. Occasionally, the material maybe encumbered as the direct result of havingarisen from sponsored research or having beenexclusively licensed to another entity. An MTAis particularly important in these situations.

In any case, it is desirable that MTAs for transfersto academic colleagues be as unrestricted aspossible. The use of the UBMTA or the NIH-recommended Simple Letter Agreement ishighly recommended. For an excellentdiscussion of issues relating to data and materialssharing among researchers, see the report of theNational Research Council of the NationalAcademies on the “Sharing of Publication-related Data and Materials” athttp://www.nap.edu/catalog/10613.html.


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11Can MTA agreementsbe expedited through

standardization?

Some progress has been made instandardization. NIH, working with universityrepresentatives, developed the UBMTA andSimple Letter Agreement, both of which aresuitable for transfers of materials among NIH-funded researchers and more generally fortransfers between academic institutions. Overtwo hundred research institutions aresignatories to the UBMTA and are able toexecute material transfers with a simpleimplementing letter.

The UMBTA and the Simple LetterAgreement may not be appropriate when thematerial was made in an academic projectsupported by industry. In such cases, theremay be obligations to the industry sponsorthat are incompatible with those agreements.Unfortunately, standardization is unlikely forMTAs transferring materials from industry toacademia since no one format is likely toaddress each company’s vastly different policies,procedures, valuations, and objectives.


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12Who has theauthority to signMTA agreements?

All agreements that bind the university, includingMTAs, must be signed by an officer of theinstitution having signatory authority.Agreements that are not signed by an authorizedinstitutional official may not be valid and maymake the signor personally responsible for anybreach of the terms and obligations of theMTA. Additionally, since the researcher utilizingthe materials is responsible for fulfilling mostof the obligations under an MTA, it isrecommended that he or she also sign theagreement, not necessarily as a party to theagreement, but as an acknowledgement of hisor her duties under the agreement.


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13 Are MTAagreements ever

enforced?

In the vast majority of transactions, the termsof the MTA will not need to be revisited andare merely the mechanism for obtaining theneeded material. However, in those cases wherea dispute arises or when the stakes are high, theterms of an MTA may be the subject oflitigation. Even if no litigation occurs, the termsof the MTA will assist in adjudicating the disputeand properly apportioning credit and blame.


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14Is it reasonableto charge fees forthe transfer of thematerial?

While the majority of material transfers occurwithout any associated fees, some MTAs doinclude a nominal charge to the recipient. Thisfee is generally calculated to offset the costsincurred by the provider in preparing andshipping the material (or animal) and mayinclude, for example, the cost of materials, theextra labor required to make the material, andshipping and handling.


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15Are there other meansof getting materials

when the obstacle istime and effort?

There are two ways to handle a time and effortproblem, neither involving an MTA:

! The materials may be suitable fordeposit in a publicly-supported or user-fee-supported facility. For example,some cell lines may be accepted formaintenance and distribution by theAmerican Type Culture Collection; or

! The right to make and distribute thematerials at nominal cost may belicensed to a company that sells reagentsto the research community. In thisinstance, the company becomes theprovider, thus alleviating the researcherfrom the task of distribution.


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16What are theimplications of NIH’s“Principles andGuidelines...”?

The “Principles and Guidelines for Recipients of NIHResearch Grants and Contracts on Obtaining andDisseminating Biomedical Research Resources” definesexpectations for NIH-funded recipients whenexchanging biomedical research materials andtools; they are available at http://ott.od.nih.gov/NewPages/RTguide_final.html. Althoughoriginally issued as guidelines, they are now acondition of funding and arguably rise to thelevel of a contractual obligation. Under thePrinciples and Guidelines, scientists and institutionsare expected to broadly disseminate tools thatarise from NIH-funded research with as fewencumbrances as possible. The Principles andGuidelines recognizes the difficult balancebetween NIH funding recipients’ rights todisclose and publish their research findings, theright of the scientific community and public atlarge to access and share the research results,the right of providers to preserve proprietaryrights to research tools, and the right ofrecipients to retain title to inventions made withNIH funds while assuring their utilization andcommercialization for public benefit. ThePrinciples and Guidelines implies a high level ofdiligence on the part of institutional officialsboth to educate and advise faculty and managethe process of disseminating and importingresearch tools. Institutions must carefullyoversee interactions (such as industry-sponsoredresearch agreements and exclusive licenses) thathave the potential to restrict sharing and therebycontradict the Principles and Guidelines. It is also


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worth noting that on May 28, 2003, the NIHpublished a draft policy on the sharing anddistribution of mouse resources. The draftpolicy can be found at http://www.nih.gov/science/models/mouse/sharing/index.html. Itencourages the timely sharing of mouseresources between researchers.


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17Are there specialrequirements fortransferring humanembryonic stem cells?

On August 9, 2001, President George W. Bushannounced that federal funds may be used inresearch utilizing certain human embryonic stem(hES) cell lines, provided the cell lines areapproved and meet certain established criteria.NIH created a Human Embryonic Stem CellRegistry that lists those stem cell lines meetingthese eligibility criteria. As this is a recent andevolving topic, readers are advised to consultthe NIH website http://www.nih.gov/news/stemcell/index.htm to obtain information aboutacquiring cells and the current policies andrequirements.

NIH has negotiated materials transferagreements for its intramural investigators withsome hES cell providers. Academicinvestigators must arrange access to the hEScells directly through the supplying company orlaboratory. NIH has asked approved hES cellproviders to make cells available in accordancewith the NIH Principles and Guidelines, and NIHrecipients are advised to consider theseguidelines when acquiring cells. NIH regulationson research with hES cells when utilizing federalfunds can be found in the NIH Guidelines forResearch Using Human Pluripotent Stem Cellsht tp ://www.n ih .g ov/news/s temce l l/stemcellguidelines.htm.


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18 Are there specialrequirements for

transferring “special”biological material?

Yes. For example, the Convention on BiologicalDiversity of 1992 is principally concerned withthe conservation of diverse ecological systems.However, it also contains certain provisionsrelating to the commercialization of geneticmaterials obtained from developing countries.This is an area that is still evolving, and not manyinstitutions or countries have either experienceor mechanisms in place to handle sucharrangements. Researchers should call on theresources of their technology transfer offices,and for the immediate future, it will probablybe useful to have the technology transferprofessionals consult experienced colleagues forassistance in this area.

Additionally, the importation of some biologicalmaterials into the U.S. requires USDA permits.If the proper documentation does notaccompany packages, the materials may bequarantined or otherwise delayed, and they maysuffer damage in the process. It is better todetermine early whether permits will be needed.USDA forms, if needed, are available on-line at<http://www.aphis.usda.gov/forms>. It alsomay be helpful for the researcher to consult theuniversity’s biosafety office for advice. See alsothe discussion below regarding laws andregulations governing exports and the transferof hazardous biological materials.


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Under U.S. export control laws, automaticlicenses can apply to most biological materials.In some cases, however, a license may berequired from the Bureau of ExportAdministration of the Department ofCommerce or from the U.S. Department ofState. There are, for instance, controls on theexport of materials that could possibly be usedin chemical or biological weapons. Examplesgiven of such materials include humanpathogens, zoonoses, toxins, animal pathogens,genetically modified microorganisms and plantpathogens. The Export AdministrationRegulations (EAR) administered by theCommerce Department are at 15 CFR Parts 768-799. The section covering the scope of materialscovered is 15 CFR Part 742 Supplement No. 1(12).The International Traffic in Arms Regulationsadministered by the State Department are at 22CFR Parts 120-130. The list of regulated itemsis in 22 CFR Part 121. An investigator planningto transfer materials which are controlled by theEAR or the ITAR outside the United Statesshould work with the appropriate institutionalstaff person to obtain the required license. Thereare civil and criminal penalties for violating eitherthe EAR or ITAR. Please also note that somehighly hazardous biological materials mayrequire multiple permits (e.g., for export fromthe U.S., and for import into another country).

19Is an export licenseneeded to transfermaterials outsidethe United States?


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20Are there specialregulations regarding the

transfer of toxicbiological agents?

Yes, there are laws and regulations coveringpossession, use, and transfer of certain biologicalagents and toxins that have the potential to posea severe threat to public health and safety.Agents that pose a threat to human health (theso-called select agents) were initially regulatedby the federal government in the Antiterrorismand Effective Death Penalty Act of 1996 [PL104-132], which placed restrictions on thetransfer of these agents and imposed record-keeping requirements on institutions thatshipped or received them. The USA PATRIOTAct of 2001 [PL 107-156] restricted certaincategories of individuals from possessing selectagents and imposed criminal penalties. ThePublic Health Security and BioterrorismResponse Act of 2002 [PL 107-188] expandedthese laws to include biological agents and toxinsthat affect plants and animals and regulatedentities such as universities that use the listedagents in research.

The Centers for Disease Control and Prevention(CDC) of the U. S. Department of Health andHuman Services and the Animal and PlantHealth Inspection Service (APHIS) of the U.S.Department of Agriculture have issued InterimFinal Rules governing the possession, use, andtransfer of the listed biological agents and toxinsto implement these laws. The effective datefor the rules was February 7, 2003, although forinstitutions who were lawfully working with theselect agents prior to that time, certain


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provisions and requirements are phased in, withfull compliance for both rules required byNovember 12, 2003. Both the CDC and APHISwebsites include a set of Questions andAnswers, which are amended periodically torespond to questions and comments about theInterim Rules from the research community.The rules are extensive and significant, and,among other things, require registrationcertificates for entities; background checks forresponsible university officials, investigators, andothers who have access to the listed agents; andsecurity plans, training, and substantial record-keeping. Upon full implementation inNovember, 2003, these rules will supersede theprevious regulations controlling transfer of theselect agents. Transfer of the so-called overlapagents, those that are both human and animalpathogens, appear to require both notificationof CDC and an APHIS permit. The COGRwebsite will be periodically updated withinformation about the implementation of andissues arising under these new regulations.


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For the preparation of this brochure, COGRgives credit and thanks to the members of theCOGR Contracts and Intellectual Property(CIP) Committee: Jilda Garton, GeorgiaInstitute of Technology, Chair; Erica Kropp,University of Maryland; Ann Hammersla,Massachusetts Institute of Technology; JosephAcanfora, University of California; AndrewNeighbour, University of California at LosAngeles; Marvin Parnes, University ofMichigan; James Severson, University ofWashington; and Robert Hardy, COGR.

In particular, COGR gratefully acknowledgesthe contributions of CIP member John Ritter,Princeton University, who led the effort torevise this brochure, and former members CarlaFishman of Tulane University and JoyceBrinton of Harvard University, who served asreviewers.

Acknowledgments


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For Notes

Council on Governmental Relations1200 New York Avenue, Suite 320

Washington, DC 2005(202) 289-6655

www.cogr.edu

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