January 26, 2026

Americans for Medical Progress (AMP) submitted formal comments to the National Institutes of Health (NIH) regarding its proposed reorganization of the Division of Program Coordination, Planning, and Strategic Initiatives (DPCPSI), including the establishment of the Office of Research Innovation, Validation, and Application (ORIVA).

In our comments, AMP expressed support for NIH’s efforts to strengthen scientific innovation and regulatory translation, while emphasizing the need for a balanced, evidence-based research ecosystem that integrates New Approach Methodologies (NAMs) alongside essential animal models. AMP offered several recommendations to help ensure ORIVA’s long-term effectiveness, scientific credibility, and public trust.

AMP’s Key Recommendations

1. Adopt a standardized definition of NAMs grounded in the full 3Rs (Replace, Reduce, Refine), not replacement alone.
2. Establish a third ORIVA division dedicated to scientific integration across NAMs and animal models.
3. Ensure ORIVA staffing reflects the full range of scientific and veterinary expertise necessary for implementation.
4. Strengthen stakeholder communication while setting realistic expectations about scientific readiness and limitations.

A PDF copy of AMP’s comments is available here.