Treatment Action Group (TAG) is an independent, activist and community-based research and policy think tank fighting for better treatment, prevention, a vaccine, and a cure for HIV, tuberculosis, and hepatitis C virus. TAG works to ensure that all people with HIV, TB, and HCV receive lifesaving treatment, care, and information. We are science-based treatment activists working to expand and accelerate vital research and effective community engagement with research and policy institutions.

TAG opposes the DCR reorganization until the public is provided with sufficient information about the proposed changes to comment on the potential implications. The flaws in the process are simply demonstrated:

• On August 31, 2026, a Federal Register notice was issued with vague language stating that “comments regarding this proposed reorganization are best assured of having their full effect if received from September 14th, 2026 – September 18th, 2026.” The NIAID website page cited in the notice contained no information on the proposed DCR changes until just before it was opened for public comment on September 9th. At that point a very brief description of the reorganization and revised organizational chart was added, with no details regarding whether or how the changes might affect extant or recompeted NIAID-supported clinical trial networks, including the HIV trial networks. The fate of any public comments submitted between September 9 and the supposed “full effect” period of September 14-18, 2026 has not been specified, and thus is unknown.
• The next day, September 1, 2026, another Federal Register notice stated that the reorganization of the DCR was being added to the agenda of the NIAID Council meeting on September 23, a section of which is open to the public and streamed on the National Institutes of Health videocast website. This should be an opportunity for the public to learn more about the specifics of the changes, but it’s occurring five days after the public comment period has ended.

This approach bears no resemblance to a process intended to seek genuine, informed public comment. Instead it smacks of deliberate abuse of bureaucratic processes intended to ensure the proposed changes are forced through. 

NIAID needs to issue a detailed description of the proposed changes to DCR, including information on staff movements and changes to current reporting lines for investigators conducting NIAID-supported clinical research. The opportunity to comment should be reopened after this information is provided to the public, and the reorganization delayed until this has occurred.

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