The AAMC recently submitted comments to the Department of Defense on proposed amendments to the Defense Federal Acquisition Regulation Supplement that address requirements for preventing unauthorized disclosure of export-controlled technology and information under DOD contracts. The proposed amendments represent an improvement over the version originally proposed in 2005 and include many suggestions that were made during the first comment period by AAMC and other organizations from the university and biomedical community. However, problems persist in the newly proposed amendments, especially: the treatment of fundamental research; the method of deciding whether export-controlled information or technology is involved in particular research and development contracts; and the absence of specific provisions for challenging contract officer determinations, and for contractor-initiated contract termination.

For more information, please visit http://www.aamc.org/advocacy/library/research/corres/2006/101306.pdf.