In response to the questions posed in this scenario, the Office of Laboratory Animal Welfare (OLAW) offers the following clarification and guidance:

This month's scenario describes unusual animal use in a nontraditional research setting. The National Institute of Mental Health is a component of the National Institutes of Health (NIH), a Public Health Service (PHS) agency. As was stated by some of the reviewers this is, by definition, a PHS-supported activity involving live vertebrate animals; therefore, as a condition of funding, the awardee institution and all performance sites must be covered under one or more Assurances on file with OLAW and verification of IACUC approval must be submitted prior to award. The IACUC review criteria and oversight requirements should be specially tailored to address those practical issues (e.g., health and welfare of animals and humans involved) already raised in the responses above.

The scenario also mentions, as a proposed analogy for consideration of the issues involved in the dog study, the practice of feeding live mice to snakes. It should be noted that in situations where the PHS Policy is applicable, the feeding of live vertebrate animals to other animals is also subject to IACUC oversight either as a part of the protocol review process or as a covered component of the institutional program of animal care and use.