THROMBOCYTOPENIA: PATHOGENESIS AND TREATMENT NIH GUIDE, Volume 26, Number 37, November 7, 1997 RFA: HL-98-001 National Heart, Lung, and Blood Institute P.T. Letter of Intent Receipt Date: January 29, 1998 Application Receipt Date: March 12, 1998 THIS RFA USES "MODULAR GRANT" AND "JUST-IN-TIME" CONCEPTS. THIS RFA INCLUDES DETAILED MODIFICATIONS TO STANDARD APPLICATION INSTRUCTIONS THAT MUST BE USED WHEN PREPARING RESPONSES TO THIS RFA. PURPOSE The purpose of this initiative is to improve the understanding of the pathogenesis of thrombocytopenia in general and HIV-related thrombocytopenia in particular. The long term goal of the initiative is to develop better therapeutic approaches for these conditions. HEALTHY PEOPLE 2000 The Public Health Service (PHS) is committed to achieving the health promotion and disease prevention objectives of "Healthy People 2000", a PHS-led national activity for setting priority areas. This RFA, Thrombocytopenia: Pathogenesis and Treatment, is related to the priority areas of HIV infection, and heart diseases and stroke. Potential applicants may obtain a copy of "Healthy People 2000" (Full Report: Stock No. 017-001-00474-0 or Summary Report: Stock No. 017-001-00473-1) through the Superintendent of Documents, Government Printing Office, Washington, DC 20402-9325 (telephone 202-512-1800). ELIGIBILITY REQUIREMENTS Applications may be submitted by domestic and foreign for-profit and non-profit organizations, public and private, such as universities, colleges, hospitals, laboratories, units of state or local governments, and eligible agencies of the federal government. Awards in response to this RFA will be made to foreign institutions only for research of very unusual merit, need, and promise, and in accordance with PHS policy governing such awards. Minority individuals and women are encouraged to apply. MECHANISM OF SUPPORT This RFA will use the NIH individual research project grant (R01) mechanism of support. Newly independent investigators who may wish to consult with a program representative (see "INQUIRIES" section) are encouraged to apply. Specific application instructions have been modified to reflect "MODULAR GRANT" and "JUST-IN-TIME" streamlining efforts being examined by the NIH. The MODULAR GRANT concept establishes specific modules in which direct costs may be requested as well as a maximum level for requested budgets. Only limited budgetary information is required under this approach. The JUST-IN-TIME concept allows applicants to submit certain information only when there is a possibility for an award. It is anticipated that these changes will reduce the administrative burden for the applicants, reviewers, and Institute staff. For this RFA, funds must be requested in $25,000 direct cost modules and a maximum of eight modules ($200,000 direct costs) per year may be requested. Any necessary escalation must be included within the number of modules being requested. Only limited budget information will be required and any budget adjustments made by the Initial Review Group will be in modules of $25,000. Instructions for completing the Biographical Sketch have also been modified. In addition, Other Support information and the application Checklist page are not required as part of the initial application. If there is a possibility for an award, necessary budget, Other Support and Checklist information will be requested by NHLBI staff following the initial review. The APPLICATION PROCEDURES section of this RFA provides specific details of modifications to standard PHS 398 application kit instructions. Applicants, who will plan and execute their own research programs, are requested to furnish their own estimates of the time required to achieve the objectives of the proposed research project. Up to 5 years of support may be requested. At the end of the official award period, renewal applications may be submitted for peer review and competition for support through the regular grant program of the NHLBI. It is anticipated that support for the present program will begin September 1998. Administrative adjustments in project period or amount of support may be required at the time of the award. Since a variety of approaches would represent valid responses to this announcement, it is anticipated that there will be a range of costs among individual grants awarded. All current policies and requirements that govern the research grant programs of the NIH will apply to grants awarded in connection with this RFA. FUNDS AVAILABLE It is anticipated that for fiscal year 1998, $2,000,000 total costs will be available for the first year of support for this initiative. The award of grants pursuant to this RFA is contingent upon receipt of such funds for this purpose. It is anticipated that approximately eight new grants will be awarded under this program. However, the specific number of awards will depend on the merit and scope of the applications received and on the availability of funds. Applicants may request up to five years of support. Direct costs will be awarded in modules of $25,000, less any overlap or other necessary administrative adjustments. Indirect costs will be awarded based on the negotiated rates. If collaborative arrangements involve subcontracts with other institutions, Ms. Jane R. Davis of the NHLBI Grants Operations Branch (telephone: (301-435-0166) should be consulted regarding procedures to be followed. RESEARCH OBJECTIVES Background Idiopathic (autoimmune) thrombocytopenic purpura (ITP) is a common disorder of immune regulation. The prevalence of chronic ITP is estimated to be 1 in 10,000 and it is seen more commonly in women than in men in about a 3:1 ratio. Autoantibodies (7S, IgG) are usually formed against platelets, and probably megakaryocytes, leading to the destruction of these cells. The resultant thrombocytopenia induces purpura and sometimes hemorrhage. Thrombocytopenia is frequently seen in individuals infected with the human immunodeficiency virus (HIV) and appears to be multifactorial in etiology. The virus may directly infect megakaryocytes and impair thrombopoiesis. On the other hand, numerous studies have clearly demonstrated the presence of platelet-reactive antibodies. Two developments make this initiative timely. Firstly, the discovery of thrombopoietin (TPO) has dramatically changed our understanding of thrombopoiesis. Secondly, there has been considerable progress in basic immunology and particularly autoimmunity. The expert recommendations of immunologists and hematologists that emerged from a Workshop on Autoimmune (Idiopathic) Thrombocytopenic Purpura: Pathogenesis and New Approaches to Therapy are included in this initiative. ITP affects children and adults of all ages. In childhood, ITP is often preceded by a viral infection or vaccination. The disorder is usually self-limited, and spontaneous recovery occurs in a few weeks to several months. The sex ratio in acute ITP is 1:1. However, about 10% of the cases become chronic. In contrast, the onset of ITP in adults is often more insidious. Autoantibodies are usually formed against platelets and megakaryocytes, leading to phagocytic destruction of these cells. The resultant thrombocytopenia induces purpura and hemorrhage if the platelet count reaches a critical level. In pregnant women, the antibody may cross the placenta with resultant neonatal thrombocytopenia which may have serious consequences. Platelet levels temporarily rise after corticosteroid therapy, but most patients eventually undergo splenectomy. The operation leads to normalization of the platelet counts in 80% to 90% of younger patients and perhaps 50% to 60% of patients over the age of 50 years, but relapses sometimes occur many years later. Some patients have been followed with chronic ITP for more than 30 years. The platelet count in these patients remains around one-third to one-half of normal value but may drop precipitously after a viral infection or in reaction to certain drugs. Thrombocytopenia is common in patients infected with HIV. In one study, 9% of HIV-positive drug abusers and 3% of HIV-positive homosexuals had platelet counts of lower than 100,000/ul while no seronegative drug abusers or homosexuals were thrombocytopenic. Thrombocytopenia in these patients seems to correlate with the CD4 lymphocyte count. The pathogenesis of thrombocytopenia in HIV- positive individuals is not well understood. There is evidence for both increased platelet destruction and decreased platelet production, and it is possible that either or both of these mechanisms may play a role in individual patients. Several studies have demonstrated the presence of platelet-reactive autoantibodies on platelets and in plasma of affected individuals. While HIV-positive individuals may produce antibodies to platelet antigens similar to chronic ITP patients, some intriguing differences between conventional and HIV-associated thrombocytopenias have been noted. One group reported that in thrombocytopenia associated with HIV infection, the autoantibodies recognize platelet membrane proteins distinct from the glycoprotein IIb/IIIa complex, the preferred target for antibodies in most cases of conventional ITP. Platelet associated IgG and C3 values are both elevated in thrombocytopenic HIV positive individuals compared to HIV negative patients. Circulating immune complexes can be demonstrated in the serum of most patients with HIV-related thrombocytopenia and these complexes, when purified, are capable of binding to platelets. One group of investigators feels that the immune complexes are made up of antibodies to HIV proteins and its anti-idiotype and could not demonstrate the presence of HIV proteins in the complex. Others reported that these autoantibodies recognize epitopes on the HIV proteins p24, GP120 and GP160. One group has implicated mixed immune complexes containing antibodies reactive with platelet GPIIIa and HIV-1 proteins as well as IgM rheumatoid factor in the pathogenesis of the thrombocytopenia. Patients with HIV infection have profound immunodeficiency which could lead to immunomodulation defects and may lead to the formation of autoantibodies. There is also the possibility of immune thrombocytopenia due to antibodies triggered by drugs used in their treatment. Platelets are produced from bone marrow megakaryocytes and arise from the fragmentation of the cytoplasm. More than three decades ago it was reported that a humoral factor present in the plasma of patients with severe thrombocytopenia increased the platelet count when injected into animals. This regulator was named thrombopoietin. Thrombopoietin (TPO) was isolated and characterized about three years ago and significant progress in our understanding of thrombopoiesis has been made since then. It is now clear that TPO is the main regulator of megakaryocyte development and platelet production. In spite of this impressive progress, the synthesis, regulation, and signaling mechanisms of TPO remain unclear. Its plasma levels in the normal state and different thrombocytopenic states, its mode of action, and its clearance mechanisms need to be defined. A better understanding of the cell and molecular biology of TPO could help to guide its clinical application for the treatment of thrombocytopenia. There is also evidence to support reduced platelet production in HIV-associated thrombocytopenia. Platelet turnover studies show decreased production in untreated HIV-positive patients with thrombocytopenia; platelet production improves when they are treated with zidovudine. Megakaryocytes are known to express the CD4 antigen, and megakaryocytes from HIV-infected individuals have been shown to express viral RNA. In addition, there is reduced in vitro growth of hemopoietic progenitor cells from HIV-infected patients, including CFU-megakaryocytes. Finally, common antigens on platelets and megakaryocytes have been identified. It is possible that antibody-mediated impairment of thrombopoiesis has a role in ITP. It is clear that the pathogenesis of thrombocytopenia with or without associated HIV infection is poorly understood. The thrombocytopenia observed may be due to the effect of viral infection on megakaryocytes and platelets, or the immunodeficient state may permit the formation of antibodies to platelets. These antibodies may be similar to those observed in chronic ITP or may have distinct properties associated with HIV infection. Studies are needed to characterize the basic pathophysiology of the autoimmune response to platelets in ITP more fully and to apply this knowledge to improve the diagnosis and treatment of this condition. Thrombocytopenia associated with HIV has been treated in various ways. There are small studies supporting the use of zidovudine, prednisone, splenectomy, intravenous gammaglobulin, staphylococcal protein A column, splenic irradiation, interferon, and anti-Rh(D) antibody. There is a need to evaluate these various therapies. Autoimmune thrombocytopenia may be considered the prototype of an autoimmune disease indicated by a humoral response and the findings of this study could be relevant to a number of other autoimmune conditions. A clear intent of this initiative is to attract high level expertise in the field of autoimmunity to the study of ITP in general and HIV-thrombocytopenia in particular. Examples of Research Areas The following are examples of areas of research related to thrombocytopenia that may be supported under this program. Applicants are encouraged to propose additional areas within the context of this special initiative. o Studies utilizing the modern concepts of immunobiology to develop a better understanding of the pathogenesis of ITP and HIV thrombocytopenia, and their treatments. For example, defining the defect in immunoregulation that leads to inappropriate antibody production, exogenous and endogenous triggers (viruses, drugs, environment, genetic factors) that precipitate the disease, identification of biologically relevant platelet component and specific epitopes, defining the apparent subgroups of ITP e.g. refractory vs. non-refractory, responders vs non-responders to splenectomy. o Studies in HIV - thrombocytopenia determining the frequency of true autoantibodies in patients of different causes (e.g. drug abuse, sexual transmission, etc.), molecular mimicry for anti- platelet antibody, role of immune complexes, involvement of anti- idiotype antibodies and the etiology of antibody production. o Develop an animal model of ITP to study autoimmune pathogenesis and the characteristics of the antibodies. o Studies evaluating thrombokinetics in thrombocytopenia and determining how platelet production may be suppressed in some patients. These might address the levels and effects of appropriate growth factors on platelet production, e.g. TPO. o Develop more sensitive and specific diagnostic methods to better characterize the antibodies responsible for platelet destruction (target epitopes, idiotypic properties, classes and subclasses). Can in vitro tests distinguish between acute and chronic forms, HIV and non-HIV ITP and predict the response to treatment? o Study the mechanism of action of IV gamma globulin which may lead to the development of more specific products for the treatment of ITP and HIV-thrombocytopenia. Evaluate or develop, in limited cooperative studies when necessary, the best forms of treatment in HIV or non-HIV thrombocytopenia, especially those who have exhausted available therapeutic options. Large clinical trials on thrombocytopenia will not be supported under this initiative. SPECIAL REQUIREMENTS Upon initiation of the program, the NHLBI may sponsor annual meetings to encourage the exchange of information among investigators who participate in this program. Travel funds for a one day meeting each year, most likely to be held in Bethesda, Maryland, should be included in the modules. Applicants should also include a statement in the applications indicating their willingness to participate in such meetings. INCLUSION OF WOMEN AND MINORITIES IN RESEARCH INVOLVING HUMAN SUBJECTS It is the policy of the NIH that women and members of minority groups and their subpopulations must be included in all NIH supported biomedical and behavioral research projects involving human subjects, unless a clear and compelling rationale and justification is provided that inclusion is inappropriate with respect to the health of the subjects or the purpose of research. This policy results from the NIH Revitalization Act of 1993 (Section 492B of Public Law 103-43). All investigators proposing research involving human subjects should read the "NIH Guidelines for Inclusion of Women and Minorities as Subjects in Clinical Research", which have been published in the Federal Register of March 28, 1994 (FR 59 14508-14513), and reprinted in the NIH GUIDE FOR GRANTS AND CONTRACTS of March 18, 1994, Volume 23, Number 11. Investigators may obtain copies from these sources or from the program staff or contact person listed under INQUIRIES. Program staff may also provide additional relevant information concerning the policy. LETTER OF INTENT Prospective applicants are asked to submit, by January 29, 1998, a letter of intent that includes a descriptive title of the proposed research, the name, address, and telephone number of the Principal Investigator, identification of any other key personnel or participating institutions; and the number and title of the RFA in response to which the application may be submitted. Such letters are requested only for the purpose of providing an indication of the number and scope of applications to be received; therefore, their receipt is usually not acknowledged. A letter of intent is not binding, and it will not enter into the review of any application subsequently submitted, nor is it a necessary requirement for the application. A faxed letter of intent may be used in place of a posted one. This letter of intent is to be sent to: Dr. C. James Scheirer Division of Extramural Affairs National Heart, Lung, and Blood Institute 6701 Rockledge Drive, MSC 7924 Bethesda, MD 20892-7924 Telephone: (301) 435-0266 FAX: (301) 480-3541 Email: [email protected] APPLICATION PROCEDURES Applications are to be submitted on the research grant application form, PHS 398 (rev. 5/95). Applications kits are available at most institutional offices of sponsored research and may be obtained from the Division of Extramural Outreach and Information Resources, National Institutes of Health, 6701 Rockledge Drive, MSC 7910, Bethesda, MD 20892-7910, telephone 301/710-0267, email: [email protected]. Use the conventional format for research grant applications and ensure that the points identified in the section on REVIEW CONSIDERATIONS are fulfilled. BUDGET INSTRUCTIONS The total direct costs must be requested in accordance with the program guidelines and the modifications made to the standard PHS 398 application instructions described below: o FACE PAGE As a reminder, Item 7 should be completed to indicate Modular Direct Costs requested and Item 8 should reflect Total Costs (Modular Direct plus F & A costs). o DETAILED BUDGET FOR THE INITIAL BUDGET PERIOD Do not complete Form Page 4 of the PHS 398 (rev 5/95). It is not required nor will it be accepted at the time of application. o BUDGET FOR THE ENTIRE PROPOSED PERIOD OF SUPPORT Do not complete the categorical budget tables on Form page 5 of the PHS 398 (rev. 5/95). Only the requested total direct costs line for each year must be completed based on the number of $25,000 modules being requested. Applicants may not request a change in the amount of each module. A maximum of eight modules ($200,000) direct costs per year may be requested and each applicant may request up to five years of support for this RFA. Direct cost budgets will remain constant throughout the life of the project (i.e. the same number of modules requested for all budget periods). Any necessary escalation should be considered when determining the number of modules to be requested. However, in the event that the number of modules requested must change in any future year due to the nature of the research proposed, appropriate justification must be provided. Total Direct Costs for the entire Proposed Project Period should be shown in the box provided. o BUDGET JUSTIFICATION - Budget justifications should be provided under "Justifications" on Form Page 5 of the PHS 398. - List the names, role on the project and proposed percent effort for all project personnel (salaried or unsalaried) and provide a narrative justification for each person based on his/her role on the project. - Identify all consultants by name and organizational affiliation and describe the services to be performed. - Provide a general narrative justification for individual categories (equipment, supplies, etc.) required to complete the work proposed. More detailed justifications should be provided for high cost items. Any large one-time purchases, such as large equipment requests, must be accommodated within these limits. No specific costs for items or categories should be shown. o CONSORTIUM/CONTRACTUAL COSTS - If collaborations or subcontracts are involved that require transfer of funds from the grantee to other institutions, it is necessary to establish formal subcontract agreements with each collaborating institution. A letter of intent from each collaborating institution should be submitted with the application. Only the percentage of the consortium/contractual TOTAL COSTS (direct and indirect) relative to the total DIRECT COSTS of the overall project needs to be stated at this time. The following example should be used to indicate the percentage cost of the consortium, "The consortium agreement represents 27% of overall $175,000 direct costs requested in the first year.". A budget justification for the consortium should be provided as described in the "Budget Justification" section above (no Form Page 5 required for the consortium). Please indicate whether the consortium will be in place for the entire project period and identify any future year changes in the percentage relative to the parent grant. If there is a possibility for an award, the applicant will be requested to identify actual direct and indirect costs for all years of the consortium. Please note that total subcontract costs need not be calculated in $25,000 modules. However, when subcontract funds are added to the parent grant budget, the total direct cost amount must be included in the number of $25,000 modules requested. o BIOGRAPHICAL SKETCH - A biographical sketch is required for all key personnel, following the modified instructions below. Do not exceed the two-page limit for each person. - Complete the educational block at the top of the form page; - List current position(s) and those previous positions directly relevant to the application; - List selected peer-reviewed publications directly relevant to the proposed project, with full citation; - The applicant has the option to provide information on research projects completed and/or research grants participated in during the last five years that are relevant to the proposed project. o OTHER SUPPORT - Do not complete the "Other Support" pages (Form Page 7). Selected other support information relevant to the proposed research may be included in the Biographical Sketch as indicated above. Complete Other Support information will be requested by NHLBI staff if there is a possibility for an award. o CHECKLIST - No "Checklist" page is required as part of the initial application. A completed Checklist will be requested by NHLBI staff if there is a possibility for an award. The applicant should provide the name and phone number of the individual to contact concerning fiscal and administrative issues if additional information is necessary following the initial review. Sample budgets and justification page will be provided upon request. Applications not conforming to these guidelines will be considered unresponsive to this RFA and will be returned without further review. Applicants from institutions that have a General Clinical Research Center (GCRC) funded by the NIH National Center for Research Resources may wish to identify the GCRC as a resource for conducting the proposed research. If so, a letter of agreement from either the GCRC program director or principal investigator could be included with the application. The RFA label available in the PHS 398 application kit must be affixed to the bottom of the face page of the original copy of the application. Failure to use this label could result in delayed processing of the application such that it may not reach the review committee in time for review. In addition, the RFA title and number must be typed on line 2a of the face page of the application form and the YES box must be marked. Send or deliver the completed application and three signed, exact photocopies of it to the following, making sure that the original application with the RFA label attached is on top: CENTER FOR SCIENTIFIC REVIEW (formerly Division of Research Grants) NATIONAL INSTITUTES OF HEALTH 6701 ROCKLEDGE DRIVE, ROOM 1040 - MSC 7710 BETHESDA, MD 20892-7710 BETHESDA, MD 20817 (for courier/overnight mail service) Send an additional two copies of the application to the Chief, Review Branch at the address listed under LETTER OF INTENT. It is important to send these two copies at the same time as the original and three copies are sent to the Center for Scientific Review. Otherwise the NHLBI cannot guarantee that the application will be reviewed in competition for this RFA. Applications must be received by March 12, 1998. If an application is received after that date, it will be returned to the applicant without review. The Center for Scientific Review (CSR) will not accept any application in response to this RFA that is essentially the same as one currently pending initial review, unless the applicant withdraws the pending application. The CSR will not accept any application that is essentially the same as one already reviewed. This does not preclude the submission of substantial revisions of applications already reviewed, but such applications must include an introduction addressing the previous critique. REVIEW CONSIDERATIONS Upon receipt, applications will be reviewed for completeness by the CSR and responsiveness by the NHLBI. Incomplete applications will be returned to the applicant without further consideration. If NHLBI staff determines that the application is not responsive to the RFA, it will be returned to the applicant without further consideration. Applications that are complete and responsive to the RFA will be evaluated for scientific and technical merit by an appropriate peer review group convened by the NHLBI in accordance with the review criteria stated below. As part of the initial merit review, a process may be used by the initial review group in which applications will be determined to be competitive or non- competitive based on their scientific merit relative to other applications received in response to the RFA. Applications judged to be competitive will be discussed and be assigned a priority score. Applications determined to be non-competitive will be withdrawn from further consideration and the principal investigator/program director and the official signing for the applicant organization will be notified. Review Criteria The goals of NIH-supported research are to advance our understanding of biological systems, improve the control of disease, and enhance health. In the written review, comments on the following aspects of the application will be made in order to judge the likelihood that the proposed research will have a substantial impact on the pursuit of these goals. Each of these criteria will be addressed and considered in the assignment of the overall score. (1) Significance Does this study address an important problem? If the aims of the application are achieved, how will scientific knowledge be advanced? What will be the effect of these studies on the concepts or methods that drive this field? (2) Approach Are the conceptual framework, design, methods, and analyses adequately developed, well-integrated, and appropriate to the aims of the project? Does the applicant acknowledge potential problem areas and consider alternative tactics? (3) Innovation Does the project employ novel concepts, approaches or method? Are the aims original and innovative? Does the project challenge existing paradigms or develop new methodologies or technologies? (4) Investigator Is the investigator appropriately trained and well suited to carry out this work? Is the work proposed appropriate to the experience level of the principal investigator and other researchers (if any)? (5) Environment Does the scientific environment in which the work will be done contribute to the probability of success? Do the proposed experiments take advantage of unique features of the scientific environment or employ useful collaborative arrangements? Is there evidence of institutional support? In addition, the adequacy of plans to include both genders and minorities and their subgroups as appropriate for the scientific goals of the research will be reviewed. Plans for the recruitment and retention of subjects will also be evaluated. The initial review group will also examine the provisions for the protection of human and animal subjects, the safety of the research environment, and conformance with the NIH Guidelines for the Inclusion of Women and Minorities as Subjects in Clinical Research. The initial review group will also examine the provisions for the protection of human and animal subjects and the safety of the research environment. The personnel category will be reviewed for appropriate staffing based on the requested percent effort. The direct costs budget request will be reviewed for consistency with the proposed methods and specific aims. Any budgetary adjustments recommended by the reviewers will be in $25,000 modules. The duration of support will be reviewed to determine if it is appropriate to ensure successful completion of the requested scope of the project. AWARD CRITERIA The anticipated date of award is September, 1998. Funding decisions will be made on the basis of scientific and technical merit as determined by peer review, program needs and balance, and the availability of funds. Awards in response to this RFA will be made to foreign institutions only for research of very unusual merit, need, and promise, and in accordance with PHS policy governing such awards. Designated funding levels are subject to change at any time prior to award, due to unforeseen budgetary, administrative and/or scientific developments. INQUIRIES Inquiries concerning this RFA are encouraged. Potential applicants may request sample budget pages. The opportunity to clarify any issues or questions from potential applicants is welcome. Inquiries regarding programmatic issues and requests for sample budget pages may be directed to: Dr. Pankaj Ganguly Division of Blood Diseases and Resources National Heart, Lung, and Blood Institute 6701 Rockledge Drive, Room 10176 Bethesda, MD 20892-7950 Telephone: (301) 435-0070 FAX: (301) 480-1046 Email: [email protected] Direct inquiries regarding fiscal matters to: Ms. Jane R. Davis Grants Management Office National Heart, Lung, and Blood Institute 6701 Rockledge Drive, MSC 7926 Bethesda, MD 20892-7926 Telephone: (301) 435-0166 FAX: (301) 480-3310 Email: [email protected] AUTHORITY AND REGULATIONS The programs of the Division of Blood Diseases and Resources, NHLBI, are described in the Catalog of Federal Domestic Assistance number 93.839. Awards will be made under the authority of the Public Health Service Act, Section 301 (42 USC 241) and administered under PHS grant policies and Federal regulations, most specifically 42 CFR Part 52 and 45 CFR Part 74. This program is not subject to the intergovernmental review requirements of Executive Order 12372, or to Health Systems Agency Review. The PHS strongly encourages all grant and contract recipients to provide a smoke-free workplace and promote the non-use of all tobacco products. In addition, Public Law 103-227, the Pro- Children Act of 1994, prohibits smoking in certain facilities (or in some cases, any portion of a facility) in which regular or routine education, library, day care, health care or early childhood development services are provided to children. This is consistent with the PHS mission to protect and advance the physical and mental health of the American people.
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