APLU-AAU joint response to the Advanced Notice of Proposed Rulemanking (ANPRM) entitled Human Subjects Research Protections: Enhancing Protections for Research Subjects and Reducing Burden, Delay, and Ambiguity for Investigators (Notice Number HHS-OPHS-2011-0005), published in the July 26, 2011 Federal Register (76 FR 44512)