The GEU IACUC reviewed a protocol involving primate work at a nearby organization. GEU did not have the equipment necessary to complete the research project, so a researcher at Great Western University (GWU) who had the equipment agreed to collaborate with the GEU researcher. The IACUCs at both organizations approved the work for nine animals and the researchers began the activity. At the end of the year it was time to file the US Department of Agriculture (USDA) annual report, and the IACUC administrator for GEU collected the animal use numbers for all protocols at the organization. The primates used at the collaborator’s organization were not reported on GEU’s USDA annual report because the animal work was performed at GWU. Approximately 6 months later, the USDA inspector visited GEU and, while reviewing the protocol, discovered that the primates were not listed on the annual report. While the GEU IACUC administrator argued that the work was done at a different organization, the USDA inspector issued GEU a citation for under-reporting animal use. The citation was based upon animal ownership, which had been retained by GEU.