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Managing Externally Funded Research Programs:
A Guide to Effective Management Practices

COGR is association of leading research universities and their affiliated academic medical centers and research institutes. One of COGR's important activities is helping to develop policies and practices in research and training that reflect the mutual interest and separate obligations of research institutions and federal and other sponsoring agencies. This guide is illustrative of such activity.

This guide may be used by institutions to help review their management systems and internal controls with regard to managing sponsored programs generally in the form of grants and contracts as distinguished from gifts and other supported activities at the institution. Readers must recognize that while general principles of effective management are stable and consistent and applicable to all externally-supported activities, rules and regulations imposed by external sponsors on grants and contracts obligate the institution to meet specific obligations and affects, among other things, the way the institution accounts for and reports on the use of the funds. The rules and regulations of external sponsors are subject to change requiring a different approach to management. This guide does not purport to set standards for sponsored program management; it only suggests effective management practices and indicators to test those practices. COGR periodically updates and revises this document. However, at any point in time, this document should be considered in the light of administrative and regulatory changes made subsequent to its latest revision date.

This document was originally published in April 1989. This is its sixth revision. Each edition updates the information through additions and, as appropriate, deletions to reflect the current effective practices with some related indicators. sometimes new principles are added as management practices expand in response to changes in research and sponsored programs and new regulations.

The guide begins with a discussion of a comprehensive compliance system that sets the framework for all the principles that follow. The discussion calls directly for an institutional commitment to compliance. A comprehensive compliance system implies looking at compliance as a systemic enterprise rather than discrete practices in response to specific regulations. Thus, while compliance will take a different form in meeting financial, administration, or performance requirements, all these activities reflect a commitment to compliance across the organization.

Throughout this document, we use "sponsored research programs" or "sponsored programs" to be inclusive of sponsored project(s), except where the use of "project" is specifically called for by the context.

The Guide is available in paper and web-based formats. The web-based format takes advantage of providing links at the end of each section to the principal regulatory documents and materials. Generally the web links are to main or home pages and the user will need to search for a specific document. These external links will be checked periodically. Users may print each section individually, or the entire document as single file. Paper copies of the Guide are available from COGR for $5.00 per copy. shipping and handling is included in the copy price.

COGR appreciates the contribution of all its members in bringing new challenges and strategies for addressing them to the attention of their colleagues across the country. The members of the working group availed themselves of this general expertise and want to thank Patricia Greer, Peggy Lowry, Julie Norris, Judith Nowack and Mary Ellen sheridan for their special assistance. The working group's dedication and commitment to a thoughtful and thorough revision benefits all the members.

Gunta Liders, University of Rochester, Chair
Michael Amey, Johns Hopkins University
John Chinn, East Carolina University
Michelle Christy, Massachusetts Institute of Technology
Allen DiPalma, University of Pittsburgh
Kathleen Irwin, University of Wisconsin
Ara Tahmassian, Boston University
David Wynes, Emory University
Carol Blum, COGR

Reproduction for purposes of sale or profit is prohibited without the written consent of the Council on Governmental Relations. Otherwise, reproduction is encouraged.

Council on Governmental Relations
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202-289-6655

July 2009

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