The August 2015 Update from the Council on Governmental Relations (COGR) provides a thorough overview of key policy developments and compliance issues impacting research institutions, particularly in relation to federal grant administration. The document addresses ongoing challenges with the implementation of the Uniform Guidance, including the advocacy for a grace period extension for procurement and conflict of interest provisions, and offers a recommended procedure for responding to agency deviations from federal standards. COGR discusses complexities surrounding Facilities and Administrative (F&A) costs, employee tuition remission, salary cap calculations, and emphasizes the need for continued dialogue with federal agencies to clarify unresolved issues. The update highlights the transition to NIH subaccounting and revised grant closeout procedures, pointing to significant operational impacts and the need for institutions to update systems in preparation for new requirements.
Further topics include updated guidance on compensation documentation, findings from the NSF OIG payroll certification audit at George Mason University, cloud computing cost treatment, and finalized compliance supplements for audits. COGR outlines its involvement in responding to proposed changes to NIH salary caps, Affordable Care Act compliance for graduate student health plans, and new Department of Labor overtime rules. The document also covers increased federal contracting labor law reporting mandates, proposed regulatory changes for controlled unclassified information and export controls, and delays in patent reform legislation. Updates are provided on federal research terms and conditions, NIH and NSF proposal procedures, efforts to reduce administrative burden (notably through the DATA Act and engagements with the National Academies and GAO), as well as policy developments surrounding laboratory animal welfare, IRB procedures, and NSF approval timelines. Throughout, COGR emphasizes its advocacy and collaborative efforts to ensure that administrative policies remain practicable for academic and research institutions, minimize unnecessary burden, and maintain compliance with evolving federal requirements.
