The document provides a detailed review and set of recommendations from the Council on Governmental Relations (COGR) regarding the implementation of the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards—commonly known as the Uniform Guidance (UG). The content outlines specific regulatory sections discussed during COFAR-COGR meetings and identifies both areas already addressed and issues that remain unresolved. Key topics include effective dates, conflict of interest policies, treatment of program income, procurement standards, closeout procedures, compensation rules, and subrecipient monitoring, among others. For each section, COGR enumerates concerns about ambiguity, potential negative impacts on institutional operations and research productivity, and inconsistencies in agency interpretation or enforcement.
The document systematically requests clarifications through updated Frequently Asked Questions (FAQs), revisions to guidance to address technical errors, and in some cases, proposals for grace periods to ease transitions to new standards. COGR also calls for sustained engagement between stakeholders—including OMB, the Department of Health and Human Services, and oversight agencies—to ensure consistent implementation, minimize administrative burden, and preserve effective delivery of federal programs. The overarching goal is to refine the Uniform Guidance in ways that maintain compliance while also supporting innovation and efficiency in federally funded research and program administration.
