The Council on Governmental Relations (COGR), representing major research universities, submits a formal response to the National Science Foundation regarding the revised Research Terms and Conditions (RTCs) linked to the Uniform Guidance for federal awards. COGR expresses appreciation for several measures within the new RTCs that streamline administration and reduce burden, particularly changes around performance measurement and closeout periods for reports. The organization encourages ongoing efforts to ensure all relevant agencies adopt these RTCs fully and emphasizes that deviations from consistent implementation increase complexity and administrative workload for research institutions.
COGR also provides detailed, section-by-section feedback highlighting both support and concerns. Key areas discussed include the classification of program clusters, conflict of interest policies, requirements for public access to federal award information, communication of national policy requirements, cost sharing clarifications, and protocols for prior approvals on budget revisions, expenditures, and participant support costs. The organization advocates for refinements to language, clearer documentation of policy intent, and removal of unnecessary prior approval steps, which would enhance clarity and reduce administrative effort. COGR concludes by stressing the importance of transparency in releasing all supporting appendices and agency-specific requirements for public review prior to finalizing the RTCs, promising further comment once these materials become available.
