The document is a formal letter from the Council on Governmental Relations (COGR), an association of 160 research-intensive universities, affiliated hospitals, and research institutes across the United States. Addressed to the Office of Federal Financial Management within the Office of Management and Budget (OMB), the letter discusses a proposed policy aimed at establishing standardized government-wide terms and conditions for federal research and research-related grants. COGR expresses strong support for the policy's intent to simplify and streamline grant administration, which aligns with longstanding Congressional interests and the Federal Financial Assistance Management Improvement Act of 1999, as well as recent directives advocating for modernization in research funding practices.
COGR acknowledges the significant progress represented by the proposed policy, noting the accumulated experience and readiness of both federal agencies and academic institutions for such improvements. However, the organization also articulates concerns and recommendations regarding the need to minimize agency-specific exceptions to the standardized terms, advocating for rigorous review criteria and public transparency. COGR emphasizes the importance of clear definitions for “research” and “research-related” programs to ensure consistent implementation, and recommends ongoing stakeholder engagement and oversight. The letter concludes by urging continued efforts toward true administrative reform and pledges COGR’s full support for the policy’s successful adoption.