The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutes, submitted a detailed response to the Office of Management and Budget’s (OMB) Request for Information regarding proposed updates to federal grant regulations (notably, 2 CFR Parts 25, 170, 175, 176, 180, 182, 183, and 200). The letter outlines a series of recommendations aimed at reducing administrative burdens, enhancing regulatory clarity, and promoting equity and fairness for institutions of higher education (IHEs) engaged in federally funded research. COGR’s high-priority suggestions include: reinforcing requirements for public comment on policy changes to ensure compliance with the Administrative Procedures Act; clarifying or removing confusing sections such as conflict-of-interest policies and voluntary uncommitted cost sharing; streamlining or eliminating redundant procedures like the DS-2 disclosure statement; updating definitions and allowable cost structures to accommodate modern research practices such as data management; and revising indirect cost recovery rules to address inequities and administrative limitations uniquely affecting IHEs.
Additionally, COGR urges the codification of certain frequently asked questions and authoritative memoranda to enhance consistency across agencies, encourages harmonization of grant administration systems, and proposes practical updates to definitions, cost allocation methodologies, and audit procedures. The letter also emphasizes the need for OMB to act as the central authority in resolving disputes or inconsistencies that arise during audits or in the acceptance of indirect cost rates. In summary, COGR’s response advocates for collaborative, data-driven reforms that acknowledge the evolving landscape of research administration, aiming to foster regulatory environments that are both effective and minimally burdensome for research institutions, thereby allowing them to focus resources more directly on their scientific missions.
