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COGR Readiness Document - Uniform Guidance -

The "COGR Implementation and Readiness Guide for the OMB Uniform Guidance," prepared by the Council on Governmental Relations (COGR) and authored by David Kennedy and the COGR Costing Policies Committee, serves as a comprehensive resource to assist research institutions in understanding and implementing the Office of Management and Budget (OMB) Uniform Guidance, which streamlines and consolidates federal regulations for grants and cooperative agreements. Published in December 2014, the guide addresses the significant changes introduced by the Uniform Guidance (commonly referred to as 2 CFR 200), offering detailed interpretations, practical readiness checklists, and policy recommendations tailored to university and research administration contexts.

The document systematically outlines key reforms and compliance areas, including cost principles, administrative requirements, and audit standards, highlighting both opportunities for administrative efficiency and areas of potential risk for noncompliance. COGR provides institutions with an actionable framework for reviewing internal policies, updating procedures, and training personnel to align with the new federal requirements. In addition to clarifying regulatory language, the guide offers advice on documentation, internal controls, negotiation strategies for indirect cost rates, subrecipient monitoring, and reporting requirements. It emphasizes collaboration with federal agencies, transparency, and continued assessment as critical strategies for a smooth transition to the new guidance. Overall, the document functions as both an educational reference and a pragmatic toolkit, supporting higher education institutions in ensuring robust compliance and optimized operational practices under the reformed federal grant environment.

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for the Guide. If interested in a Word version of the Guide, please contact David Kennedy.