The document is a formal response from the Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, to the Office of Management and Budget’s (OMB) proposed revisions to 2 CFR Chapters 1 and 2. COGR commends OMB for its transparency and dedication throughout the rulemaking process but highlights several areas where the proposed changes could negatively affect established research funding principles, increase administrative burdens, or generate ambiguity. The response is comprehensive, providing detailed, constructive feedback and section-by-section recommendations aimed at refining regulatory clarity and efficiency while minimizing unnecessary burden on research institutions.
COGR’s recommendations focus on restoring consistency and fair cost-sharing principles, strengthening OMB oversight in grant-related disputes, and clarifying guidance around disclosures, cost sharing, and other key operational areas. Specific concerns are raised regarding ambiguous or potentially problematic language in areas such as conflict-of-interest policies, program income, cost definitions, record retention, audit requirements, and the treatment of indirect and fringe benefit costs. The organization applauds efforts to streamline and update federal grant management but emphasizes the necessity for clearer definitions, the retention of established and effective provisions, and the elimination of outdated or redundant requirements.
Additionally, COGR advocates for robust stakeholder engagement, practical implementation timelines, and continued access to user-friendly guidance such as FAQs. The response stresses the need for OMB to maintain its central role in oversight and harmonization, ensure consistency and equity across grant recipients, and incorporate ongoing stakeholder feedback. In conclusion, COGR expresses appreciation for OMB’s openness to input, reiterating the shared commitment to an efficient, fair, and effective federal-grantee partnership that fosters the continued advancement of research and innovation.
