The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted a response to the Office of Management and Budget (OMB) regarding proposed revisions to several parts of 2 CFR, which governs the administration of federal grants. COGR outlined key recommendations aimed at reducing administrative burden, enhancing clarity, and ensuring fairness for institutions of higher education (IHEs) and other research entities involved in federally sponsored research. Among the high-priority items, COGR emphasized the need for stronger adherence to the Administrative Procedures Act in agency policymaking, urged the elimination of redundant or outdated requirements such as the DS-2 disclosure statement, and advocated for more equitable treatment of IHEs concerning indirect (F&A) cost reimbursements and compliance costs. They also recommended updates to definitions, cost-sharing rules, and the handling of post-project costs to reflect current research practices and technological changes.
Additionally, COGR suggested the codification of specific frequently asked questions (FAQs) into regulation to clarify administrative processes and reduce ambiguity, while proposing low-risk, high-reward revisions on topics ranging from grant definitions to agency harmonization efforts and cost rate calculations. The organization voiced concerns over inequities in current policies, particularly those placing undue burden on research institutions compared to other grantee types, and called for solutions such as the adoption of an “uncapped compliance cost pool.” COGR's response reflects a collaborative intent to work with OMB on reforms that will benefit both the federal government and the broader research community, emphasizing the importance of efficiency, transparency, and stakeholder input in federal research administration policy.
COGR has posted its Letter to OMB, in response to OMB’s Request for Information (RFI) – Uniform Guidance. We expect OMB to review responses from all stakeholders and publish proposed revisions to the Uniform Guidance later in 2023. Contact Krystal Toups at ktoups@cogr.edu or David Kennedy at dkennedy@cogr.edu if you have comments or questions
