The document is a formal response from the Council on Governmental Relations (COGR), an association of over 180 major research universities and affiliated institutes, to the Office of Management and Budget’s (OMB) Advanced Notice of Proposed Guidance (ANPG) regarding reforms to federal grant and cooperative agreement policies. COGR expresses appreciation for the federal effort to reduce administrative burden and increase the efficiency of grants administration, while emphasizing the importance of maintaining responsible compliance and accountability standards. The letter underlines the substantial contributions and perspective of research institutions, which conduct more than $60 billion in R&D annually, and calls for reforms that streamline processes without imposing undue financial or administrative burdens on these institutions.
Within its comprehensive response, COGR outlines various recommendations and concerns regarding proposed reforms. Key points include strong opposition to arbitrary cost reimbursement limitations and additional caps on Facilities & Administrative (F&A) cost rates, which already result in multi-billion dollar shortfalls for universities. COGR supports several initiatives designed to reduce administrative burden—such as alternatives to time-and-effort reporting, expanded utility cost adjustments, and allowance of directly allocable administrative costs—but criticizes moves toward simplified, flat F&A rates, consolidated cost principles, and standardized administrative requirements when they threaten institution-specific flexibility or add new mandates. The response is nuanced, endorsing reforms that provide genuine relief and efficiency, while cautioning against measures that might further shift costs to universities or diminish the effective partnership between federal agencies and the research community. Furthermore, COGR advocates for transparent processes, consistent government-wide policies—such as in cost sharing—and a collaborative approach to policy development, including the establishment of an ombudsman and mechanisms for ongoing dialogue and appeals. Overall, the document conveys COGR’s commitment to advancing grants reform in a manner that supports the mutual goals of accountability, productivity, and innovation in federally sponsored research.
