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COGR Response to NIH RFI

The document is a formal letter from the Council on Governmental Relations (COGR), representing over 180 research universities and affiliated institutions, addressed to the A-21 Task Force of the National Science and Technology Council. Authored by COGR President Anthony P. DeCrappeo and dated July 28, 2011, the letter provides organized input in response to a Request for Information (RFI) regarding the reduction of cost and administrative burden associated with compliance to OMB Circular A-21, which sets forth cost principles for educational institutions engaged in federally sponsored research. COGR underscores the significant contribution of its member institutions to federally funded research, amounting to over $55 billion annually, and emphasizes the impact of federal regulatory requirements on the operational efficiency and effectiveness of research activities.

The letter summarizes COGR’s Executive Summary and detailed recommendations aimed at streamlining regulatory requirements, reducing unnecessary administrative complexities, and alleviating cost burdens imposed by current federal policies and practices. The recommendations, while primarily focused on institutions subject to OMB Circular A-21, are also deemed relevant to organizations governed by OMB Circular A-122 and 45 CFR Part 74, covering non-profit and hospital research entities. COGR attaches specific proposed actions, rationales, and, where applicable, suggested textual changes to federal guidance documents. Concluding with an expression of willingness to collaborate with the A-21 Task Force, COGR advocates for swift implementation of feasible recommendations, thereby enhancing the conduct of federally sponsored research at the nation’s leading academic institutions.

This summary was generated with AI. Report Issue

 Input on Reduction of Cost and Burden Associated with Federal Cost Principles for Educational Institutions (OMB Circular A-21), July 2011.  

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