The document is a formal communication from the Council on Governmental Relations (COGR) to the U.S. Office of Management and Budget (OMB), offering comprehensive commentary on the proposed Uniform Guidance intended to streamline and update federal policies for grants, cooperative agreements, cost principles, and administrative requirements. Representing major research universities and institutions, COGR recognizes OMB's efforts toward harmonization and standardization, but stresses the importance of careful vetting to prevent unintended consequences that could increase administrative burden or compromise research effectiveness.
COGR’s response identifies numerous opportunities for improvement within the proposed guidance. These include advocating for greater consistency, transparency, and practicality in federal requirements; discouraging unnecessary agency deviations; rationalizing timelines for new guidance implementation; and ensuring advance notice for application deadlines. The organization emphasizes the need for clear, consistent definitions of key terms and alignment across federal regulations to reduce confusion and compliance risk.
Administrative efficiency and operational flexibility feature prominently in COGR’s recommendations. Specific concerns are raised about overly prescriptive procurement rules, burdensome record-keeping, and cost-sharing policies that do not reflect the realities of research management. COGR recommends risk-based and streamlined subrecipient monitoring, more flexible approaches to personnel compensation documentation, and the use of integrated payroll systems instead of rigid effort reporting.
On financial matters, COGR calls for transparent and equitable treatment of indirect costs, practical cost thresholds, flexibility in administrative and clerical charges, and improvements in facilities and administrative (F&A) rate development practices. The document strongly opposes the introduction of requirements viewed as outdated or unsuited to contemporary research environments, such as certain equipment screening procedures and unnecessary procurement burdens.
COGR also addresses audit-related provisions, advocating for a balanced approach that raises audit thresholds without shifting excessive oversight responsibilities to institutions, and requests mechanisms to avoid redundant federal audits and ensure transparent audit processes.
Throughout, COGR urges ongoing collaboration, offering specific alternatives and edits to the guidance that aim to reduce regulatory complexity, ensure administrative feasibility, and better align federal requirements with the practical needs of research organizations. The overarching theme is a call for regulations that achieve compliance objectives while minimizing unnecessary complexity and burden, thereby enabling institutions to focus resources on the advancement of research and innovation.
