The Council on Governmental Relations (COGR), representing 188 research universities and related institutions, submitted feedback on the draft Federal Grants Management Data Standards proposed by the Office of Federal Financial Management. COGR acknowledges the importance of standardized data fields for enhancing electronic grant processes and appreciates the progress thus far. However, the organization raises several concerns regarding the draft, including ambiguity about responsibility for completing data fields, criteria for multiple responses, and the degree of required submission for each proposal or report.
COGR also expresses significant apprehension about transparency and sensitivity of certain data elements, particularly those that could reveal intellectual property, research involving sensitive materials, or personal information such as researcher citizenship status. The letter emphasizes the need for careful consideration of data privacy, ethical, and legal issues, especially in the context of anti-discrimination laws. While supporting the overarching goals of interoperability and efficient data management, COGR urges continued dialogue and opportunities for stakeholder input throughout the development and implementation of these federal data standards.