The letter from the Council on Governmental Relations (COGR), addressed to the National Science Foundation in December 2015, offers a detailed response to revised Research Terms and Conditions (RTCs) that implement the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200, or Uniform Guidance). COGR commends the collaborative efforts of federal agencies, acknowledging positive changes such as improved performance measurement provisions and the standardization of a 120-day closeout period for all reports, which collectively reduce the administrative burden on research institutions. The council encourages wider adoption of the RTCs among agencies and suggests appointing high-ranking agency contacts for addressing deviations, thereby advocating for consistent and transparent implementation.
COGR also presents substantive technical and policy recommendations for further revisions. These include clarifying classification for research and development awards, refining conflict of interest policies, ensuring institutional oversight in public access notifications, and modifying the language around compliance with national policy requirements to ensure fairness and clear federal communication. The letter addresses specific Uniform Guidance sections, offering practical amendments regarding cost sharing, budget revisions, prior approval processes, and handling of capital expenditures and participant support costs. COGR concludes by noting the review is preliminary pending the release of RTC appendices and emphasizes the importance of incorporating community feedback before finalizing the terms, committing to further commentary once all materials are available.
