COGR Submits Letter to OMB Objecting to DoEd’s Section 117 Emergency Order

The Council on Governmental Relations (COGR), representing 187 research universities and affiliated research entities, submitted a formal letter to Mr. Paul Ray, Acting Administrator at the Office of Information and Regulatory Affairs within the Office of Management and Budget, regarding a Department of Education request for emergency review of a proposed Information Collection Request (ICR) related to Foreign Gifts and Contracts Disclosures (Docket No. ED-2019-ICCD-0154). COGR expresses significant concern over the Department's decision to reduce the standard public comment period from 30 to 10 days, particularly as the shortened window coincides with the holiday season when federal offices and universities are largely inactive. The organization emphasizes that this compressed timeline undermines its ability to provide comprehensive and meaningful feedback. Furthermore, COGR aligns itself with the positions stated by the American Council on Education and other organizations, arguing that the Department of Education's request does not meet established criteria for emergency review. Accordingly, COGR strongly urges the Office of Management and Budget to reject the Department’s request for expedited consideration.