COGR Submits Letter to OMB on Open Items Per UG

The document is a formal letter from the Council on Governmental Relations (COGR), representing leading research institutions, addressed to the White House Office of Management and Budget (OMB). Dated March 16, 2016, the letter outlines a set of unresolved issues pertaining to the implementation of 2 CFR Part 200, commonly known as the Uniform Guidance, which governs federal grants management. COGR commends OMB and the Council on Financial Assistance Reform (COFAR) for their collaboration and expresses optimism that the outstanding issues can be resolved as policy clarifications rather than requiring substantive policy changes. The letter emphasizes that COGR’s recommendations aim to reduce administrative cost and burden, uphold established audit and accountability standards, and promote fairness across non-federal entities.

COGR presents a prioritized list of ten substantive concerns, each accompanied by proposed solutions. Key issues involve clarifications to procurement standards, conflict of interest policies—particularly regarding the inappropriate conflation with scientific conflicts—the utility cost adjustment formula for research facilities, and the requirements related to disclosure statements (DS-2) for cost accounting practices at institutions of higher education. The letter further addresses increased administrative burdens resulting from subrecipient monitoring, challenges in negotiating F&A rates with for-profit entities, inconsistencies stemming from varying agency adoption of research terms and conditions, and the need for codifying both the regulatory preamble and frequently asked questions for more consistent application across agencies. Additionally, COGR highlights concerns about cost sharing and F&A rate deviations, and proposes the establishment of an OMB Ombudsman to ensure transparent resolution of disputes and policy ambiguities. Throughout, COGR calls for timely, pragmatic, and collaborative solutions that support federally funded research without imposing undue administrative impediments.