The Council on Governmental Relations (COGR), representing a consortium of 188 research universities, medical centers, and research institutes, submitted feedback to the Office of Science and Technology Policy (OSTP) regarding draft guidelines for desirable characteristics of data repositories managing federally funded research data. COGR acknowledges the value of accessible, well-managed data repositories in driving innovation and discovery. The organization emphasizes the importance of clear, consistent definitions developed with broad stakeholder input, and advocates for repositories and standards that evolve with scientific practices while ensuring governance, sustainability, accessibility, and security.
COGR recommends centralized, agency-managed repositories to promote consistency, minimize administrative burdens on researchers, and optimize funding and technical oversight. The organization warns that decentralized, local repositories risk inefficiency, redundancy, and lapses in best practices, potentially undermining data quality and compliance with FAIR principles. The statement highlights the need for repository governance structures inclusive of researchers and administrators, as well as funding mechanisms that cover the costs of compliance—particularly for credentialing and long-term maintenance. COGR also addresses the complexity of sustaining repositories, defining “long-term,” establishing reuse and metadata standards, and securing data (especially sensitive human subjects data), recommending alignment with regulatory frameworks such as IRB review, NIH guidance, and data protection laws. The letter concludes by urging ongoing collaboration among stakeholders to refine achievable, cost-conscious standards that promote public access while supporting researchers' needs.
