The Council on Governmental Relations (COGR), representing nearly 200 U.S. research universities and related institutions, provided formal feedback in response to the NIH’s Request for Information on its Draft Strategic Plan for Scientific Workforce Diversity for 2022-2026. COGR commended NIH’s efforts toward diversity, equity, inclusion, and accessibility (DEIA) and acknowledged alignment between NIH initiatives and those underway at member institutions. COGR noted that research institutions have already implemented significant DEIA measures—such as increasing recruitment from diverse backgrounds, creating more inclusive environments, and establishing DEI-focused positions—arguing that further regulation targeting grantees may not be necessary.
For sustaining DEIA through structural and cultural change, COGR advocated for ongoing engagement with a broad segment of the research community, including regular evaluation of NIH policies by an external advisory group with representation from under-resourced and less research-intensive institutions. The organization highlighted the disproportionate burden imposed on emerging research institutions, such as HBCUs and Minority Serving Institutions, by the current cap on facilities and administrative cost reimbursement. COGR also encouraged NIH to recognize the value of research addressing issues disproportionately affecting diverse communities and to integrate this awareness into the evaluation of research significance. Overall, COGR’s response emphasized collaboration, recognition of institutional diversity, and practical consideration of challenges facing less-established research organizations in advancing DEIA goals.
