The Council on Governmental Relations (COGR), representing over 220 U.S. research institutions, submitted detailed comments to the National Science Foundation (NSF) regarding proposed revisions to the NSF Proposal and Award Policies and Procedures Guide (PAPPG 26-1). COGR commends NSF's history of collaborative policy development but expresses concern over certain ambiguities, new compliance burdens, and inconsistencies with federal regulations. Key recommendations include clarifying and limiting system security reporting obligations to NSF accounts, tailoring multi-factor authentication to higher-risk roles, and specifying that research security training must be completed within one year of proposal submission while aligning renewal cycles with other federal standards to ease implementation.
COGR also advises that administrative and clerical salary policies should reflect Uniform Guidance without imposing additional budget approval conditions, and that equipment definitions and thresholds should be updated to align with recent federal changes. Regarding new data management and sharing requirements, COGR recommends more flexible, less prescriptive documentation and the ability to upload established data management plans. The organization supports the timing and flexibility of new foreign financial disclosure reports but urges consistency with existing federal reporting cycles to minimize burden. Additional recommendations address indirect cost rate applications in light of recent federal updates, clarification of oversight responsibilities in research involving recombinant DNA, practical guidance for the dissemination of research results (especially for physical collections and software), and more flexible equipment marking requirements. Overall, COGR’s response emphasizes minimizing unnecessary administrative work, ensuring policy clarity, and aligning with existing federal standards to facilitate ongoing effective research administration.
