The Council on Governmental Relations (COGR), in its communication addressing the NIH RFI and federal research oversight, outlines a comprehensive set of recommendations designed to alleviate the administrative and financial burdens imposed by federal regulations—particularly OMB Circular A-21—on research universities, hospitals, and nonprofit research organizations. COGR advocates for a modernization and simplification of regulatory requirements, emphasizing the need to update or eliminate provisions that are outdated, redundant, or unnecessarily complex. Key recommendations include shifting from mandatory effort reporting to institutionally tailored, outcome-based payroll systems, allowing the direct charging of legitimate project management costs, and streamlining subrecipient monitoring for entities already subject to federal audit requirements.
The organization also calls for the universal acceptance of federally negotiated Facilities & Administrative (F&A) rates, the removal of arbitrary caps on F&A recoveries, and restrictions on cost sharing to instances where they are explicitly required. Additional proposals promote a more transparent and collaborative F&A rate negotiation process, standardized utility cost adjustments, broader acceptance of electronic records, and harmonized audit and compliance procedures across federal agencies. COGR further highlights the importance of enhancing the Grants.gov portal’s functionality and stability, the harmonization of regulations governing research, and the periodic updating and effective communication of compliance guidelines.
To ensure that new policies do not introduce undue compliance costs, COGR recommends rigorous cost analyses for any new mandates, with these costs explicitly considered in policy development and made recoverable by affected institutions. The appointment of a federal ombudsman and the extension of regulatory flexibility measures to research organizations are also proposed to improve communication and responsiveness. Collectively, these measures are intended to promote efficiency, consistency, and a more effective partnership between research organizations and the federal government, reducing unnecessary compliance burdens while maintaining high standards of financial stewardship and accountability.
