The COGR August 2015 Update provides a detailed overview of significant regulatory, policy, and compliance developments affecting research institutions, particularly in the areas of federal grant administration, labor law, and compliance issues. Central topics include updates on the implementation of the OMB Uniform Guidance, with an emphasis on procurement standards and conflict of interest policies, and the requested extension of the grace period for compliance. The document outlines concerns regarding agency deviations from federal regulations and presents a systematic approach for responding to such deviations. It addresses challenges in indirect cost (F&A) calculations, such as tuition remission and the treatment of NIH salaries over the cap, while underscoring the evolving landscape of federal audit and documentation expectations.
Furthermore, the update reviews the transition to NIH subaccounting and the new 120-day grant closeout requirement, providing operational guidance to institutions. It discusses the ongoing implementation of compensation documentation under the Uniform Guidance, highlighting the COGR's new resource guide. Additionally, the document comments on various federal policy proposals, including increases in the minimum salary threshold for exempt overtime, stricter reporting of labor law violations for federal contractors, and changes related to Affordable Care Act compliance for research assistants. The report also covers current developments in federal research policy, such as efforts to streamline NIH grant procedures, upcoming changes in federal definitions of export control, harmonization of animal welfare oversight between NIH and NSF, and federal initiatives to reduce administrative burden in research. Throughout, the document underscores COGR’s advocacy and collaborative efforts on behalf of its member institutions, aiming to ensure practical, efficient, and compliant practices in federally funded research administration.
