The Council on Governmental Relations (COGR), a collective representing leading research universities, addressed a letter to officials at the Office of Federal Financial Management regarding concerns about the impending implementation of the Uniform Guidance scheduled for December 26th, 2014. While expressing appreciation for the government's efforts to enhance the effectiveness and efficiency of federal financial assistance, COGR highlighted significant issues surrounding the Disclosure Statement (DS-2) requirement for Institutions of Higher Education (IHEs). The organization argued that reintroducing the DS-2, previously eliminated, would impose unnecessary administrative burdens without yielding corresponding improvements in accountability or transparency. COGR pointed out that the information contained in DS-2 forms is already available in university policy documents, that the form plays a minimal role in audits, and that the current approach singles out IHEs as the only major federal award recipients subject to this requirement, a practice inconsistent with the treatment of other entities.
COGR recommended eliminating the DS-2 requirement for IHEs as previously done or, alternatively, modifying the threshold so that only those IHEs with $50 million or more in Cost Accounting Standards (CAS)-covered contracts—rather than aggregate federal awards—be subject to DS-2 submissions. This adjustment, consistent with standards applied to commercial enterprises, would help ensure fairness, reduce unwarranted administrative workload, and facilitate smoother implementation of the Uniform Guidance. COGR emphasized that aligning requirements across types of organizations would maintain accountability while supporting the core goals of federal research funding policy and requested timely consideration of this technical correction.
