The document is an official letter from the Council on Governmental Relations (COGR), representing over 180 major research universities and affiliated institutions, addressing the National Science and Technology Council’s A-21 Task Force. Authored by David Kennedy and signed by COGR President Anthony P. DeCrappeo, the letter provides detailed feedback in response to a Request for Information (RFI) regarding the reduction of cost and administrative burdens associated with OMB Circular A-21, which outlines federal cost principles for educational institutions receiving research funding. The correspondence underscores the significant role that COGR member institutions play in federally funded research, executing more than $55 billion in annual R&D activities supported by over 25 federal agencies.
The letter introduces an Executive Summary of COGR’s recommendations, followed by expanded explanations that detail proposed actions and rationales. In certain instances, specific revisions to the language of OMB Circular A-21 are suggested to facilitate immediate implementation and broad applicability, including to institutions governed by OMB Circular A-122 and other federal cost principles. COGR’s recommendations are intended to limit regulatory burdens that impede research activities, enhance efficiency in administrative processes, and align cost principles more closely with the practical realities faced by educational and non-profit research institutions. The letter concludes by expressing appreciation for the Task Force’s efforts and a willingness to collaborate in enacting the proposed modifications.
