The November 2021 Update from the Council on Governmental Relations (COGR) provides an in-depth overview of recent developments affecting research security, intellectual property management, research ethics and compliance, costing, financial compliance, and contracts and grants administration for academic institutions. Key updates include the Department of Defense’s (DOD) implementation of CMMC 2.0, which streamlines cybersecurity compliance requirements by reducing maturity levels and emphasizing self-attestation and NIST standards, although the full adoption awaits the completion of the rulemaking process. Legislative changes are ongoing, with pending research security and reporting requirements for federal contractors expanding under the National Defense Authorization Act. The Department of Energy (DOE) issued clarifications on domestic manufacturing requirements in the Bayh-Dole Act and is considering further limiting federal oversight of institutional changes of control. The Defense Advanced Research Projects Agency (DARPA) introduced a Countering Foreign Influence Program, raising concerns regarding the breadth and nature of risk assessments for academic personnel, especially regarding personal ties, risk rubrics, and potential contradictions with fundamental research principles.
The report discusses ongoing efforts to standardize and ease disclosure and compliance requirements under the Presidential NSPM-33 directive, emphasizing cross-agency consistency, reduced administrative burden, and support for international collaboration. Updates are provided on efforts to modernize and harmonize electronic CV and disclosure mechanisms and institution-led initiatives to enhance compliance with broadened federal agency requirements. In research ethics, COGR addresses regulatory changes concerning animal research, conflict of commitment, China’s Personal Information Protection Law, and updates to conflict-of-interest management and export controls. Financial compliance updates focus on audit responses, treatment of cost sharing and rebates, the National Science Foundation’s (NSF) indirect cost rate policies, and ongoing challenges with the federal Payment Management System. Administration updates include guidance changes regarding COVID-19 vaccine mandates, revised criteria for “well-funded investigators,” and continued work with OSTP to further reduce administrative burden. Throughout, the report underscores a commitment to transparency, stakeholder engagement, and balancing research security with operational feasibility and academic values.
