The document is a formal letter from the Council on Governmental Relations (COGR), an association representing 190 major research universities and affiliated institutions, to the U.S. Department of Defense (DoD). Signed by COGR President Anthony DeCrappeo and dated February 6, 2017, the letter provides feedback on the proposed changes to DoD Grants and Cooperative Agreements, specifically focusing on administrative requirements, cost principles, and audit requirements for federal awards. COGR expresses appreciation for the opportunity to comment, but voices concerns over certain modifications, such as the introduction of a prior approval requirement for budget transfers exceeding 10% of the total award, which is seen as inconsistent with prior practice and other major federal agencies, potentially increasing administrative burden for grant recipients.
COGR also discusses the clarity, structure, and user-friendliness of the proposed regulatory language and format. The organization generally supports efforts to improve clarity and consistency through plain language, but notes areas of potential concern, such as inconsistent financial reporting periods and ambiguous or potentially burdensome language that may complicate compliance. Overall, COGR welcomes alignment with Uniform Guidance but urges the DoD to reconsider aspects that diverge from norms, emphasizing the importance of minimizing unnecessary administrative complexity and ensuring clear, consistent expectations for research institutions. The letter concludes by offering to provide further input or clarification upon request.
to a series of six (6) DoD NPRMs updating the DoD Grant and Agreement Regulations (DoDGARs) to implement 2 CFR part 200.
