COGR’s Response to JCORE RFI

COGR submitted comprehensive comments to the White House Office of Science and Technology Policy (OSTP) regarding the American Research Environment. COGR commended OSTP for its cross-agency efforts to address persistent challenges in research administration, emphasizing that the proliferation of federal regulations and inconsistent agency requirements has increased administrative burdens, potentially hindering U.S. scientific competitiveness. The association advocated for systematic consultation between agencies and the research community prior to the implementation of new policies, highlighting that such engagement typically produces clearer, more effective outcomes. COGR’s response addressed several core issues. On research rigor and integrity, COGR supported ongoing efforts to strengthen reproducibility and recommended federal agencies recognize diverse research outputs and support discipline-specific standards. The letter urged harmonization and simplification of administrative and conflict of interest (COI) requirements, specifically calling for streamlined, federal-wide COI policies modeled after the NSF’s approach rather than the more burdensome 2011 Public Health Services rules. Regarding proposal submissions and awards, COGR suggested a single, standardized system for federal research funding applications and a phased information submission process to minimize unnecessary requirements. On research security, the association supported risk-based disclosure requirements, the clear definition of reportable activities, and improved government sharing of timely security information with institutions. It also emphasized the importance of preserving the fundamental research exclusion in export control regulations. Finally, COGR acknowledged the need for sustained institutional and federal efforts to promote safe and inclusive research environments, highlighting the importance of proactive leadership, robust anti-harassment policies, and regular reassessment of institutional procedures. Together, these recommendations aim to balance regulatory oversight with operational efficiency, sustain research integrity, and foster an inclusive, competitive U.S. research landscape.