The document presents a multifaceted discussion regarding the financial and regulatory challenges facing institutions of higher education (IHEs) in conducting research, with a particular emphasis on the cost burden imposed by federal requirements and the impact on American research competitiveness. Drawing on the 2021 National Science Foundation Higher Education Research and Development (HERD) survey, the presenters highlight a sustained increase in the cost of research compliance and associated risks, particularly for smaller and underrepresented institutions. Notably, there is a growing gap between federal investment and the institutional funds required to sustain R&D activities. The administrative cap, stringent reporting requirements, and the complexity of unfunded federal mandates are leading to significant institutional expenditures that are often underreported and insufficiently reimbursed by federal funding streams. The shifting financial burden, if unaddressed, risks eroding support for core educational programs and student services.
In response to these issues, the Council on Governmental Relations (COGR) is undertaking a detailed Facilities & Administrative (F&A) Survey to gather actionable data and inform advocacy for regulatory reform. Concurrently, COGR is preparing a response to the Office of Management and Budget’s (OMB) request for information (RFI) on Uniform Guidance at 2 CFR 200, aiming to address long-standing concerns such as the administrative cap, cost allowability, and reporting burdens. The document underscores the importance of institutional participation in surveys and public comment processes to shape future federal policy, with the ultimate goal of achieving greater equity, transparency, and sustainability in research funding and compliance frameworks.
