The letter from the Council on Governmental Relations (COGR), authored by David Kennedy and the COGR Costing Policies Committee, is addressed to the Office of Management and Budget (OMB) regarding the implementation of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). Representing over 190 research-intensive institutions, COGR acknowledges and commends the OMB and the Council on Financial Assistance Reform (COFAR) for their transparent and inclusive process in developing the Uniform Guidance, which aims to streamline federal grant administration and reduce unnecessary regulatory burden. Nevertheless, COGR outlines eight priority areas where further policy refinements are necessary to ensure effective and equitable implementation. These areas include clarifying conflict of interest rules to distinguish between procurement and scientific collaborations, streamlining subrecipient monitoring through safe harbor provisions, revising procurement standards (notably increasing the micro-purchase threshold and aligning requirements for research institutions with established state practices), standardizing a 120-day closeout period across agencies, modifying the DS-2 cost accounting disclosure process to reduce administrative delays, correcting ambiguities in policies regarding compensation and tuition benefits, adjusting the utility cost allocation methodology to better reflect actual research costs, and promoting ongoing OMB leadership and interagency collaboration to address inconsistencies and further reduce administrative burden.
COGR’s recommendations emphasize the need for practical adjustments that will both uphold accountability and ensure fair treatment for research institutions, supporting the overarching goals of regulatory efficiency and scientific productivity. The letter urges OMB to adopt these changes in a collaborative manner, recognizing the dynamic policy environment and the necessity for continuous review and partnership among federal agencies, the audit community, and research institutions. By addressing these issues proactively, COGR contends that the federal grants process will become more effective, efficient, and better aligned with the needs of the broader scientific research community while maintaining the integrity of federal funds.
COGR has submitted its comments to the December 19, 2014 Federal Register Notice on Federal Awarding Agency Regulatory Implementation of Office of Management and Budget's Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2 CFR [art 200)
