The document, authored by the Council on Governmental Relations (COGR) Costing Committee, addresses the inconsistencies and challenges research universities face regarding federal reimbursement for research costs, particularly facilities and administrative (F&A) expenses. The paper contends that many federal funding agency policies frequently diverge from official federal guidelines, resulting in substantial under-recovery of research costs by universities and research institutions. It highlights the financial strain caused by arbitrary limitations on cost reimbursement—such as artificial caps on F&A rates and restrictive cost-sharing requirements—which undermine the financial stability necessary for research excellence and the broader institutional mission, including education.
Through data and historical context, the document demonstrates that universities often contribute significantly to research endeavors, both through direct investment and unrecouped indirect costs, with recent estimates of unreimbursed F&A costs exceeding $2 billion annually. Despite established federal directives (notably OMB Circular A-21 and subsequent policy statements) intended to standardize cost principles and ensure the government bears its "fair share" of research costs, the report cites persistent, agency-specific deviations as a source of inefficiency, administrative burden, and inequity. The document concludes with a series of recommendations urging federal agencies and the Office of Management and Budget to enforce compliance with existing guidelines, eliminate arbitrary cost limitations, and establish clearer, more equitable reimbursement protocols, positing that aligning agency practices with federal principles will better ensure the sustainability and impact of the nation’s research enterprise.
to view the Policy Paper
to view the Appendix
