The Council on Governmental Relations (COGR), representing 190 U.S. research universities and affiliated medical centers, submitted comments to the General Services Administration regarding the proposed Federal Acquisition Regulation (FAR) Case 2014-025, “Fair Pay and Safe Workplaces.” The letter, dated July 27, 2015, acknowledges the growing compliance demands faced by research institutions in relation to federal contracts and expresses support for a more manageable compliance process. Specifically, COGR endorses an alternative approach outlined in the proposal, whereby subcontractors would report labor law violations directly to the Department of Labor (DOL), which would then provide determinations regarding their responsibility for labor compliance.
COGR emphasizes that universities often lack the necessary expertise and resources to independently evaluate subcontractor compliance across multiple tiers, and argues that relying on DOL’s assessments would mitigate administrative burdens and promote consistency. The organization advocates for adoption of the alternative provisions within the proposed regulation, allowing universities to opt for DOL guidance rather than conducting their own evaluations. The letter concludes with COGR’s appreciation for the opportunity to provide input, reinforcing the importance of a balanced and effective regulatory framework for federal research contracts.
