The Council on Governmental Relations (COGR) Guide on Managing Externally Funded Sponsored Programs serves as a comprehensive resource for research universities, academic medical centers, and research institutes seeking to strengthen their management, compliance, and internal control systems for grants and contracts. Recognizing the complexity and evolving landscape of external sponsor requirements, the Guide presents structured principles and best practices spanning the entire sponsored program lifecycle, from proposal development and award negotiation through execution, reporting, and closeout.
Key focus areas include the establishment of clear, documented policies; well-defined roles and responsibilities; rigorous financial administration; effective internal controls; robust oversight mechanisms; and regular staff training. The Guide underscores the importance of compliance with federal, state, and local regulations, emphasizing proper stewardship of funds, transparency, accountability, and the application of consistent accounting standards. Special attention is devoted to distinct aspects such as subrecipient monitoring, procurement (with requirements for competitive processes and conflict-of-interest safeguards), equipment management, and reporting standards tailored to a range of sponsor and agency requirements.
Institutional infrastructure is addressed through policies supporting a collaborative compliance culture, diversity and non-discrimination in human resources, and comprehensive approaches to environmental health and safety, emergency preparedness, and information security. The Guide delineates procedures for conducting both internal and external audits, reinforcing the importance of independence, risk-based assessment, corrective actions, and the safeguarding of financial and sensitive information.
Integrity and protection regulations receive substantial emphasis, including the establishment and functioning of Institutional Review Boards (IRBs) and Institutional Animal Care and Use Committees (IACUCs), as well as processes for research integrity, responsible conduct, managing financial conflicts of interest, and protecting human and animal subjects in accordance with federal standards. Whistleblower protections, disaster recovery coordination, and clear communication with oversight bodies are also highlighted.
In the realm of intellectual property, the Guide outlines institutional obligations under statutes such as the Bayh-Dole Act, stressing the need for effective disclosure, protection, tracking, commercialization, and compliance with export control regulations (including ITAR and EAR). Senior leadership is called upon to foster a culture of compliance, support ongoing training, and ensure coordination among all offices engaged in research administration.
Overall, the COGR Guide acts as a benchmark for best practices, promoting ethical behavior, continuous improvement, and preparedness to adapt to regulatory changes. While not setting mandatory requirements, it provides a foundation for institutions to evaluate and enhance their research administration systems, ensuring the responsible conduct of research and stewardship of sponsored funds.
A Guide to Effective Management Practices
COGR has released the 2016 update to the Effective Management Practices Guide. The 2016 version incorporates the latest regulatory updates and other new content. In addition, this update includes bookmarks for ease of navigation and hyperlinks to direct the reader to related material both within the document and online. The online version will updated as needed and can be downloaded and printed anytime.
