COGR Update

March 2023 Update

The March 2023 COGR Update provides a comprehensive overview of ongoing activities, policy developments, and advocacy efforts pertinent to research-intensive institutions in the United States. The report begins with announcements, notably highlighting the transition to a new COGR president, plans for the organization’s 75th anniversary, and ongoing efforts to engage more members in COGR activities through volunteer opportunities. The Update then systematically details major regulatory and compliance issues impacting the research community, including the implementation of the NIH Data Management and Sharing Policy, which has generated significant administrative and financial impact, particularly on smaller institutions. The policy's rollout has exposed challenges in budgeting, proposal preparation, and the capture of true data management costs, prompting COGR to advocate for greater clarity and practical solutions, including through ongoing surveys and engagement with NIH.

The Update also delves deeply into federal policy frameworks, such as OMB’s proposed revisions to 2 CFR 200 (Uniform Guidance), where COGR has provided detailed feedback to improve clarity, streamline compliance processes, and address cost-recovery issues. Science and security topics feature prominently, with updates on federal research security standards mandated by NSPM-33 and the CHIPS & Science Act, Congressional scrutiny over foreign influence (particularly concerning China), and the challenges institutions face in responding to evolving risk matrices from agencies like the Army. Additional attention is given to research ethics and compliance, referencing developments in FDA guidance, changes in conflict of interest management, new animal research regulations, and collaborative initiatives with agencies such as ORI and NASA.

Furthermore, the report summarizes significant developments in contracts and grants administration, including NIH and NSF policy updates, evolving open access requirements, and new administrative burdens tied to grant management. Costing and financial compliance matters are addressed through updated F&A Cost Rate surveys and advocacy for timely negotiations of cost rate agreements. The report concludes with an acknowledgment of the contributions made by COGR leadership and standing committees, underlining the organization's ongoing commitment to representing and supporting its membership in navigating an increasingly complex regulatory environment for research. Overall, the Update reflects COGR’s proactive role in tracking regulatory changes, fostering institutional preparedness, and ensuring the research community’s interests are represented in national policy discussions.

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