The Council on Governmental Relations (COGR), representing major research universities, issued a comprehensive response to the National Academy of Sciences Committee’s report on optimizing federal research regulations. COGR largely supports the report’s thrust to streamline and harmonize research regulations, endorsing uniform grant proposal processes, centralized data repositories, and the expansion of just-in-time submission for grant materials, though implementation will necessitate both policy adjustments and legislative changes. In the area of subrecipient monitoring, COGR strongly advocates for reliance on existing Single Audit mechanisms to avoid redundant oversight and promote efficient resource allocation. While supporting harmonization of conflicts of interest (COI) policies, COGR warns against adopting a single, burdensome federal standard based on Public Health Services (PHS) regulations, urging suspension of agency-specific COI policies pending further study.
Regarding the protection of human subjects, COGR opposes both the creation of an "excused" research category and mandates for single Institutional Review Boards (IRBs), instead favoring piloted, flexible approaches, strong harmonization of agency regulations, and avoidance of unnecessary consent requirements for biospecimens. In animal research, COGR echoes calls for reducing redundant reporting and risk-based protocol reviews. On research grant financial management, COGR critiques costly and duplicative audit practices and supports flexible procurement thresholds alongside enhanced timelines and uniformity in financial and progress reporting. Notably, COGR calls for eliminating the DS-2 requirement, deeming it outdated. COGR endorses establishing a new Research Policy Board and a government official with the authority to oversee regulatory issues, emphasizing that these roles require sufficient legal mandate to effect systemic change. Throughout, COGR underscores the need for practical, evidence-driven regulatory reform that balances accountability with operational efficiency, while expressing commitment to ongoing collaboration with policymakers and regulatory bodies.
