The document is the Council on Governmental Relations (COGR)'s response to the National Academy of Sciences' report on optimizing federal research regulations and reporting requirements for academic research institutions. COGR broadly expresses support for the report’s recommendations aimed at reducing administrative burden and increasing efficiency in the management of federal research grants. The organization endorses the adoption of uniform documents for grant proposals, expansion of “just-in-time” submissions, centralized repositories for assurances, and streamlined progress reporting. It emphasizes the need for harmonized agency policies, particularly in areas such as conflict of interest, human subjects research, and animal research, while cautioning against one-size-fits-all solutions, such as the mandated use of single Institutional Review Boards (IRBs) or a federal-wide conflict of interest policy without further evidence and study.
COGR also advocates for significant reforms in financial management, including clarifying audit and subrecipient monitoring processes, raising procurement micro-purchase thresholds, and eliminating redundant requirements such as the DS-2 accounting disclosure. The response supports the creation of a Research Policy Board (RPB) and a designated government official with the authority to oversee academic research regulations, urging that these roles be both sufficiently empowered and representative of the academic research community. COGR further calls for regular review of existing regulations, pilot-testing of new requirements, and continued stakeholder engagement to ensure that regulatory frameworks remain effective without imposing unnecessary burdens on institutions. Overall, the response conveys a commitment to collaboration and reform while highlighting the need for balance between oversight, efficiency, and the unique needs of the academic research enterprise.
