The letter from Katharina Phillips, President of the Council on Governmental Relations (COGR), addresses the Office of Science and Technology Policy (OSTP) regarding the development of new business models for federally funded academic research. Representing 150 research-intensive universities, COGR expresses concern that the concept of a "business model," often rooted in commercial practice, can be misleading when applied to the not-for-profit context of university research. The letter emphasizes that universities primarily contribute new knowledge, trained individuals, and research capacity, and cautions that any changes to the existing government-university relationship should consider the longstanding social contract that underpins federal support for basic research. The correspondence highlights the need for federal agencies to manage research and development as a cohesive portfolio and stresses the importance of consistent support for research instrumentation and facilities, which have seen declining federal investment.
COGR critiques current federal cost and regulatory policies—specifically the implementation of OMB Circulars A-21 and A-110—arguing that inconsistent and sometimes arbitrary changes have strained university infrastructures and increased administrative burdens. The organization also warns against efforts to measure research impact solely through short-term or quantifiable returns, noting the unpredictable timeline and varied nature of fundamental research outcomes. Additional concerns include the proliferation of disparate administrative and electronic systems across agencies, the challenges posed by heightened audit and compliance demands, and misconceptions surrounding university-industry collaborations, advocating for recognition of the broader educational and research missions over solely commercial objectives. Ultimately, COGR calls for more balanced and equitable regulatory and cost reimbursement frameworks, greater interagency coordination, and meaningful dialogue to sustain and enhance the nation’s research enterprise amidst evolving societal and scientific needs.
