The COGR October 2016 Update provides a comprehensive overview of major regulatory, policy, and audit developments affecting the U.S. research community, with a particular focus on procurement standards, indirect cost (F&A) recoveries, grant closeout practices, and compliance requirements. Key regulatory updates include an expected extension of the procurement standards implementation grace period to FY2019, ongoing updates to Uniform Guidance FAQs as solicited by OMB and COFAR, and a detailed review of recent developments in F&A rate negotiations and survey results. Significant attention is given to a DOJ settlement over F&A cost recovery, emphasizing the complexities of applying correct indirect cost rates for research conducted in third-party facilities, and the broader implications for aggregate F&A charges under federal research grants.
Further, the Update addresses policy and procedural developments from federal agencies such as HHS, NIH, DOE, and NARA. It highlights HHS's initiatives on grants closeout and policy statement revisions, ongoing efforts for equitable cost treatment of off-campus research centers by NIH, and analysis of the GAO’s report calling for stronger controls in indirect cost rate-setting. The Update also discusses the impact of the new CUI rule from NARA, the DOE’s waiver process for foreign national approvals, and new contractual rules regarding data rights and sick leave requirements. With respect to audit and compliance, it covers the release of the 2016 Single Audit Compliance Supplement, acknowledges unresolved issues around audit requirements for the Student Financial Aid Cluster, and references notable findings in recent NSF OIG audit reports. Policy debates on international access to medicines and the Bayh-Dole Act's march-in rights are reviewed, as is the continued federal effort to reduce administrative burden and streamline research regulations, including Congressional hearings and newly proposed legislation. Collectively, the document underscores COGR’s active engagement with federal agencies, advocacy efforts for the research community, and commitment to keeping members informed about evolving regulatory and compliance landscapes.
