The Council on Governmental Relations (COGR), representing major research universities, provides a detailed response to the National Academy of Sciences’ report on optimizing federal research regulations. COGR broadly supports recommendations aimed at streamlining grant application processes, harmonizing regulations across federal agencies, and reducing administrative burdens—particularly through uniform proposal and reporting formats, just-in-time submission of supplementary materials, and central repositories for required documentation. They advocate for amendments to existing regulations to enable greater efficiency and support modifying subrecipient monitoring requirements to rely on existing Single Audit processes, thus reducing duplicative oversight.
COGR endorses harmonization of conflict of interest policies and human subject protections but opposes a federally mandated single Institutional Review Board (IRB), citing inadequate evidence for efficacy and concerns about feasibility for multi-site and social science research. Additionally, COGR calls for minimizing regulatory burdens in animal research oversight and supports more risk-based review processes. In financial management, the organization supports raising procurement thresholds and eliminating obsolete requirements like the DS-2 report, arguing they are no longer useful. Importantly, COGR backs the formation of a Research Policy Board to serve as a public-private regulatory forum, but stresses the need for broad university representation and meaningful government authority to effect change. They argue that such reforms should be guided by principles of regular retrospective review, risk management, harmonization, and effective oversight, while cautioning against additional university sanctions beyond those already provided by funding agencies. COGR’s overall position is collaborative, seeking ongoing engagement with policymakers while emphasizing practicality and reduction of unnecessary regulatory and administrative barriers in academic research.
