The Council on Governmental Relations (COGR), representing over 190 research universities and affiliated institutions, submitted a formal response to the White House Office of Management and Budget (OMB) on February 13, 2015, regarding the implementation of Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). COGR commended the OMB and the Council on Financial Assistance Reform (COFAR) for their transparent, inclusive process and recognized the Uniform Guidance as a substantial step toward grants reform and reducing administrative burdens. However, COGR identified eight high-priority areas requiring further modification to ensure effective and equitable implementation. Their recommendations were developed in consultation with member institutions that collectively conduct over $60 billion in federally sponsored research annually.
The eight priority concerns addressed were: clarifying conflict of interest policies to exclude scientific conflicts from procurement-related rules; establishing “Safe Harbors” for subrecipient monitoring to avoid duplicative audits; amending procurement standards to allow higher micro-purchase thresholds and institutional flexibility consistent with established internal controls; standardizing federal grant closeout periods to 120 days for financial and performance reporting; streamlining and potentially eliminating the DS-2 cost accounting disclosure requirement for universities; clarifying policies on tuition remission as a fringe benefit; ensuring a more equitable approach for utility cost adjustments in indirect cost rate proposals; and urging stronger OMB leadership in continuously refining and harmonizing federal grants policy. COGR emphasized that these adjustments would reduce unnecessary administrative costs, reinforce accountability and fairness, and support research productivity, ultimately facilitating more efficient and effective delivery of federal programs. The organization reiterated its commitment to partnership with OMB, COFAR, federal agencies, and other stakeholders to achieve the overarching goal of maintaining integrity while minimizing burdens across the research enterprise.
