The document is a formal letter from the Council on Governmental Relations (COGR) to Mr. Mark Reger, Deputy Controller at the White House Office of Management and Budget (OMB), dated April 17, 2017. Representing 190 research universities and institutions that collectively perform over $60 billion in federally funded research annually, COGR offers a series of policy recommendations intended to substantially reduce the administrative burden placed upon grantees without compromising efforts to prevent fraud, waste, or abuse. The letter is structured into two main sections: immediate actions and additional opportunities for OMB involvement.
In the immediate actions, COGR urges OMB to rescind outdated reporting and disclosure requirements, delay or replace newly implemented procurement and conflict-of-interest rules that have proven confusing and inefficient, facilitate grant closeout practices to avoid excessive reconciliation of minor balances, and eliminate unnecessary duplicative reviews by pass-through entities. Further, the letter calls for clarification of accounting rules—particularly concerning software capitalization—and the rescinding of burdensome disclosure statements. In additional opportunities, COGR proposes improved OMB oversight of agency reporting systems, advocates for a uniform 120-day grant closeout period, and suggests ways to mitigate audit burdens, especially regarding Department of Education requirements. Overall, COGR’s recommendations emphasize regulatory streamlining, clearer guidance, consistent application across federal agencies, and improved efficiency in federal grant administration, aligning with the administration’s goal to reduce unnecessary administrative complexity for research institutions.
