The April 2012 letter from the Council on Governmental Relations (COGR) to the Office of Management and Budget (OMB) articulates research universities’ perspectives and recommendations regarding proposed federal grants reform. Representing over 180 major research institutions, COGR underscores the importance of grants reform that reduces unnecessary administrative burdens and costs, enhances research productivity, and upholds principles of fairness and accountability without sacrificing compliance standards. The organization expresses appreciation for the reform efforts thus far but highlights a series of critical areas not addressed in the Advanced Notice of Proposed Guidance (ANPG), including arbitrary cost reimbursement policies, inconsistencies in Facilities and Administrative (F&A) rate negotiations, problematic cost sharing requirements, burdensome regulatory compliance, and uneven application of federal requirements among agencies.
COGR provides detailed responses to proposed reforms in audit requirements, cost principles, and administrative guidelines. The council largely supports efforts to streamline and clarify compliance measures, such as permitting more direct charging of certain administrative or project-specific costs, rationalizing audit processes, and expanding the utility cost adjustment. However, it opposes flat or discounted F&A rates, consolidation of all cost principles into one document across all entity types, and certain measures that risk shifting additional costs onto research institutions. COGR also warns against unchecked agency discretion that could increase compliance complexity and calls for OMB to enforce uniform standards and processes. Throughout the letter, COGR emphasizes the need for constructive federal-academic collaboration, transparent negotiations, and regulatory frameworks that sustain the research enterprise while maintaining accountability and efficient stewardship of public funds.
