The document is an official letter from the Council on Governmental Relations (COGR), a consortium representing 160 major research universities, hospitals, and institutions in the United States, addressed to Beth Phillips at the Office of Federal Financial Management within the Office of Management and Budget (OMB). Dated February 28, 2005, the letter responds to the recently proposed federal policy on standardized terms and conditions for research and research-related grants, introduced by the Office of Science and Technology Policy (OSTP) and OMB. COGR commends the policy’s potential to significantly simplify and harmonize grant administration across federal agencies, aligning with Congressional intents for improved financial assistance management and building on years of experience with streamlining initiatives such as the Federal Demonstration Partnership.
While supporting the goal of reducing administrative burden and improving clarity in federal grant processes, COGR expresses cautious optimism and provides detailed recommendations for successful policy implementation. The letter emphasizes the need to minimize agency-specific exceptions to core grant terms, suggesting that only statutory exceptions be permitted after rigorous scrutiny. COGR also recommends establishing clear criteria and a review process for justifying any deviation from standard terms, advocating for stakeholder involvement and public transparency. Furthermore, it calls for standardization in the definitions of “research” and “research-related programs” to broaden and clarify the policy’s applicability. Overall, COGR underscores the importance of agency leadership endorsement and collaborative refinement of the policy, reaffirming its support and urging OSTP and OMB to address these points to ensure meaningful administrative reform and enhanced stewardship of federal research funding.
