The Council on Governmental Relations (COGR), representing research universities, addressed a formal letter on September 24, 2015, to the Office of Management and Budget (OMB) expressing concerns about federal agencies’ deviations from the Uniform Guidance (UG) under 2 CFR 200, which governs administrative requirements, cost principles, and audit requirements for federal awards. COGR highlighted recurrent agency-specific variations in funding announcements and award notices, particularly regarding cost sharing, indirect cost rates, and conflict of interest policies. These deviations often go unapproved by OMB and undermine the standardization and reduction of administrative burden intended by the UG. The document provides detailed examples from multiple federal agencies where requirements or encouragements for cost sharing, limitations on indirect cost rates, and inconsistent conflict of interest disclosures diverge from UG standards.
COGR urged OMB to take a more proactive oversight role, recommending the establishment of an ombudsman function to monitor and address agency deviations and maintain a transparent record of approved exceptions and their justifications. Furthermore, the organization requested a grace period for implementation of section 200.112 on conflict of interest, to allow time for harmonization and clearer guidance across agencies. While acknowledging progress with some agencies’ commitment to uniform practices and responsive actions to correct deviations, COGR emphasized the ongoing need for OMB leadership and collaboration to ensure effective, consistent, and efficient implementation of the Uniform Guidance for the research community.
