The Council on Governmental Relations (COGR), representing major research universities, submitted a letter to the Office of Management and Budget (OMB) on September 24, 2015, highlighting widespread deviations by federal agencies from the Uniform Guidance (UG) codified in 2 CFR 200.107. The letter details specific examples of federal funding announcements and award notices that impose requirements or expectations—particularly concerning cost sharing, indirect (F&A) cost limits, and conflict of interest policies—that exceed or diverge from the UG’s standards, often without evidence of formal OMB approval. COGR notes that while member institutions have engaged individually with agencies to resolve these matters, the prevalence of such deviations necessitates coordinated action and escalated their concerns to OMB.
The communication requests that OMB play a more active oversight role to ensure consistent and proper implementation of the UG, proposing the establishment of an ombudsman function to systematically review, track, and justify exceptions. Additionally, COGR emphasizes the administrative burden and confusion resulting from non-uniform application of conflict of interest policies and recommends a grace period for UG §200.112 to allow for standardized implementation. While acknowledging productive dialogue and some agency responsiveness to concerns, COGR stresses the importance of ongoing vigilance to reduce administrative burden and achieve greater consistency and fairness in federal research funding practices.
