The document summarizes updates discussed at the June 2016 COGR meeting pertaining to unresolved issues with the Uniform Guidance (UG), as communicated in a March 16 letter from the Council on Governmental Relations (COGR) to the Office of Management and Budget (OMB). Key topics include procurement rules—COGR is requesting an extension of the grace period and possible reopening of rulemaking—and considerations around conflict of interest, particularly clarifying and harmonizing definitions. OMB is open to reviewing technical corrections regarding several areas, including subrecipient monitoring, the 1.3% UCA and REUI weighting factor, and the application of indirect cost rates to for-profit and foreign subrecipients, acknowledging institutional challenges in rate negotiation and compliance.
Further, COGR urged elimination of the protracted DS-2 approval process, and OMB has indicated a willingness to engage federal partners to evaluate this change. Discussions also covered promoting uniform research terms and conditions, with OMB agreeing to support greater uniformity where feasible, though not currently considering a uniform 120-day grant closeout. Additionally, the codification of guidelines and FAQs will continue via the Single Audit Compliance Supplement. Persistent concerns about cost sharing and Facilities & Administrative (F&A) deviations in funding announcements were raised, prompting a recommendation for a formal process where specific instances can be reviewed and resolved in coordination with OMB, even though establishing an OMB ombudsman position was deemed unfeasible at this time. The overall spirit of the meeting was collaborative, seeking to clarify federal policy and streamline research administration processes for academic institutions.
