Managing Externally Funded Research Programs: A Guide to Effective Management Practices

The Council on Governmental Relations (COGR) is an association of leading research institutions. One of COGR’s important activities is helping to develop policies and practices in research and training that reflect the mutual interest and separate obligations of research institutions and federal and other sponsoring agencies. This web-based guide is illustrative of such activity.

This guide may be used by institutions to help review their management systems and internal controls. Readers must recognize that while general principles of effective management are stable and consistent, rules and regulations imposed by external sponsors are subject to change. This guide does not purport to set standards; it only suggests effective management practices and indicators to test those practices. COGR periodically updates and revises this document. However, at any point in time, this document should be considered in the light of administrative and regulatory changes made subsequent to its latest revision date.

This document was originally published in April 1989. This is its fifth revision. Each edition updates the information through additions and, as appropriate, deletions to reflect the current effective practices with some related indicators.   Sometimes new principles are added as management practices expand in response to changes in research and sponsored projects and new regulations. This edition includes a new principle addressing the challenges of international issues in sponsored projects. As sponsored projects become more collaborative and those collaborations involve the global community and questions of export controls, embargos, and visas affect the sponsored projects enterprise, international transactions have become more complex. A new principle bringing these various practices together is appropriate at this time.
This edition of the guide begins with a discussion of a comprehensive compliance system that sets the framework for all the principles that follow. The discussion calls directly for an institutional commitment to compliance. A comprehensive compliance system reflects new emphasis on the value of looking at compliance as a systemic enterprise rather than discrete practices in response to specific regulations. Thus, while compliance will take a different form in meeting financial, administration, or performance requirements, all these activities reflect a culture of compliance. In this context, this edition is entirely reorganized within and among the basic principles.

All previous versions have been published on paper. In order to provide greater access and streamline the process of critical updates, the “publication” of this guide is online. This approach allows a listing at the end of each section of web links to the principal regulatory documents and materials. Generally the web links are to main or home pages and the user will need to search for a specific document. These external links will be checked periodically. Users may print each section individually, or the entire document as single file. If a user prints this document, the external links should be compared with the online version to ensure they are accurate.< A companion, paper guide to the Principles (only) is available from COGR. It is intended to serve as an overview of effective management practices.

COGR appreciates the contribution of all its members in bringing new challenges and strategies for addressing them to the attention of their colleagues across the country. The members of the working group availed themselves of this expertise. The working group’s dedication and commitment to a thoughtful and thorough revision benefits all the members.

Mark Brenner, Indiana University-Indianapolis, Chair
Susan Camber, University of Washington
Kathleen Irwin, University of Wisconsin
Jamie Lewis Keith, Massachusetts Institute of Technology
Julie Norris, emerita, Massachusetts Institute of Technology
Suzanne Polmar, Yale University
David Wynes, University of Iowa
Carol Blum, COGR staff

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