Financial Management

COGR Submits Comments to GSA Regarding the Transition of the Federal Audit Clearinghouse

COGR provided comments to the GSA regarding the transition of the Federal Audit Clearinghouse from the U.S. Census Bureau to the GSA.

COGR Submits Comments to NSF on the Draft PAPPG (NSF 23-1)


Posted December 15, 2021

COGR Submits Comments to DoEd on HEERF Data Collection Form Federal Register Notice

Posted November 8, 2021

COGR Submits Comments to OMB on 2 CFR 200 Subpart F - Audit Requirements Appendix XI - Compliance Supplement 2021

COGR Submits Letter to DoEd in Response on HEERF I, II, & III, Data Collection Form

Posted August 12, 2021

COGR Writes to NSF to Address Concerns on Recent Audit Findings Related to Application of the F&A Cost Rate

Posted on May 14, 2021

F&A Cost Rates and Reimbursement Pressures Under COVID-19: Maintaining a Fair and Reliable System

Posted April 21, 2021

Research Impact Under COVID-19: Financial Crisis and the "Pandemic Normal"

Posted August 25, 2020

Furlough Programs and Implications for Financial Research Compliance (Updated)

Posted May 8, 2020

COGR Letter to NIFA Regarding the Reimagining NIFA Initiative

Posted January 23, 2020

COGR Letter to OMB on 2019 Compliance Supplement

Posted July 26, 2019

COGR Releases "Excellence in Research: The Funding Model, F&A Reimbursement, and Why the System Works"

Posted April 12, 2019

Additional F&A Resources

COGR Submits Letter to OMB on Payments/Reimbursements under Single Audit

*As Sent to COGR Listserv 10/20:


COGR has sent the following letter to Gilbert Tran at OMB.


Some of your institutions have been challenged in recent single audits. Specifically, a new auditor position is that prior to billing a federal sponsor for reimbursement, the institution must have evidence that the institution’s payment to the vendor has been cleared by the institution’s bank. This is in conflict with existing policy per 2 CFR Part 200.305(b): … payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.


Public Comments are due October 31, 2017. The COGR letter to OMB and Mr. Tran is attached. We encourage you to submit a letter if this issue is a concern at your institution. A letter in support of the COGR letter, with any examples specific to your institution, is appropriate.


DIRECTIONS FOR SUBMITTING LETTERS:  As specified in an August 14th Federal Register Notice, comments should be submitted to Gilbert Tran at Include “2 CFR Part 200.305, Subpart F-Audit Requirements, Appendix XI-Compliance Supplement-2017” in the subject line and the full body of your comments in the text of the email and as an attachment. Include your name, title, organization, postal address, telephone number, and email address in the text of the message. Comments may also be sent through


This is an important issue to a number of institutions and comment letters from your institution, in addition to the COGR letter, will elevate the unease around this issue. Contact David Kennedy at if you have questions on how to best craft your concerns to OMB.

Associations Oppose Cuts to NIH Budget

COGR joined with over 100 other organizations Monday on a letter to Office of Management and Budget Director Mick Mulvaney and Health and Human Services Secretary Tom Price to oppose the proposed cuts to NIH funding and facilities and administrative (F&A) costs in the Administration's FY18 budget. 

Among other things, the letter states that "If the Administration’s proposal to reduce NIH support for F&A moves forward, it will make research unaffordable for many institutions and ultimately lead to less research carried out across the country", and that "the economic impact could also be significant; communities will lose jobs, and the country will fall behind as our foreign competitors forge ahead in medical research. These consequences will hurt patients, scientists, and all Americans."

COGR Letter to Mulvaney and Price Objecting to NIH and F&A Budget Cuts

Posted June 12, 2017

At OMB Request: Letter to Identify OMB Actions to Reduce Administrative Burden

Posted April 17, 2017

COGR Submits Letter to OMB to Address 2017 Compliance Supplement and Securing Student Information

The National Association of College and University Business Officers (NACUBO), EDUCAUSE, the National Association of Student Financial Aid Administrators (NASFAA), and COGR write to OMB to address a proposed new section to the 2017 Compliance Supplement: Securing Student Information, Student Financial Aid (SFA) Cluster.

Click here.

F&A Survey Results Available to COGR Membership

Click here.

Finances of Research Universities - June 2014

“Finances of Research Universities” describes the financial landscape of research universities and calls for active collaboration among all stakeholders to address financial risks to the research enterprise in a productive manner.

Full Report


An Analysis of the DCA Best Practices Manual - COGR Interpretations

Click here to view the paper.

Faculty Appointments at Academic Medical Centers - A Focus on University and Veterans Joint Appointments

Click here to view

How to Conduct Non-Federal Stem Cell Research Without Violating the Federal Stem Cell Funding Prohibition

How to Conduct Non-Federal Stem Cell Research Without Violating the Federal Stem Cell Funding Prohibition
By Robert J. Kenny, Jr. [Medical Research Law and Policy Review, 2005]

National Institutes of Health Stem Cell Resource Web Site


November 13, 2015: COGR submits letter to OMB with Proposed Modifications to the Utility Cost Adjustment Methodology used in F&A Rate Proposals. Click here to read the letter.


COGR Implementation and Readiness Guide for OMB Uniform Guidance is available. 

November 13, 2015: COGR Submits Letter to OMB on Utility Cost Adjustment Methodology

Click here

COGR Guide to 2 CFR 200.430 Compensation-Personal Services

Click here for the Guide.

COGR Readiness Document - Uniform Guidance -

Click here for the Guide. If interested in a Word version of the Guide, please contact David Kennedy.

COGR Response to Grants Reform

OMB Advance Notice of Proposed Guidance, April 2012. Click here for the letter.

COGR Proposal to the A-21 Task Force

Discontinuation of the Effort Reporting Requirement, November 2011. Click here for the proposal.

COGR Survey of F&A Rates

Contact COGR for Historical F&A Rates and Components Data Tables

COGR Response to NIH RFI

 Input on Reduction of Cost and Burden Associated with Federal Cost Principles for Educational Institutions (OMB Circular A-21), July 2011.  Click here to view the Letter and here to view the Attachment.

Improving the F&A Rate-Setting Process with the Federal Government

Click here to view the Policy Paper. 

Regulatory and Financial Reform of Federal Research Policy - Recommendations to the NRC

Click here to view the Recommendations.

Federal Funding Agency Limitations on Cost Reimbursement: A Request for Consistency in the Application of Federal Guidelines

Click here to view the Policy Paper
Click here to view the Appendix

Compensation, Effort Commitments and Certification

Click here to view the full document.
Click here to view the Executive Overview.

Cost and Facility Issues in Conducting Stem Cell Research

Summary of June 2005 COGR Meeting Discussion