Latest News

COGR's Survey on Research Institutions' Experiences with DoD Policy for Risk-Based Security Reviews of Fundamental Research (FR) (Responses Due 4/5/24)

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COGR Virtual Meeting Materials

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COGR Joins a Multi-Association Response to the Request for Comments to Docket Number DoD–2023–OS–0063 / Regulatory Identifier Number (RIN) 0790–AL49, “Cybersecurity Maturity Model Certification (CMMC) Program”

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COGR Responds to EPA Scientific Integrity Policy Draft for Public Comment (EPA-HQ-ORD-2023-0240; FRL-10973-01-ORD)

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Update Now Available: Quick Reference Table of Current & Upcoming Federal Research Security Requirements

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COGR's February 2024 Update

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Update Now Available (V.4): COGR Matrix of Science & Security Laws, Regulations, and Policies

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COGR's Questionnaire on HHS-OIG Survey (Please complete by 2/23)

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COGR, EDUCAUSE, and AAU Submit Joint Comment Letter to GSA on Cyber Threat and Incident Reporting & Information Sharing (FAR 2021-017)

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COGR Submits Comments to NIST on Draft Interagency Guidance Framework for Considering the Exercise of March In Rights

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COGR Comments & Extension Request to Office of Evaluation and Inspections, OIG, HHS on NIH Monetary Donations that Support Research Survey (OEI-03-22-00570)

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2024 Call for Nominations - COGR Board of Directors

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COGR Submits Joint Association Response for NSF Public Access 2.0

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COGR Position Announcement: Director for Research Security and Intellectual Property

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COGR Joins a Multi-Association Extension Request to NIST for the RFI Regarding the Draft Interagency Guidance Framework for Considering the Exercise of March-In Rights (Docket No.: 230831-0207)

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COGR Responds to NIH Request for Information (RFI) on Proposed Guidance to Assured Institutions on Cephalopod Care and Use (NOT-OD-23-176)

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COGR's December 2023 Update

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COGR is Moving! Update Your Institutional Records by January 1, 2024!

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COGR Submits Comments to ORI on Public Health Service Policies on Research Misconduct Notice of Proposed Rulemaking

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COGR Joins C4IP in Urging the Biden Administration to Oppose the Proposed WTO IP Waiver for Covid-19 Therapeutics and Diagnostics

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COGR Responds to OMB's NPRM on Guidance for Grants & Agreements "Uniform Guidance"

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COGR Submits Joint Association Request for Extension of Comment Period for Oct. 6, 2023, NPRM on PHS Policies on Research Misconduct (88 FR 69583)

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COGR Responds to Request for Information (RFI) on an Update to the Current OLAW Guidance Disclaimer

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COGR Responds to RFI on Potential Changes to the Policies for Oversight of Dual Use Research of Concern (DURC) and the Potential Pandemic Pathogen Care and Oversight (P3CO) Policy Framework

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Analysis of NIST Safeguarding International Science Research Security Framework

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COGR Responds to RFI on Flexibilities for Streamlining IACUC Review of Protocols and Significant Changes (NOT-OD-23-152)

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COGR Responds to Proposed Amendments to the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules (NIH Guidelines) (88 FR 54332)

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Session Materials Available: Workshop on Compliance with Research Security Requirements and the Associated Cost of Compliance Survey

 

On September 27, 2023, COGR is hosted a virtual, interactive workshop to provide an opportunity for members to share information on institutional efforts to comply with research security requirements and how to assess associated costs and institutional burden.  The workshop was led by COGR directors and members of COGR’s four committees.

NSTC is expected to finalize its model disclosure forms and research security program standards this autumn, and upon their issuance, COGR will initiate Phase II of its research security cost survey.  This workshop provided a forum for institutions to discuss their compliance strategies, learn about the methodology of the Phase II survey, and consider the resources they will need to implement research security programs and additional disclosure requirements.  The workshop begins with an overview of current requirements and the Phase II survey, and then participants joined break-out rooms to discuss how their institutions are addressing certification mandates, training requirements, security program structures and associated costs and administrative burden. 

Institutions that participated in the Workshop will be highly encouraged to complete the Phase II Survey.  Phase II will be initiated later this autumn, and COGR will follow-up with workshop participants at the time to determine if they will participate.  

Questions and topics of interest may be sent in advance of the session to Kristin West at kwest@cogr.edu.

Workshop materials include:

Session recording (log in required)
Slide Presentation
Institutional Resources on Research Security (log in required)

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Preparing for a Government Shutdown: A List of Institutional Considerations

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COGR's September 2023 Update

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COGR, APLU, and AAU Submit Joint Response to Request for Public Comment on Common Disclosure Forms for the Biographical Sketch and Current and Pending (Other) Support for Use in Submission of Research Applications

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COGR's October 26-27, 2023 Meeting Preliminary Agenda Now Available

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COGR's October 26-27, 2023 Meeting in Washington DC: Registration Now Open

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COGR Submits Response to Congressional RFI on Federal Regulation of CBD Products

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2023 F&A Survey Reports

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COGR's 2022-2023 Year In Review

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COGR Supports EDUCAUSE Response to FAR: Prohibition on a ByteDance Covered Application

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COGR Analysis on Executive Order 14104 “Federal Research and Development in Support of Domestic Manufacturing and U.S. Jobs”

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COGR Joins Multi-Organization Statement on Addressing the Shortage of Long-Tailed Macaques for Research

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COGR and AAU Team to Submit Input on the Ongoing Discussion Regarding NIH's Levers to Catalyze Technology Transfer

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COGR Responds to OLAW's Request for Information (RFI) on Clarification of Animal Activities Exempt from PHS Policy Requirements for IACUC Review (NOT-OD-23-119)

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COGR Responds to OMB's Request to Provide Data-driven Evidence to Support Modifications to 2 CFR Chapter 2, Part 200 (2 CFR 200) of the Uniform Guidance (UG)

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COGR Submits Comments in Response to NASA’s RFI: Freedom of Information Act (FOIA) Disclosures: Proposed NASA Grant Application Marking for FOIA Disclosure-Exempt Material Published in the Federal Register

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Overview of Department of Defense Statement on Countering Unwanted Foreign Influence in Department-Funded Research Institutions of Higher Education

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COGR Submits Joint Association Response to OMB on Comment Request; iEdison System

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COGR Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603)

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COGR's June 2023 Update

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COGR Supports EDUCAUSE Response to NIST's Cybersecurity for R&D Request for Comment

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COGR Responds to NSF's Request for Response to Dear Colleague Letter: Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization

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COGR Responds to the National Science Foundation Proposal/Award; Information— NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 24-1) Comment Request

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June 2023 Meeting Materials

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COGR Participates in Joint Association Response to Comment Request; Agency Information Collection Activities; Submission to OMB for Review and Approval; Foreign Gifts and Contracts Disclosures

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COGR Responds to OSTP Request for Information: NSPM 33 Research Security Programs Standard Requirement (88 FR 14187)

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COGR's May 2023 Update

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Results from the COGR Survey on the Cost of Complying with the New NIH DMS Policy

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Preliminary Agenda Now Available: COGR's June 8-9, 2023 Meeting

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COGR, AAU, and AUTM Submit Joint Association Letter on COVID-19 Diagnostics and Therapeutics: Supply, Demand, and TRIPS Agreement Flexibilities

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COGR Is Now On LinkedIn

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COGR's Response to Request for Information (RFI) on Update to NOT-OD-05-034 Guidance on Prompt Reporting of Noncompliances to OLAW (NOT-OD-23-063)

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COGR Responds to the NIH Plan to Enhance Public Access to the Results of NIH-Supported Research [NOT-OD-23-091]

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COGR's Response to Request for Information (RFI): Re-envisioning U.S. Postdoctoral Research Training and Career Progression within the Biomedical Research Enterprise [NOT-OD-23-084]

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Registration Now Open: COGR's June 8-9, 2023 Meeting in Washington D.C.

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COGR Submits Joint Association Request to OSTP for Listening Sessions on Research Security Programs Standards

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COGR Publishes "Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts"

 

COGR has published a new report:  “Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts.”  Ensuring the objective conduct of research, free from bias, is one of a research institution’s most important duties, as well as a key focus for federal research funding agencies.  This report discusses both personal financial and institutional conflict of interest issues in the context of situations in which these conflicts most commonly occur, including consulting, licensing, and clinical studies.  The report also addresses federal research funding agencies’ recent focus on the intersection of conflicts and malign foreign influence, and includes key regulations and guidance documents, points institutions should consider in evaluating scenarios, and case studies that can be used to foster discussion and support educational efforts. 

“Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts” complements COGR’s 2021 publication:  "Principles for Conflict of Commitment Concerns in Academic Research." 

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COGR's March 2023 Update

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COGR Responds to OMB's RFI: Uniform Guidance (2 CFR 200)

COGR has posted its Letter to OMB, in response to OMB’s Request for Information (RFI) – Uniform Guidance. We expect OMB to review responses from all stakeholders and publish proposed revisions to the Uniform Guidance later in 2023. Contact Krystal Toups at ktoups@cogr.edu or David Kennedy at dkennedy@cogr.edu if you have comments or questions

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COGR Posts DRAFT Response to OMB (Uniform Guidance)

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COGR's Joint Response to NASA’s “New Conflict of Interest and Conflict of Commitment Policy for Recipients of NASA Financial Assistance Awards”

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COGR Submits Comments in Response to ANPRM Entitled Wild and Exotic Animal Handling, Training of Personnel Involved with Public Handling of Wild and Exotic Animals, and Environmental Enrichment for Species

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Now Available: February 28-March 3, 2023 COGR Virtual Meeting Presentations & Session Recordings

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COGR's 2 CFR 200 "Uniform Guidance" Resource Page

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COGR Signs on to Multi-Association Letter to DoEd Regarding Foreign Gift & Contract Disclosures (ED-2022-SCC-0159)

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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.

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COGR Requests a 30-Day Extension to Respond to OMB's RFI

COGR requested a 30-day extension to respond to OMB’s RFI regarding updates to 2 CFR Part 200, Uniform Guidance.

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COGR Releases NIH DMS Readiness Guide Chapter 4 Part II - Budgeting and Costing: Project-Based and Institutional Cost Considerations

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COGR's February 2023 Update

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COGR Responds to the Request for Information: Clinical Research Infrastructure and Emergency Clinical Trials

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COGR Responds to HHS Notice of Proposed Rulemaking “Confidentiality of Substance Abuse Disorder Patient Records”

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2023 Call for Nominations - COGR Board of Directors

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Registration Now Open: COGR's February 28-March 3, 2023 Virtual Meeting

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NIH Data Management and Sharing (DMS) Policy Readiness Webinar on January 17

 

The final countdown approaches for the January 25, 2023, implementation of the NIH Data Management and Sharing (DMS) Policy. On January 17, COGR hosted Michelle Bulls, Director, Office of Policy for Extramural Research Administration (OPERA), NIH, to discuss the new policy as the community prepares. This webinar covered updates from NIH, presented budgeting issues recently released in Chapter 4 Part I of the COGR NIH DMS Readiness Guide, and other topics of interest. 

PowerPoint Presentation

Webinar Recording (log in required)

For additional information and resources on the NIH Data Management and Sharing Policy, please visit COGR’s Resource Page and the COGR NIH DMS Readiness Guide, including the recently released Chapter 4 Part I:  COGR Review of the Final NIH Policy for Data Management and Sharing:  Budgeting and Costing

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COGR Announces Matt Owens as Incoming COGR President

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COGR's Review of the Final Policy on Data Management and Sharing: Budgeting and Costing (Readiness Guide Chapter 4 Part I)

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COGR Submits Letter to HHS on Timely Establishment of Indirect Cost and Fringe Benefit Rate Agreements

COGR submitted a letter to Mak Karim, the National Director for Cost Allocation Services at the U.S. Department of Health and Human Services. In the letter, COGR requests assistance to facilitate improvements in the speed of the review and approval process associated with indirect cost and fringe benefit rates.

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COGR Submits Letter to Dr. Tabak on the NIH Modular Grant Application and Award Process

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COGR's November 2022 Update

 

NOVEMBER 2022 Update Topics:

NIH Data Management and Sharing Policy: Cross Cutting Issues

     NIH Data Management and Sharing (UPDATE)

     NIH Data Management & Sharing Panel: Thursday Session at October COGR Meeting (NEW)

     Cost Impact: NIH Data Management & Sharing Policy Survey (UPDATE)

Science & Security: Cross Cutting Issues

     Research Security & Cost of Compliance: REPORT IS AVAILABLE (NEW)

     NSPM-33 and CHIPS & Science Act Research Security Provisions (UPDATES)

     NSPM-33 Implementation Guidance Disclosure Requirements & Standardization Forms: Thursday Session at October COGR Meeting (NEW)

     COGR Submits Comments to NSF on Common Disclosure Forms (NEW)

     COGR Joins Higher Ed. Association Letter to NSF on Standard Disclosure Forms (NEW)

     COGR 9/23 Webinar “Digging into DPIs” (UPDATE)

     COGR Presentation to National Academies (UPDATE)

     SBIR/STTR “Foreign Risk Management” Provisions (NEW)

     NASEM Report on Protecting Critical Technologies for National Security in an Era of Openness and Competition (NEW)

Research Security & Intellectual Property (RSIP)

     RSIP COGR Committee Holds Informal Discussion with DOD (NEW)    

     New Export Control Rules on End Users and Semiconductors (NEW)

     March-In Calls Continue (UPDATE)

Research Ethics & Compliance (REC)

     Request for Information (RFI) Regarding Cannabis Research (UPDATE)

     Responsible and Ethical Conduct of Research Changes (NEW)

     Animal Research (UPDATE)

     Human Subjects Research Certificates of Confidentiality (NEW)

     Recent FDA Guidance Document on Expanded Access (NEW)

     OSTP RFI: Clinical Research Infrastructure and Emergency Clinical Trials (NEW)

     ORI RFI Regarding Research Misconduct Regulations (UPDATE)

     OSTP Webinar on Open Access Policy (NEW)

     Conflict of Interest (COI) Publication (UPDATE)

Costing & Financial Compliance (CFC)

     F&A Cost Rate Negotiations and Engagement with Cost Allocation Services (ONGOING)

     COGR F&A Cost Rate Survey, Revisited (NEW)

     Cost of Compliance Studies: Science & Security and Data Management & Sharing (ONGOING)

     Costing & Financial Compliance: Other Issues (NEW & ONGOING)

Contracts & Grants Administration (CGA)

     NSF Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 23-1)

     Grant & Contract Administration: Other Issues (UPDATES)

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Research Security and the Cost of Compliance – Phase I Report, Disclosure Requirements Now Available

COGR conducted Phase I of the survey described in this report to quantify the considerable time and resources (financial and otherwise) that research institutions have invested (or will invest) to achieve compliance with the Disclosure Requirements.  COGR is providing this Phase I report to research institutions and federal research funding agencies in the hope that it will both encourage and facilitate discussions of equitable cost allocation, as well as how “return on investment” (ROI) should be considered and measured.

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Chapter 3 Part II of COGR's NIH DMS Readiness Guide: Roles and Responsibilities (Excel Download) Now Available

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COGR Submits Comments to the Small Business Administration in Response to Federal Register Notice

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Joint Comments from AAU, AAMC, APLU, ACE and COGR to NSF on Standard Disclosures

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COGR Letter for Request for Comment for Common Disclosure Forms

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COGR and ARIO Joint Response to ORI RFI Research Misconduct Policies

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NSPM-33 Implementation Guidance Disclosure Requirements Standardization Talking Points for Institutions

The proposed Standardized Disclosure Forms were released for public comment on August 31, 2022. This document includes critical themes for institutions to consider. These themes were included in the COGR response

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COGR October 2022 Meeting Materials

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COGR and AAMC Submit Joint Comment Letter to NIH on Cannabis RFI (NOT-AT-22-026)

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COGR & the Association of Research Libraries Present: Gearing Up for January 2023: Institutional Strategies for Implementing the NIH Data Management & Sharing Policy

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Digging Into DPIs (Digital Persistent Identifiers) 9/23 Webinar Materials

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Overview of the NSPM-33 Standardization Disclosure Forms for the Common Biographical Sketch and Current and Pending (Other) Support 9/23 Webinar Materials

The highly anticipated Standardize Disclosure Forms were released on August 31, 2022 for public comment. Section 4(b)(vi) of NSPM-33 directs that “agencies should standardize forms for initial disclosures as well as annual updates…and should provide clear instructions to accompany these forms and to minimize any associated administrative burden”. This webinar provides an overview of the standardized disclosure forms and associated attributes highlighting key considerations for institutions.

Speakers for this webinar are Pamela Webb, Associate Vice President for Research, University of Minnesota; Jeffrey Friedland, Associate Vice President, Research Administration; University of Delaware; Craig Reynolds Assistant Vice President for Research - Sponsored Projects University of Michigan; and Krystal Toups, Director, Contracts & Grants Administration. This webinar provides information on how institutions can engage and provide comments by October 31, 2022. 

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COGR September 2022 Update

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COGR Matrix of Laws, Regulations, and Policies Regarding Science & Security

COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security.  The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy (e.g., National Presidential Security Memorandum 33, CHIPS and Science Act of 2022); (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies.  The chart will be updated as new laws, policy and guidance are published. 

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COGR's Science & Security Resource Page

The United States government’s focus on inappropriate foreign influence on federally funded research has resulted in an evolving legislative and regulatory environment that research institutions rank as a top compliance concern. Under the leadership of the Office of Science and Technology Policy, federal research funding agencies have/will issue researcher disclosure and research security program requirements in compliance with National Security Presidential Memorandum 33 and legislative requirements, including the FY 2021 National Defense Authorization Acts and the recent CHIPS and Science Act. COGR has developed this Science and Security webpage to provide resources and analysis to assist institutions in navigating requirements in this area. Resources are grouped under the subject-matter headings below, and the page will be updated as existing requirements are clarified and new mandates emerge.

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Register for COGR's October 20-21, 2022 Meeting in Washington D.C.

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COGR Submits Comments to OHRP in Response to HHS-OASH-2022-0011 "Use of a Single IRB for Cooperative Research" Draft Guidance

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Multi-Association Follow Up Letter to DoEd on Section 117

This letter provides comments from the American Council on Education, Association of American Universities, Association of Public and Land-grant Universities, and COGR expressing concerns regarding Dept. of Education requirements under Sec. 117 of the Higher Education Act of 1965. 

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COGR Releases NIH Data Management Implementation Roles & Responsibilities: Considerations for Institutions

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Digging Into DPIs Webinar - Registration Open (Rescheduled to 9/23)

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Looking at the CHIPS on the Table Webinar Materials

The CHIPS and Science Act of 2022 is expected to have a major impact on numerous facets of the U.S. science and technology landscape, including manufacturing, support of innovation, STEM education, promotion of more inclusive and diverse research and research settings, along with additional efforts aimed at increasing research security. This COGR webinar provides members which an early look at the new Act, with a particular focus on the new research security provisions, agency authorizations and potential new STEM training and research opportunities.    

Presentation Slides

Recording (Log in required)

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Technology Transfer in U.S. Research Universities: Dispelling Common Myths (Updated August 2022)

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COGR Releases "Biennial Year in Review: 2020-2022"

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COGR Submits March-In Letter to HHS Secretary Becerra on Prescription Drug Pricing

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COGR Letter of Support for SACHRP’s Efforts to Redefine “Engaged in Research”

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COGR Submits Comments to OMB Regarding the 2022 Compliance Supplement

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COGR's June 2022 Update

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COGR Submits Comments in Response to NIH Guide Notice NOT-OD-22-131 Regarding Protecting Privacy When Sharing Human Research Participant Data

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

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COGR May 2022 Update

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COGR Submits Comments to USDA on Proposal Rule on Standards for Birds Not Bred for Use in Research Under AWA

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COGR Submits Comments to NASA on T&C's Affecting Procurement

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COGR Submits Response to NIH on Suggestions on the Draft NIH Chief Officer for Scientific Workforce Diversity Strategic Plan for FY 2022-2026 (NOT-OD-22-061) RFI

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COGR Submits Comment Letter to NIH on NOT-OD-22-064

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COGR March 2022 Update

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COGR Joins Over 90 Associations on Free and Open Academic Inquiry Statement

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COGR Submits Letter to NIH on Genomic Data Sharing Policy RFI (NOT-OD-22-029)

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COGR February 2022 Update

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COGR Submits Comment Letter to OSTP Concerning January 2022 Guidance for Implementing NSPM-33

This letter contains COGR’s comments regarding the Implementation Guidance for National Security Presidential Memorandum 33, and stresses the need for transparency, a risk-based approach, and cross-agency consistency. 

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Overview of DARPA’s Countering Foreign Influence Program (CFIP) and Senior/Key Personnel Foreign Influence Risk Rubric

 

Overview of DARPA’s Countering Foreign Influence Program (CFIP) and Senior/Key Personnel Foreign Influence Risk Rubric DARPA officials Wes Bennett, Director, Contracts Management Office and Kevin Flaherty, Assist. Director, Policy & Oversight, Security & Intelligence Directorate will provide an overview of DARPA’s CFIP. Their presentation will include a discussion of DARPA’s recently revised risk rubric and how the rubric will be used in the grant process. The presentation will include time for questions and answers. 

Presentation Slides

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COGR Releases a Summary of NSTC Guidance for Implementing NSPM-33's Disclosure Requirements & Other Provisions

This summary highlights key points of the NSPM-33 Guidance’s disclosure requirements, including comparison of those provisions with current NIH and NSF requirements in this area. 

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COGR Submits Letter to OSTP on Reducing Administrative Burden

This letter provides specific suggestions to OSTP for achieving its objective of reducing administrative burden associated with federally funded research, including suggestions regarding research security requirements.  

Posted December 21, 2021

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UPDATE & ERRATA TO COGR NOVEMBER 2021 UPDATE

Posted December 15, 2021

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COGR Submits Comment Letter to NSF in Response to "Notice of a New System of Records: (SORN)

This letter provides comments regarding to NSF concerning its Privacy Act notice of a new system of records that describes the use of a data analytics tool to analyze information collected from researcher disclosures. 

Posted December 8, 2021

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COGR's November 2021 Update

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

Posted November 8, 2021

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COGR Submits Joint Association Letter to OLAW on NOT-OD-21-161 RFI

Posted October 26, 2021

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The Bayh-Dole Act: A Guide to the Law and Implementing Regulations (October 2021 Update)

Originally published in 1999, and updated October 2021:

Version 2.0 (October 2021 Update)

 

Contributors:

COGR would like to thank the Research Security & Intellectual Property Management Committee  (RSIP), and in particular, Michael Moore from Augusta University, for contributing to the update of this paper, originally published in October 1999 by the then-titled Technology Transfer and Research Ethics Committee (TTRE).

 

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COGR Signs On to Joint Association Letter to WH & CDC on Upcoming Changes to US Travel Policy for International Travelers and Vaccination Requirements

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A Tutorial on Technology Transfer in U.S. Colleges and Universities (Updated October 2021)

Released October 1, 2021

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COGR Joins Multi Association Letter to OSTP on NSPM-33 Implementation

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Task Force Announces Details of Federal Contractor Vaccine Mandate (Hogan Lovells)

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Principles for Evaluating Conflict of Commitment Concerns in Academic Research (Update)

Updated September 22, 2021

This paper examines the issue of conflict of commitment in the context of concerns regarding inappropriate foreign influence, promoting transparency, and avoiding conflicts. 

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COGR's August 2021 Update

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Registration Open: October 19-22, 2021 Virtual Meeting

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

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COGR Submits Joint Comments with AUTM and Bayh-Dole Coalition to DOE on Exceptional Circumstances Determination

Posted August 25, 2021

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COGR's Releases Paper on "Foreign Influence - Practical Considerations in Developing an Institutional Response"

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Federal Focus on Inappropriate Foreign Influence on Research: Practical Considerations in Developing an Institutional Response

This paper provides an overview of points that institutions should consider on issues related to research security as they perform risk assessments and develop/implement processes to appropriately address areas of higher research security risk

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

Posted August 12, 2021

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COGR Submits Comments to USDA in Response to Notice of Proposed Rulemaking - Handling of Animals; Contingency Plans

Posted August 6, 2021

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COGR Submits Joint Association Comments with AAU, AAMC, AAAS, and APLU to OSTP on Scientific Integrity RFI

Posted July 27, 2021

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COGR Submits Letter to NIH on NOT-OD-21-118 RFI Regarding Zebrafish

Posted July 26, 2021

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COGR, AAU, and APLU Submit Letter to DOE on Order 142.3B

Posted July 12, 2021

This letter sets forth comments to the Dept. of Energy from COGR, Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU) regarding the application of DOE Order 142.3B and the removal of the  limited screening exemption for U.S. universities

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June 2021 COGR Update

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COGR Joins Coalition Statement in Support of Research Using Human Fetal Tissue

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Materials Transfer in Academia: 20 Questions and Answers (Update)

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COGR's May 2021 Update

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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

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

Posted April 21, 2021

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COGR Submits Comments to NIH on Diversity & Inclusion RFI (NOT-OD-21-066)

Posted April 14, 2021

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Joint Association Comments on NIST NPRM Proposed Changes to Part 401 and 404

Posted April 5, 2021

This letter provides association comments regarding changes proposed to Part 401 Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants Contracts and Cooperative Agreements.

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February 2021 Meeting Report & Update

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COGR Joins Multi Association Letter to DHS in Support of International Students Returning to Campus

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COGR Joins Multi Association Comment Letter on the National Strategy for Expanding American Innovation (Docket #PTO-P-2020-0057)

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Principles for Evaluating Conflict of Commitment Concerns in Academic Research

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Technical Corrections to 2 CFR - To Be Published on 02/22/21

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COGR Joins Coalition Letter to HHS on Proposed Fetal Tissue Rule (RIN 0991-AC15)

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COGR Joins Multi Association Letter to OSTP Regarding NSPM-33 and JCORE Reccomendations

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COGR Comment Letter to NSF on 22-1 PAPPG

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January 2021 Addendum to Research Impact Under COVID-19 is Available

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COGR Joins Multi Coalition Letter to President-elect Biden on Human Fetal Tissue Research

Posted January 7, 2021

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COGR Releases Report on Pulse 3 & 4 of the COVID Research Impact Study

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Multi Association Letter to Department of Education on Section 117

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COGR Submits Letter to ORI on RFI on Research Integrity (85 FR 66341)

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Joint Association Letter to DoD Regarding CMMC (DFARS Case 2019-D041)

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Multi Association Letter to Incoming Administration on Regulatory Actions

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COGR October 2020 Meeting Report

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COGR Submits Letter to USDA APHIS on Proposed Rule Regarding AWA Research Facility Registration, Updates, Reviews, and Reports

Posted November 13, 2020

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Joint Association Comment Letter Regarding Foundational Technologies ANPRM

Posted November 2020

This letter contains joint association comments regarding concerns associated with potential expansion of controls on foundational technologies. 

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COGR Submits Comments to NIH on NOT-OD-20-153 RFI Regarding Grant and Congruency Reviews

Posted October 30, 2020

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COGR Submits Letter to DEA on RIN 1117-AB53 Implementation of the Agriculture Improvement Act of 2018

Posted 10/21/20

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COGR Submits Comments to NIH on NOT-OD-20-145 RFI Regarding Semiannual Inspections

Posted October 20, 2020

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COGR Releases Uniform Guidance Readiness Guide 2020

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COGR Sends Letter to OMB on the 2020 Compliance Supplement

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COGR Joins Multi-Association Letter to White House Opposing EO 13950 "Combating Race and Sex Stereotyping"

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COGR Submits Multi-Association Letter to OMB Requesting Extension/Reinstatement of M-20-17 & -26

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COGR Submits Letter to OMB on 2 CFR 200.216

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COGR Releases Current and Pending Support Table (NSF)

Posted 9/22/20

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Register Today for COGR's October 21-23, 2020 Virtual Meeting

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COGR September 2020 Update

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COGR Joins Multi-Association Letter Expressing Concern about DOD and the CMMC Accreditation Body

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COGR Joins Coalition Letter to DHHS on the NIH Human Fetal Tissue Ethics Advisory Board

Posted August 31, 2020

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

Posted August 25, 2020

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COGR Submits Comments to NIH in Response to NOT-OD-20-130 RFI on Enhancing Rigor, Transparency, and Translatability to Improve Biomedical Research Involving Animal Models

Posted August 19, 2020

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Foreign Influence and Research Security: The Challenges Continue Webinar Slides Now Available

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COGR Joins Coalition Letter to NIH Human Fetal Tissue Ethics Advisory Board

Posted July 28, 2020

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JASON Report: Managing the Risk From COVID-19 During a Return to On-site University Research

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June 10-12 Virtual Meeting Report

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COGR's 2019-2020 Year In Review

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COGR Submits Comments to ORI on Sequestration RFI

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COGR Releases Research Ramp Up Road Map: A Guide to Considerations and Resources for Ramping Up On-Campus Laboratory, Animal and Human Subjects Research as COVID-19 Restrictions are Lifted

Posted June 11, 2020 (Version 1.0)

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COGR, AAU, APLU and AAMC Submit Letter to OMB Requesting Flexibilities in M-20-17 Be Extended

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COGR's May 2020 Update

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COGR Submits Letter to DEA in Regard to Federal Register Notice, "Controls to Enhance the Cultivation of Marihuana for Research in the United States

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COGR, AAU, APLU and AAMC Submit Letter to EPA on Strengthening Transparency in Regulatory Science

Posted May 18, 2020

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Furlough Programs and Implications for Financial Research Compliance (Updated)

Posted May 8, 2020

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COGR's COVID-19 Research Impact Study

COGR has launched our COVID-19 Research Impact Study. This baseline survey (linked below) is estimated to take about 10 minutes to complete. It will be followed by brief "pulse questions" every two weeks.  The information we collect will help our members, sponsors, and other constituents to track the pandemic's effects over time.

Questions focus on your institution's research program status and staff; all responses will be reported in aggregate and de-identified.

We would like to receive only one response per institution.  To simplify the process, we ask that this survey (and subsequent pulse questions) be directed to the person in your institution who can best answer them, and/or coordinate with others in the institution to collect the information requested.

We would like to receive all responses to this baseline survey by  May 15, 2020.

If you are the best contact, please click here to enter the survey. If there is a more appropriate contact than you, please simply forward this email to that person.

Thank you in advance for your time and thoughtful insights.  If you have any questions about this survey, please email COVID19@cogr.edu.


Joint Association Letter to OSTP on Public Access RFI

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Proposed Pledges and Statements of Principles in Regard to IP Rights and Technology Licensing Related to COVID-19

Posted April 21, 2020

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COGR FAQs on COVID 19 Impact on Federal Awards V.2.2

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Register for COGR's Webinar on Case Studies on COVID-19’s Impact on Sponsored Activities at Research Institutions

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Joint Association Letter to EPA to Request an Extension for the Strengthening Transparency in Regulatory Science NPRM

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Joint Association & Institutional Letter to President Trump on Fetal Tissue Research Restrictions and COVID-19

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COGR Submits Letter to OMB on Uniform Guidance Revisions

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COGR February 27-28 Meeting Report

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Multi Association Request for Expanded Administrative Relief Due to the Impacts of COVID-19

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COGR Submits Letter to OSTP on “Draft Desirable Characteristics of Repositories for Managing and Sharing Data Resulting from Federally Funded Research

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COGR Submits Joint Letter to NLM on RFI for Clinical Trials.gov Modernization

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COGR Releases FAQs Regarding COVID-19's Impact on Federal Awards

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COGR Submits Joint Letter with AAU to NIH on Clinicaltrials.gov Modernization

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COGR Comments on Revised DofEd Sec. 117 Reporting Requirements

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COGR Signs on To Joint Association Letter to FAA on Unmanned Aircraft Systems NPRM

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COGR Submits Joints Association Request to OMB for Extension on UG Comment Period

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COGR Joins Association Letter to Department of Education on Free Inquiry

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COGR February 2020 Update

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COGR February 27-28, 2020 Meeting Agenda Released

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COGR Submits Letter to USDA on Hemp Rules

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COGR's Response to JCORE RFI

Posted January 27, 2020

This letter contains COGR's comments in response to the request for information on aspects of the American Research Environment [FR Doc. 2019-25604]

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COGR Submits Joint Association Comment Letter to NIST on iEdison RFI

Posted January 24, 2020

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COGR Letter to NIFA Regarding the Reimagining NIFA Initiative

Posted January 23, 2020

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Framework for Review of Individual Global Engagements in Academic Research

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COGR Comments to NIH on Draft Data Sharing and Management Policy

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COGR's December 2019 Update

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COGR Letter to SAMHSA on New Attestation Requirements

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COGR Submits Letter to OMB Objecting to DoEd's Section 117 Emergency Order

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COGR Releases Commentary on Disclosing Other Support

Posted December 5, 2019

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COGR Releases PPT Version of "Excellence in Research"

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COGR October 24-25th Meeting Report Now Available!

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COGR Submits Joint Letter to EPA Expressing Concern on Proposed Rule "Strengthening Transparency in Regulatory Science"

Posted November 13, 2019

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COGR Submits Comments to Dept. of Education on Section 117 Reporting

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COGR Position Available: Director of Research Ethics & Compliance

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COGR October 24-25th Meeting Agenda Now Available!

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COGR's September 2019 Update Now Available

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Joint Association Letter to NASA on Sexual Harassment Federal Register Notice

Posted 8/16/19

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Joint Association Letter to NIST on Protecting Controlled Unclassified Information SP800-171B

Posted August 2, 2019

This letter sets forth joint association comments expressing questions and concerns about how sponsoring agencies will apply the enhanced requirements of NIST SP 800-171B.

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COGR Submits Comments to NSF on PAPPG

Posted 7/29/19

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COGR Letter to OMB on 2019 Compliance Supplement

Posted July 26, 2019

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COGR Submits Letter to FDA on Cannabis Research

Posted 7/16/19

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Joint Letter to HHS on Fetal Tissue Research

Posted July 12, 2019

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Association Response to DoEd on Section 117 Reporting

Posted 7/12/19

This letter expresses joint association concerns regarding the continuing need for clarification regarding reporting requirements under Sec. 117 of the Higher Education Act of 1965. 

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COGR's June 2019 Meeting Report

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COGR, Other Associations and Universities Support Securing American Science and Technology Act

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COGR June 6-7, 2019 Meeting Agenda

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COGR May 2019 Update

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Final Joint Association Letter to OHRP on Cooperative Research

Posted May 1, 2019

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Registration Now Open for COGR's June 6-7, 2019 Meeting!

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COGR Letter to NIFA on Section 1462(c), Treatment of Subgrants

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

Posted April 12, 2019

Additional F&A Resources

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COGR February 2019 Meeting Report

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COGR Comments on the Draft Federal Report Reducing Administrative Burden for Researchers: Animal Care and Use in Research

Posted February 20, 2019

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February 2019 COGR Update

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COGR Sends Letter to OMB on Data Standards

Posted January 15, 2019

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COGR Letter to FDA Regarding Institutional Review Board Waiver or Alteration of Informed Consent for Minimal Risk Clinical Investigations

Posted January 14, 2019

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Joint Association Comment Letter on Emerging Technologies ANPRM

Click here to view

This letter contains joint association comments in response to the Advance Notice of Proposed Rulemaking Regarding Review of Controls for Certain Emerging Technologies Reference: 83 Fed. Reg. 58201 (Nov. 19, 2018).

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Joint Association Comments on Draft ROI Green Paper

Posted January 9 ,2019

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COGR's February 2019 Meeting Registration Now Open!

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COGR December 2018 Update

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Joint Association Letter to OSP-NIH: RFI on Proposed Provisions for a Draft Data Management and Sharing Policy

Posted December 10, 2018

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Joint Association Memo Requesting Extension from BIS

Posted December 4, 2018

This letter contains a joint association request for an extension to provide comments in response to the Advance Notice of Proposed Rulemaking (ANPRM) on the “Review of Controls for Certain Emerging Technologies published by the Bureau of Industry and Security (BIS) in the Federal Register on November 19, 2018.

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COGR October 2018 Meeting Report

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COGR, AAMC, and ARIO Submit Joint Letter to NIH on Communicating Research Misconduct to NIH, NOT-OD-19-020

Posted November 16, 2018

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Joint Response to NIH Registration and Results Reporting Standards for Prospective Basic Science Studies Involving Human Subjects (NOT-OD-18-217)

Posted November 13, 2018

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Joint Association Letter on Industrial Hemp

Posted November 5, 2018

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October 2018 COGR Update

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Final Joint Association Comments on Proposed Changes to the NIH Guidelines on Recombinant or Synthetic Nucleic Acid Research

Posted October 10, 2018

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COGR Submission to DOT on NABR Complaint

Posted September 20, 2018

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COGR Submits Letter to DEA Regarding Production Quotas for Schedule I & II Controlled Substances

Posted September 20, 2018

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COGR's September 2018 Update

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Register for the COGR October Meeting Today!

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Statement of Support for Kelvin Droegemeier As OSTP Director

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Higher Education Associations RFI Response: Federal Technology Transfer Authorities and Processes

Posted  7/27/18

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Engage Research Institutions on Research Regulatory Reform

Science, July 20, 2018

Summary

Reprint

Full Text

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Joint Association Letter to EPA on Proposed Rule to Limit Scientific Research

COGR, along with the AAMC, AAU and APLU submit their joint letter to the Environmental Protection Agency (EPA) opposing a proposed rule that seeks to limit the scientific research it will consider unless all underlying data are made publicly available. The mechanisms of competitive grant funding and peer review of publications serve to ensure the validity of science and integrity of research even when the data are not available to the public for legitimate, reasonable and ethical reasons. Restrictions related to data availability, such as the privacy of individual health information should not discount the validity of the research, or its findings, and should not prevent the EPA from using credible research in its rulemaking decisions.

If instituted, the proposal will prevent the EPA from evaluating the best available evidence when making its regulatory decisions. Because of this, the cosigning organizations urged the withdrawal of the proposed rule and invite the EPA to engage with the scientific community to discuss how evidence-based policy should be developed to protect human health and the environment.

Posted July 11, 2018

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June 2018 COGR Meeting Report

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Joint Association Letter on Revisions to the Animal Welfare Act

Posted June 21, 2018

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COGR's Response to NIH OLAW's Request for Comments

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COGR June 2018 Update

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COGR Final Meeting June Meeting Agenda

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COGR Submits Letter to DOD on Security Requirements

Posted 5/29/18

This letter contains COGR's comments seeking DOD clarification that SSPs and NIST compliance is not required in contracts or subcontracts involving solely the performance of fundamental research, and/or research not involving any covered defense information or other types of controlled unclassified information.

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Joint Association Comments on the Common Rule NPRM

Posted May 16, 2018

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Joint Association Letter in Support of Amendment to Farm Bill

Posted May 15, 2018

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Joint Association Letter to NSF on Reporting of Sexual Harassment (No. 144)

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COGR Working Group Develops FAQs on Cannabis Research

Posted May 1, 2018

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COGR May 2018 Update Now Available

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Letter to FBI Director Requesting Meeting Regarding National Security Higher Education Advisory Board (NSHEAB)

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Register Today for June 7-8, 2018 COGR Meeting!!

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COGR Submits Joint Association Letter in Support of HR 5485

Posted April 19, 2018

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Joint Statement on Foreign Plots Targeting America's Research and Development

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University Associations Support Bi Partisan Stronger Patents Act

Posted 3/23/18

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COGR Comments on the Common Rule Interim Final Rule

Posted March 16, 2018

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COGR's February 2018 Meeting Report Now Available

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COGR February 2018 Update Now Available

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COGR February 22-23 Meeting Agenda

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COGR Releases Matrix of Recent Legislative Actions Taken to Reduce Research Regulatory Burden

Posted January 2018

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COGR Sends Follow Up Letter to Open Science Committee Members on Public Access

Posted January 19, 2018

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COGR December 2017 Update Now Available

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Register Today for the February 22-23, 2018 Meeting!

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COGR October 2017 Meeting Report Now Available

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Joint Association Comments on USDA Regulatory Reform

Posted November 14, 2017

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COGR Submits Joint Association Letter to EPA Regarding Advisory Boards & Committees

Posted November 6, 2017

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New Report Aims to Advance Regulatory Efficiency in Animal Research

Posted 10/24/17

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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 hai_m._tran@omb.eop.gov. 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 regulations.gov.

 

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 dkennedy@cogr.edu if you have questions on how to best craft your concerns to OMB.

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COGR Submits Joint Letter with AAU & APLU on Access to Genomic Data

Posted October 20, 2017

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COGR October 2017 Meeting Agenda (Updated)

The October Meeting Agenda has been slightly updated for Thursday afternoon.

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COGR October Update Now Available

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Joint Association Letter on NIH Clinical Trial Case Studies

A number of institutions have contacted COGR over the last several weeks to express concern about clinical trial case studies that NIH has posted to their website to provide guidance on determining whether proposed research meets NIH criteria for a clinical trial. Many in the research community have been surprised to find that several of the case studies suggest that some basic health-related research meets the clinical trial definition.  COGR, AAMC, AAU and APLU have communicated these concerns to NIH officials.  The associations also sent a letter to Mike Lauer, NIH Deputy Director for Extramural Research, yesterday afternoon detailing our concerns and requesting continued dialogue. NIH made revisions to the case studies on September 8 and has indicated that the case studies and related guidance may continue to evolve. We will keep the membership informed of any further developments. 

Read Joint Association Letter

*Sent to COGR Listserv 9/19/17

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Joint Comment Letter to DoEd on Open Licensing

Posted 9/19/17

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COGR September 2017 Update Now Available

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Joint Association Letter Submitted to FDA on Hatch-Waxman Amendments to the Cosmetic Act

Posted 9/8/17

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Register Today for COGR's October 26-27, 2017 Meeting

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What Do Revised U.S. Rules Mean for Human Research? (Science, Aug. 2017)

Posted August 30, 2017

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COGR Submits Joint Letter with AAU to DOD on DFARS Streamlining Measures

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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."

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COGR Submits Joint Association Letter on DOE Regulatory Reform

Posted July 14, 2017

This letter provides joint association comments on Department of Energy regulations, paperwork requirements and other regulatory obligations as part of the agency’s implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.” 

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COGR June Meeting Report Now Available

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COGR Submits Joint Association Letter to Request Delay in Common Rule Compliance Date

Posted June 21, 2017

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

Posted June 12, 2017

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COGR May 2017 Update Now Available

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F & A and the Cost of Research

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COGR June 8-9, 2017 Meeting Agenda Now Available

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Research Highlights - Science Coalition

As there is interest from the COGR Membership regarding materials that demonstrate the importance of basic scientific research at universities to innovation, job creation and the economy in general, we have provided a link below  to the latest report from the Science Coalition which provides excellent information by university, by State, and by federal agency. 

The Science Coalition released a Sparking Economic Growth report that traces the origins of 302 companies – many of them small businesses – back to federally support research. The report is “intended to showcase one of the ways that federal investment in basic scientific research helps stimulate the economy."

 

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Joint Association Request to OMB on the Research Policy Board

Posted April 27, 2017

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Register Today for COGR June 8-9 Meeting!

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

Posted April 17, 2017

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Current Developments - April 2017

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COGR Submits Letter to DOD Regarding Pre/Post Award Administrative Matters on Financial Assistance Awards

Posted April 5, 2017

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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.

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COGR Submits Comments/Questions to NIH on "Single IRB Policy FAQs for Extramural Community"

COGR submits comments and questions to NIH on the document 'NIH Single IRB Policy FAQs for Extramural Community."  Comments are indicated in red italic text.

 

Click here.

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COGR February 2017 Meeting Report Now Available

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Call for COGR Board Nominations 2017!

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Updated: COGR February 23-24, 2017 Meeting Agenda Now Available

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COGR February 2017 Update Now Available

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COGR’s Response to DOD on NPRMS Implementing 2 CFR Part 200

COGR’s response to a series of six (6) DoD NPRMs updating the DoD Grant and Agreement Regulations (DoDGARs) to implement 2 CFR part 200.

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Overview of the Final Revised Common Rule

February 1, 2017:  An overview of the changes to the revised Common Rule published in the Federal Register on January 19, 2017, a one page summary table of the changes made, and a link to the final revised Common Rule.

Summary of Changes Made to the Common Rule

COGR Common Rule Summary Table

Final Revised Common Rule

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COGR, AAU, APLU Submit Joint Comments to NIH RFI on Data Sharing NOT-OD-17-015

Click here to view

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COGR Meets with OIRA Staff to Discuss Final Common Rule Under Review

Click here to review document.

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COGR Submits Letter to DOD on Proposal Submission Deadlines

Click here to view

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December 2016 Update Now Available

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Joint Comment Letter with AAU, AAMC, APLU & AUTM to NIST Regarding Bayh-Dole NPRM

Click here for letter

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COGR Supports Cures Legislation in Letter to Senate HELP Staff

Click here for letter

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NIH Response to COGR Concerns Regarding GCP Training Requirements

Click here to view

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COGR October 2016 Meeting Report Now Available

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COGR Submits Joint Letter with AAU, APLU, and AAMC Requesting Extension to NIH sIRB Policy Implementation

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COGR October 2016 Update Now Available

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COGR's Letter to CMS on COI Procedures

Posted October 6, 2016

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COGR's FLSA Postdoctoral Research Survey Executive Summary Now Available

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COGR 2016 Meeting Agenda Now Available!

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COGR's September 2016 Update

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COGR Response to Part 2 of the National Academies Report

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COGR Submits Proposed FAQs on Uniform Guidance to OMB

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COGR/AAU/APLU Submit Joint Letter Thanking NIH for Rescinding NOT-OD- 16-088

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COGR Comments on Proposed Changes to HHS Adoption of UG

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COGR Submits Letter to OMB on COI Under Uniform Guidance

Posted July 8, 2016

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June 2016 Meeting Report and Summary Now Available

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COGR Releases Joint Statement with AAU and APLU on National Academies Report to Optimize Federal Investments in Academic Research

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COGR Submits Comments to NIH on Postdocs Supported by NRSA and RGA Awards

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COGR & AIRI Submit Joint Letter on Procurement as Requested by OMB

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May 2016 Update Now Available

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June 9-10 COGR Meeting Agenda Now Available!

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COGR Submits Recommendations to ORI Director Dr. Kathryn Partin

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COGR Releases Findings From a Review of the Common Rule NPRM Comments

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COGR and AAU Submit Joint Comments on OMB's Draft Open Source Policy

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COGR Comments on DOI Conflict of Interest Policy

Posted April 8, 2016

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NSF Approved Notice of Preliminary IRB Approval for a Project Lacking Immediate Plans for Involvement of Human Subjects

COGR has recently engaged in conversations with Jean Feldman, Head, Policy Office, and Jeff Mantz, Human Subjects Research Protection Officer, National Science Foundation, regarding applications and proposals lacking definite plans for involvement of human subjects. Per 45 CFR 690.118, applications lacking definite plans, such as “projects in which human subjects’ involvement will depend upon completion of instruments, prior animal studies, or purification of compounds,” need not be reviewed by an IRB before an award is made. NSF has indicated that for studies that meet these criteria, IRBs may use a “Preliminary Approval” notice for NSF projects (see "Read More" below) and that this approval is consistent with the Proposal and Award Policies and Procedures Guide.

The letter was drafted by Cindy Shindledecker and Lois Brako of the University of Michigan who have been working with Jeff and others on this for some time and we appreciate all of the work that they have done. The draft letter provides a limited approval period and indicates that the investigator must submit an amendment or new IRB application for full IRB approval of the project prior to the expiration date. It also emphasizes that no work with human subjects, including recruitment, may be conducted under the determination. Establishing a time limit, whether it is 3 or 6 months, requires investigators to return to the IRB and establishes accountability. Please contact Lisa Nichols if you have questions or concerns about the use of this draft letter.

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COGR Submits Letter to OMB on Open Items Per UG

Click here to go to COGR March 16 Letter.
Click here to go to the OMB May 16 response.


COGR February 2016 Meeting Report Now Available

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COGR and AAU Submit Joint Letter to DOD on DFARS Case 2013-D-018

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COGR's February 2016 Update

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COGR Seeks Clarification from the U.S. Fish & Wildlife Service on COI Language

Posted February 11, 2016

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COGR February 25-26, 2016 Meeting Agenda Now Available

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COGR Submits Letter to OMB Requesting “Implementation of Sensible Procurement Standards”

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COGR's December 2015 Update

COGR has released the December 2015 Update

 [Full Text] [Summary]


Joint COGR/AAU/APLU/AUTM Letter Submitted to DOEd on Open License Requirement

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COGR Submits Comment Letter to NSF on Research Terms and Conditions

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COGR Submits Comments on Common Rule NPRM and Provides Summary Brief

COGR Detailed and Summary Comments on Common Rule

Click here to read the full NPRM Comment Letter.

Click here to read a summary of the full NPRM Comment Letter.


Register Now For the Next COGR Meeting- February 25-26, 2016

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COGR Submits Comments on NIH Guidelines on Recombinant or Synthetic Nucleic Acid Molecules

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NIH Releases 2015 Revised Grants Policy Statement

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Revised Grants.gov Application Guide Now Posted

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

Click here

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COGR Submits Letter to DOD on COI Requirements

Posted November 9, 2015

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October 2015 COGR Meeting Report Published

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October 30, 2015- COGR/AAU Joint Letter on DFARS Case 2013-D018

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October 28, 2015- COGR Responds to Part 1 of the National Academies Report

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NSF Releases 2016 PAPPG

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2015-2016 COGR Meeting Dates Published

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October 2015 COGR Update

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September 24, 2015 COGR Letter to OMB on UG Deviations

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September 4, 2015 - COGR Comment Letter to the Department of Labor Wage and Hour Division Regarding RIN 1235-AA11

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August 17, 2015 - August 2015 COGR Update COGR has published its August 2015 Update.

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August 3, 2015 - Joint COGR/AAU Comments on the Petition to Develop Specific Ethologically Appropriate Standards for Non-Human Primates in Research

COGR and AAU submitted joint comments on the petition to develop specific ethologically appropriate standards for non-human primates in research.

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July 27, 2015: COGR Submits Comments to GSA on FAR Case 2014-025 Fair Pay and Safe Workplace

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June 30, 2015 - Revisions to Procurement Standards and Grace Period Extension

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May 26, 2015 - May 2015 Update

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May 12, 2015 - Joint Letter from COGR/AAU to NIST on the Revised Draft Guidanced on Controlled Unclassified Information

COGR and AAU sent a joint letter regarding the revised draft guidance concerning controlled unclassified information (CUI) to the National Institute of Standards and Technology which was outlined in NIST Special Publication 800-171.

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May 8, 2015 - June 2015 COGR Meeting Agenda

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April 30, 2015 - Abusive Litigation Practices of Patent Trolls

COGR and other higher education associations released a statement expressing the view that bipartisan legislation introduced in the Senate, seeking to address abusive litigation practices of patent trolls while protecting the integrity of our patent system, was a substantial improvement over the pending House version (HR 9).

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April 24, 2015 - Comment Letter to the FAA on Proposed Rule for the Operation and Certification of Unmanned Aircraft Systems

COGR signed on to a comment letter to the FAA on its proposed rule for the Operation and Certiification of Small Unmanned Aircraft System.

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March 27, 2015 - COGR Letter to NIH on Proposed Extension of Reporting Requirements for FCOI

COGR sent at letter to OPERA on the request for a three-year extension of the reporting requirements set out in regulations on the Responsibility of Applicants for Promoting Objectivity in Research.

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February 20, 2015 - COGR Letter to EPA on Interim Conflict of Interest Policy

Posted February 20, 2015

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February 13, 2015 - COGR Response to OMB on Uniform Implementation

COGR has submitted its comments to the December 19, 2014 Federal Register Notice on Federal Awarding Agency Regulatory Implementation of Office of Management and Budget's Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2 CFR [art 200)

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January 22, 2015 - COGR Letter to OHRP on Draft Guidance on Disclosing Reasonably Foreseeable Risks in Research Evaluating Standards of Care

COGR sent a letter to the Office for Human Research Protections on draft guidance concerning disclosure of reasonably foreseeable risks in research evaluating standards of care.

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January 16, 2015 - Joint AAU and COGR Letter to NIST on Controlled Unclassified Information

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January 16, 2015 - COGR Summary of Background and Technical Corrections to Final Uniform Guidance

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