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2025 Call for Nominations - COGR Board of Directors
Read MoreCOGR Response to NSF RFI on CHIPS and Science Act, Section 10343
Read MoreCOGR Responds to USDOJ's Notice of Proposed Rulemaking - Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons
Read MoreCOGR. APLU, and AAU Submit Joint Comments on DFARS Case 2020-D028 [Docket DARS-2024-0027]
Read MoreCOGR's November 2024 Update
Read MoreCOGR Submits Response to Interim Final Rule - "Implementation of Controls on Advanced Technologies Consistent with Controls Implemented by International Partners"
Read MoreCOGR Submits Response to Health and Human Services Adoption of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Read MoreCOGR's Emerging Research Institutions Pilot Program
Read MoreSurvey of Research Integrity Officers on Final ORI Research Misconduct Rule (Please Complete by 11/30)
As sent to the COGR and ARIO listservs on 10/31:
Subject: Survey of Research Integrity Officers on Final ORI Research Misconduct Rule: Please Complete by 11/30
COGR Membership and ERI Pilot Participants,
COGR and the Association of Research Integrity Officers (ARIO) are conducting a survey of Research Integrity Officers on the Final ORI Research Misconduct Rule. We invite the appropriate individual at each institution to submit a response to aid in COGR and ARIO’s advocacy efforts. We ask that each institution submit one survey via the link below by November 30, 2024. We estimate this survey to take approximately 15 minutes to complete for those that are already familiar with the Final Rule. Read on for more information on this survey.
Survey of Research Integrity Officers on Final ORI Research Misconduct Rule
Who is conducting this survey?
This survey is being jointly conducted by COGR (Council on Governmental Relations) and ARIO (Association of Research Integrity Officers). Representatives from both COGR and ARIO will have access to and analyze the survey responses.
Who should complete this survey?
This survey is being sent to COGR and ARIO members. It is designed to be answered by the individual at the institution who is responsible for administering the institution’s policies and processes regarding the review of allegations of research misconduct (i.e., fabrication, falsification, and plagiarism). At many institutions this individual may be the research integrity officer, but it will vary from institution to institution. If you receive this survey link and you are not responsible for handling your institution's allegations of research misconduct, please forward the link to the appropriate individual for response. Only one response per institution should be submitted.
What is the purpose of this survey?
The federal Office of Research Integrity (ORI) recently issued its final research misconduct rule – Public Health Service (PHS) Policies on Research Misconduct (“Final Rule”) – which updated the requirements for the policies and process that institutions must have in place to address allegations of research misconduct concerning PHS-supported research. This survey is designed to identify areas of the Final Rule for which RIOs or other individuals responsible for handling allegations of research misconduct believe it would be beneficial to receive additional guidance or clarification from (a) ORI; (b) the RIO community working through COGR and ARIO; or (c) both ORI and the RIO community. COGR and ARIO will use the information that is collected in developing advocacy plans, communications with ORI, and materials to assist member institutions in their implementation of the Final Rule.
How Long Does the Survey Take to Complete?
If you are familiar with the provisions of the Final Rule, it should take about 15 minutes to complete the survey. If you are less familiar with the provisions of the Final Rule, you may want to look at the following summaries of its provisions before you start the survey:
Confidentiality of Information
COGR and ARIO will keep the information that they collect confidential and only report results in an aggregated and deidentified fashion.
Collection Tool and Due Date
COGR and ARIO will use the Alchemer online survey tool to collect survey responses. Responses are due no later than November 30, 2024. A Word copy of the survey is available here so that institutions can preview the questions before completing the online survey.
Points of Contact
For questions regarding the survey, please contact Kris West, COGR’s Director of Research Ethics & Compliance at kwest@cogr.edu and Lauran Qualkenbush, ARIO’s President at lhaney@northwestern.edu.
Read MoreOctober Meeting Materials
Read MoreCOGR Endorses AUECO Comment Letter to BIS on Export Administration Regulations: Crime Controls and Expansion/Update of U.S. Persons Controls
Read MoreCOGR Endorses AUECO Letter to U.S. Department of State on International Traffic in Arms Regulations: Revisions to Definition and Controls Related to Defense Services
Read MoreCOGR Endorses AUECO Comments to BIS on End-Use and End-User Based Export Controls, Including U.S. Persons Activities Controls: Military and Intelligence End Use and End Users
Read MoreCOGR's September 2024 Update
Read MoreF&A Cost Reimbursement Educational Materials
Read MoreNow Available: Fifth Look: Implementation and Readiness Guide for the OMB Guidance for Federal Financial Assistance
Read MoreWebinar Slides & Recording Now Available: Going AI: Cutting-Edge Strategies for Enhancing Research Administration Efficiency through Practical Application of Artificial Intelligence
Read MoreCOGR Joins a Multi-Association Request to DOE's RTES for Full Engagement with the Research Community Prior to Implementation of Risk Matrices
Read MoreCOGR, AAU, and APLU Letter to DOE on Financial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy Requirements
Read MoreCOGR Joins a Multi-Association Response to NIH's Draft Public Access Policy
Read MoreUpdated: Quick Reference Table of Current & Upcoming Federal Research Security Requirements
Read MoreUpdated: COGR Matrix of Science & Security Laws, Regulations, and Policies
Read MoreCOGR Releases 2023-2024 Year In Review
Read MoreCOGR Responds to Request for Comments: Biosketch and Current and Pending Support Disclosure Policy
Read MoreCOGR Submits Comments to NIH on Intramural Research Program Policy: Promoting Equity Through Access Planning
Read MoreCOGR Responds to NIH Proposed Collection of Post-Award Reporting Requirements
Read MoreOverview of OSTP Guidelines for Research Security Programs at Covered Institutions
Read MoreCOGR's July 2024 Update
Read MoreCOGR and AAMC Submit Joint Letter to DEA on Rescheduling Marijuana
Read MoreCOGR Responds to OMB's Invitation to Provide Comments and Technical Corrections to Address Select Items in the Recently Released OMB Guidance for Federal Financial Assistance
Read MoreJune 2024 COGR Meeting Materials
Read MoreJune 2024 COGR Meeting: Slide Presentations
Read MoreCOGR's May 2024 Update
Read MoreSlides & Recording Now Available (Log In Required): A Second Look at the Final OMB Guidance for Federal Financial Assistance
Read MoreCOGR Responds to Centers for Medicare & Medicaid Services February 2024 Request for Information on Research Data Request and Access Policy Changes – Updated March 1, 2024
Read MoreCOGR & AAU Submit Joint Comments in Response to Unlocking the Full Potential of Intellectual Property by Translating More Innovation to the Marketplace (Docket No. PTO-C-2024-004)
Read MoreCOGR's First Look at OMB's Guidance on Federal Financial Assistance
Read MoreResults from COGR’s Survey on Research Institutions’ Experiences with DoD Policy for Risk-Based Security Reviews of Fundamental Research
Read MoreCOGR Responds to Advance Notice of Proposed Rulemaking - "Provisions Regarding Access to Americans' Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern"
Read MoreCOGR Position Announcement: Director for Costing and Financial Compliance
Read MoreRegistration Now Open: COGR's June 6-7, 2024 Meeting in Washington D.C.
Read MoreCOGR Joins AIRI in Submitting Comments to OMB on the Treatment of Salaries and the Executive Level II Salary Limitation
Read MoreCOGR Responds to APHIS Notice of Proposed Rulemaking on Agricultural Bioterrorism Protection Act of 2002; Biennial Review and Republication of the Select Agent and Toxin List
Read MoreCOGR Submits Response to CDC on Notice of Proposed Rulemaking on Possession, Use, and Transfer of Select Agents and Toxins; Biennial Review of the List of Select Agents and Toxins
Read MoreCOGR's March 2024 Update
Read MoreCOGR Virtual Meeting Materials
Read MoreCOGR 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”
Read MoreCOGR Responds to EPA Scientific Integrity Policy Draft for Public Comment (EPA-HQ-ORD-2023-0240; FRL-10973-01-ORD)
Read MoreUpdate Now Available: Quick Reference Table of Current & Upcoming Federal Research Security Requirements
Read MoreCOGR's February 2024 Update
Read MoreUpdate Now Available (V.4): COGR Matrix of Science & Security Laws, Regulations, and Policies
Read MoreCOGR's Questionnaire on HHS-OIG Survey (Please complete by 2/23)
Read MoreCOGR, EDUCAUSE, and AAU Submit Joint Comment Letter to GSA on Cyber Threat and Incident Reporting & Information Sharing (FAR 2021-017)
Read MoreCOGR Submits Comments to NIST on Draft Interagency Guidance Framework for Considering the Exercise of March In Rights
Read MoreCOGR Comments & Extension Request to Office of Evaluation and Inspections, OIG, HHS on NIH Monetary Donations that Support Research Survey (OEI-03-22-00570)
Read More2024 Call for Nominations - COGR Board of Directors
Read MoreCOGR Submits Joint Association Response for NSF Public Access 2.0
Read MoreCOGR Position Announcement: Director for Research Security and Intellectual Property
Read MoreCOGR 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)
Read MoreCOGR Responds to NIH Request for Information (RFI) on Proposed Guidance to Assured Institutions on Cephalopod Care and Use (NOT-OD-23-176)
Read MoreCOGR's December 2023 Update
Read MoreCOGR is Moving! Update Your Institutional Records by January 1, 2024!
Read MoreCOGR Submits Comments to ORI on Public Health Service Policies on Research Misconduct Notice of Proposed Rulemaking
Read MoreCOGR Joins C4IP in Urging the Biden Administration to Oppose the Proposed WTO IP Waiver for Covid-19 Therapeutics and Diagnostics
Read MoreCOGR Responds to OMB's NPRM on Guidance for Grants & Agreements "Uniform Guidance"
Read MoreCOGR Submits Joint Association Request for Extension of Comment Period for Oct. 6, 2023, NPRM on PHS Policies on Research Misconduct (88 FR 69583)
Read MoreCOGR Responds to Request for Information (RFI) on an Update to the Current OLAW Guidance Disclaimer
Read MoreCOGR 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
Read MoreAnalysis of NIST Safeguarding International Science Research Security Framework
Read MoreCOGR Responds to RFI on Flexibilities for Streamlining IACUC Review of Protocols and Significant Changes (NOT-OD-23-152)
Read MoreCOGR Responds to Proposed Amendments to the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules (NIH Guidelines) (88 FR 54332)
Read MoreSession 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)
Preparing for a Government Shutdown: A List of Institutional Considerations
Read MoreCOGR's September 2023 Update
Read MoreCOGR, 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
Read MoreCOGR's October 26-27, 2023 Meeting Preliminary Agenda Now Available
Read MoreCOGR's October 26-27, 2023 Meeting in Washington DC: Registration Now Open
Read MoreCOGR Submits Response to Congressional RFI on Federal Regulation of CBD Products
Read More2023 F&A Survey Reports
Read MoreCOGR's 2022-2023 Year In Review
Read MoreCOGR Supports EDUCAUSE Response to FAR: Prohibition on a ByteDance Covered Application
Read MoreCOGR Analysis on Executive Order 14104 “Federal Research and Development in Support of Domestic Manufacturing and U.S. Jobs”
Read MoreCOGR Joins Multi-Organization Statement on Addressing the Shortage of Long-Tailed Macaques for Research
Read MoreCOGR and AAU Team to Submit Input on the Ongoing Discussion Regarding NIH's Levers to Catalyze Technology Transfer
Read MoreCOGR 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)
Read MoreCOGR 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)
Read MoreCOGR 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
Read MoreOverview of Department of Defense Statement on Countering Unwanted Foreign Influence in Department-Funded Research Institutions of Higher Education
Read MoreCOGR Submits Joint Association Response to OMB on Comment Request; iEdison System
Read MoreCOGR Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603)
Read MoreCOGR's June 2023 Update
Read MoreCOGR Responds to NSF's Request for Response to Dear Colleague Letter: Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization
Read MoreCOGR Supports EDUCAUSE Response to NIST's Cybersecurity for R&D Request for Comment
Read MoreCOGR Responds to the National Science Foundation Proposal/Award; Information— NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 24-1) Comment Request
Read MoreJune 2023 Meeting Materials
Read MoreCOGR Participates in Joint Association Response to Comment Request; Agency Information Collection Activities; Submission to OMB for Review and Approval; Foreign Gifts and Contracts Disclosures
Read MoreCOGR Responds to OSTP Request for Information: NSPM 33 Research Security Programs Standard Requirement (88 FR 14187)
Read MoreCOGR's May 2023 Update
Read MoreResults from the COGR Survey on the Cost of Complying with the New NIH DMS Policy
Read MorePreliminary Agenda Now Available: COGR's June 8-9, 2023 Meeting
Read MoreCOGR, AAU, and AUTM Submit Joint Association Letter on COVID-19 Diagnostics and Therapeutics: Supply, Demand, and TRIPS Agreement Flexibilities
Read MoreCOGR Is Now On LinkedIn
Read MoreCOGR'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)
Read MoreCOGR Responds to the NIH Plan to Enhance Public Access to the Results of NIH-Supported Research [NOT-OD-23-091]
Read MoreCOGR'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]
Read MoreRegistration Now Open: COGR's June 8-9, 2023 Meeting in Washington D.C.
Read MoreCOGR Submits Joint Association Request to OSTP for Listening Sessions on Research Security Programs Standards
Read MoreCOGR 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."
Read MoreCOGR's March 2023 Update
Read MoreCOGR 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
Read MoreCOGR Posts DRAFT Response to OMB (Uniform Guidance)
Read MoreCOGR's Joint Response to NASA’s “New Conflict of Interest and Conflict of Commitment Policy for Recipients of NASA Financial Assistance Awards”
Read MoreCOGR 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
Read MoreNow Available: February 28-March 3, 2023 COGR Virtual Meeting Presentations & Session Recordings
Read MoreCOGR's 2 CFR 200 "Uniform Guidance" Resource Page
Read MoreCOGR Signs on to Multi-Association Letter to DoEd Regarding Foreign Gift & Contract Disclosures (ED-2022-SCC-0159)
Read MoreCOGR 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.
Read MoreCOGR 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.
Read MoreCOGR Releases NIH DMS Readiness Guide Chapter 4 Part II - Budgeting and Costing: Project-Based and Institutional Cost Considerations
Read MoreCOGR's February 2023 Update
Read MoreCOGR Responds to the Request for Information: Clinical Research Infrastructure and Emergency Clinical Trials
Read MoreCOGR Responds to HHS Notice of Proposed Rulemaking “Confidentiality of Substance Abuse Disorder Patient Records”
Read More2023 Call for Nominations - COGR Board of Directors
Read MoreNIH 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.
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.
Read MoreRegistration Now Open: COGR's February 28-March 3, 2023 Virtual Meeting
Read MoreCOGR Announces Matt Owens as Incoming COGR President
Read MoreCOGR's Review of the Final Policy on Data Management and Sharing: Budgeting and Costing (Readiness Guide Chapter 4 Part I)
Read MoreCOGR 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.
Read MoreCOGR Submits Letter to Dr. Tabak on the NIH Modular Grant Application and Award Process
Read MoreCOGR'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)
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)
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)
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)
Read MoreResearch 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.
Read MoreChapter 3 Part II of COGR's NIH DMS Readiness Guide: Roles and Responsibilities (Excel Download) Now Available
Read MoreCOGR Submits Comments to the Small Business Administration in Response to Federal Register Notice
Read MoreJoint Comments from AAU, AAMC, APLU, ACE and COGR to NSF on Standard Disclosures
Read MoreCOGR Letter for Request for Comment for Common Disclosure Forms
Read MoreCOGR and ARIO Joint Response to ORI RFI Research Misconduct Policies
Read MoreNSPM-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.
Read MoreCOGR October 2022 Meeting Materials
Read MoreCOGR and AAMC Submit Joint Comment Letter to NIH on Cannabis RFI (NOT-AT-22-026)
Read MoreCOGR & the Association of Research Libraries Present: Gearing Up for January 2023: Institutional Strategies for Implementing the NIH Data Management & Sharing Policy
Read MoreDigging Into DPIs (Digital Persistent Identifiers) 9/23 Webinar Materials
Read MoreOverview 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.
Read MoreCOGR September 2022 Update
Read MoreCOGR 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.
Read MoreCOGR'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.
Read MoreRegister for COGR's October 20-21, 2022 Meeting in Washington D.C.
Read MoreCOGR Submits Comments to OHRP in Response to HHS-OASH-2022-0011 "Use of a Single IRB for Cooperative Research" Draft Guidance
Read MoreMulti-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.
Read MoreCOGR Releases NIH Data Management Implementation Roles & Responsibilities: Considerations for Institutions
Read MoreDigging Into DPIs Webinar - Registration Open (Rescheduled to 9/23)
Read MoreLooking 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.
Recording (Log in required)
Read MoreTechnology Transfer in U.S. Research Universities: Dispelling Common Myths (Updated August 2022)
Read MoreCOGR Releases "Biennial Year in Review: 2020-2022"
Read MoreCOGR Submits March-In Letter to HHS Secretary Becerra on Prescription Drug Pricing
Read MoreCOGR Letter of Support for SACHRP’s Efforts to Redefine “Engaged in Research”
Read MoreCOGR Submits Comments to OMB Regarding the 2022 Compliance Supplement
Read MoreCOGR's June 2022 Update
Read MoreCOGR Submits Comments in Response to NIH Guide Notice NOT-OD-22-131 Regarding Protecting Privacy When Sharing Human Research Participant Data
Read MoreCOGR Submits Comments to NSF on the Draft PAPPG (NSF 23-1)
Read MoreCOGR May 2022 Update
Read MoreCOGR Submits Comments to USDA on Proposal Rule on Standards for Birds Not Bred for Use in Research Under AWA
Read MoreCOGR Submits Comments to NASA on T&C's Affecting Procurement
Read MoreCOGR 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
Read MoreCOGR Submits Comment Letter to NIH on NOT-OD-22-064
Read MoreCOGR March 2022 Update
Read MoreCOGR Joins Over 90 Associations on Free and Open Academic Inquiry Statement
Read MoreCOGR Submits Letter to NIH on Genomic Data Sharing Policy RFI (NOT-OD-22-029)
Read MoreCOGR February 2022 Update
Read MoreCOGR 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.
Read MoreOverview 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.
Read MoreCOGR 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.
Read MoreCOGR 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.
Read MoreCOGR 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.
Read MoreCOGR's November 2021 Update
Read MoreCOGR Submits Comments to DoEd on HEERF Data Collection Form Federal Register Notice
Read MoreCOGR Submits Joint Association Letter to OLAW on NOT-OD-21-161 RFI
Read MoreCOGR Signs On to Joint Association Letter to WH & CDC on Upcoming Changes to US Travel Policy for International Travelers and Vaccination Requirements
Read MoreThe 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).
Read More
A Tutorial on Technology Transfer in U.S. Colleges and Universities (Updated October 2021)
Read MoreCOGR Joins Multi Association Letter to OSTP on NSPM-33 Implementation
Read MoreTask Force Announces Details of Federal Contractor Vaccine Mandate (Hogan Lovells)
Read MorePrinciples for Evaluating Conflict of Commitment Concerns in Academic Research (Update)
This paper examines the issue of conflict of commitment in the context of concerns regarding inappropriate foreign influence, promoting transparency, and avoiding conflicts.
Read MoreCOGR's August 2021 Update
Read MoreRegistration Open: October 19-22, 2021 Virtual Meeting
Read MoreCOGR Submits Comments to OMB on 2 CFR 200 Subpart F - Audit Requirements Appendix XI - Compliance Supplement 2021
Read MoreCOGR Submits Joint Comments with AUTM and Bayh-Dole Coalition to DOE on Exceptional Circumstances Determination
Read MoreCOGR's Releases Paper on "Foreign Influence - Practical Considerations in Developing an Institutional Response"
Read MoreFederal 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
Read MoreCOGR Submits Letter to DoEd in Response on HEERF I, II, & III, Data Collection Form
Read MoreCOGR Submits Comments to USDA in Response to Notice of Proposed Rulemaking - Handling of Animals; Contingency Plans
Read MoreCOGR Submits Joint Association Comments with AAU, AAMC, AAAS, and APLU to OSTP on Scientific Integrity RFI
Read MoreCOGR, AAU, and APLU Submit Letter to DOE on Order 142.3B
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
Read MoreJune 2021 COGR Update
Read MoreCOGR Joins Coalition Statement in Support of Research Using Human Fetal Tissue
Read MoreMaterials Transfer in Academia: 20 Questions and Answers (Update)
Read MoreCOGR's May 2021 Update
Read MoreCOGR Writes to NSF to Address Concerns on Recent Audit Findings Related to Application of the F&A Cost Rate
Read MoreF&A Cost Rates and Reimbursement Pressures Under COVID-19: Maintaining a Fair and Reliable System
Read MoreCOGR Submits Comments to NIH on Diversity & Inclusion RFI (NOT-OD-21-066)
Read MoreJoint Association Comments on NIST NPRM Proposed Changes to Part 401 and 404
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.
Read MoreFebruary 2021 Meeting Report & Update
Read MoreCOGR Joins Multi Association Letter to DHS in Support of International Students Returning to Campus
Read MoreCOGR Joins Multi Association Comment Letter on the National Strategy for Expanding American Innovation (Docket #PTO-P-2020-0057)
Read MorePrinciples for Evaluating Conflict of Commitment Concerns in Academic Research
Read MoreTechnical Corrections to 2 CFR - To Be Published on 02/22/21
Read MoreCOGR Joins Coalition Letter to HHS on Proposed Fetal Tissue Rule (RIN 0991-AC15)
Read MoreCOGR Joins Multi Association Letter to OSTP Regarding NSPM-33 and JCORE Reccomendations
Read MoreCOGR Comment Letter to NSF on 22-1 PAPPG
Read MoreJanuary 2021 Addendum to Research Impact Under COVID-19 is Available
Read MoreCOGR Joins Multi Coalition Letter to President-elect Biden on Human Fetal Tissue Research
Read MoreCOGR Releases Report on Pulse 3 & 4 of the COVID Research Impact Study
Read MoreMulti Association Letter to Department of Education on Section 117
Read MoreCOGR Submits Letter to ORI on RFI on Research Integrity (85 FR 66341)
Read MoreJoint Association Letter to DoD Regarding CMMC (DFARS Case 2019-D041)
Read MoreMulti Association Letter to Incoming Administration on Regulatory Actions
Read MoreCOGR October 2020 Meeting Report
Read MoreMulti-Association Letter to Biden Administration on Regulatory Actions
Read MoreCOGR Submits Letter to USDA APHIS on Proposed Rule Regarding AWA Research Facility Registration, Updates, Reviews, and Reports
Read MoreJoint Association Comment Letter Regarding Foundational Technologies ANPRM
This letter contains joint association comments regarding concerns associated with potential expansion of controls on foundational technologies.
Read MoreCOGR Submits Comments to NIH on NOT-OD-20-153 RFI Regarding Grant and Congruency Reviews
Read MoreCOGR Submits Letter to DEA on RIN 1117-AB53 Implementation of the Agriculture Improvement Act of 2018
Read MoreCOGR Releases Uniform Guidance Readiness Guide 2020
Read MoreCOGR Submits Comments to NIH on NOT-OD-20-145 RFI Regarding Semiannual Inspections
Read MoreCOGR Sends Letter to OMB on the 2020 Compliance Supplement
Read MoreCOGR Joins Multi-Association Letter to White House Opposing EO 13950 "Combating Race and Sex Stereotyping"
Read MoreCOGR Submits Multi-Association Letter to OMB Requesting Extension/Reinstatement of M-20-17 & -26
Read MoreCOGR Submits Letter to OMB on 2 CFR 200.216
Read MoreRegister Today for COGR's October 21-23, 2020 Virtual Meeting
Read MoreCOGR September 2020 Update
Read MoreCOGR Joins Multi-Association Letter Expressing Concern about DOD and the CMMC Accreditation Body
Read MoreCOGR Joins Coalition Letter to DHHS on the NIH Human Fetal Tissue Ethics Advisory Board
Read MoreResearch Impact Under COVID-19: Financial Crisis and the "Pandemic Normal"
Read MoreCOGR 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
Read MoreForeign Influence and Research Security: The Challenges Continue Webinar Slides Now Available
Read MoreCOGR Joins Coalition Letter to NIH Human Fetal Tissue Ethics Advisory Board
Read MoreJASON Report: Managing the Risk From COVID-19 During a Return to On-site University Research
Read MoreJune 10-12 Virtual Meeting Report
Read MoreCOGR's 2019-2020 Year In Review
Read MoreCOGR Submits Comments to ORI on Sequestration RFI
Read MoreCOGR 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)
Read MoreCOGR, AAU, APLU and AAMC Submit Letter to OMB Requesting Flexibilities in M-20-17 Be Extended
Read MoreCOGR's May 2020 Update
Read MoreCOGR Submits Letter to DEA in Regard to Federal Register Notice, "Controls to Enhance the Cultivation of Marihuana for Research in the United States
Read MoreCOGR, AAU, APLU and AAMC Submit Letter to EPA on Strengthening Transparency in Regulatory Science
Read MoreFurlough Programs and Implications for Financial Research Compliance (Updated)
Read MoreCOGR'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
Read MoreProposed Pledges and Statements of Principles in Regard to IP Rights and Technology Licensing Related to COVID-19
Read MoreCOGR FAQs on COVID 19 Impact on Federal Awards V.2.2
Read MoreRegister for COGR's Webinar on Case Studies on COVID-19’s Impact on Sponsored Activities at Research Institutions
Read MoreJoint Association Letter to EPA to Request an Extension for the Strengthening Transparency in Regulatory Science NPRM
Read MoreJoint Association & Institutional Letter to President Trump on Fetal Tissue Research Restrictions and COVID-19
Read MoreCOGR Submits Letter to OMB on Uniform Guidance Revisions
Read MoreCOGR February 27-28 Meeting Report
Read MoreMulti Association Request for Expanded Administrative Relief Due to the Impacts of COVID-19
Read MoreCOGR Submits Letter to OSTP on “Draft Desirable Characteristics of Repositories for Managing and Sharing Data Resulting from Federally Funded Research
Read MoreCOGR Submits Joint Letter to NLM on RFI for Clinical Trials.gov Modernization
Read MoreCOGR Releases FAQs Regarding COVID-19's Impact on Federal Awards
Read MoreCOGR Submits Joint Letter with AAU to NIH on Clinicaltrials.gov Modernization
Read MoreCOGR Comments on Revised DofEd Sec. 117 Reporting Requirements
Read MoreCOGR Signs on To Joint Association Letter to FAA on Unmanned Aircraft Systems NPRM
Read MoreCOGR Submits Joints Association Request to OMB for Extension on UG Comment Period
Read MoreCOGR Joins Association Letter to Department of Education on Free Inquiry
Read MoreCOGR February 2020 Update
Read MoreCOGR February 27-28, 2020 Meeting Agenda Released
Read MoreCOGR Submits Letter to USDA on Hemp Rules
Read MoreCOGR's Response to JCORE RFI
This letter contains COGR's comments in response to the request for information on aspects of the American Research Environment [FR Doc. 2019-25604]
Read MoreCOGR Submits Joint Association Comment Letter to NIST on iEdison RFI
Read MoreFramework for Review of Individual Global Engagements in Academic Research
Read MoreCOGR Comments to NIH on Draft Data Sharing and Management Policy
Read MoreCOGR's December 2019 Update
Read MoreCOGR Letter to SAMHSA on New Attestation Requirements
Read MoreCOGR Submits Letter to OMB Objecting to DoEd's Section 117 Emergency Order
Read MoreCOGR Releases PPT Version of "Excellence in Research"
Read MoreCOGR October 24-25th Meeting Report Now Available!
Read MoreCOGR Submits Joint Letter to EPA Expressing Concern on Proposed Rule "Strengthening Transparency in Regulatory Science"
Read MoreCOGR Submits Comments to Dept. of Education on Section 117 Reporting
Read MoreCOGR Position Available: Director of Research Ethics & Compliance
Read MoreCOGR October 24-25th Meeting Agenda Now Available!
Read MoreCOGR's September 2019 Update Now Available
Read MoreJoint Association Letter to NASA on Sexual Harassment Federal Register Notice
Read MoreJoint Association Letter to NIST on Protecting Controlled Unclassified Information SP800-171B
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.
Read MoreAssociation Response to DoEd on Section 117 Reporting
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.
Read MoreCOGR's June 2019 Meeting Report
Read MoreCOGR, Other Associations and Universities Support Securing American Science and Technology Act
Read MoreCOGR June 6-7, 2019 Meeting Agenda
Read MoreCOGR May 2019 Update
Read MoreRegistration Now Open for COGR's June 6-7, 2019 Meeting!
Read MoreCOGR Letter to NIFA on Section 1462(c), Treatment of Subgrants
Read MoreCOGR Releases "Excellence in Research: The Funding Model, F&A Reimbursement, and Why the System Works"
Read MoreCOGR February 2019 Meeting Report
Read MoreCOGR Comments on the Draft Federal Report Reducing Administrative Burden for Researchers: Animal Care and Use in Research
Read MoreFebruary 2019 COGR Update
Read MoreCOGR Letter to FDA Regarding Institutional Review Board Waiver or Alteration of Informed Consent for Minimal Risk Clinical Investigations
Read MoreJoint Association Comment Letter on Emerging Technologies ANPRM
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).
Read MoreCOGR's February 2019 Meeting Registration Now Open!
Read MoreCOGR December 2018 Update
Read MoreJoint Association Letter to OSP-NIH: RFI on Proposed Provisions for a Draft Data Management and Sharing Policy
Read MoreJoint Association Memo Requesting Extension from BIS
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.
Read MoreCOGR October 2018 Meeting Report
Read MoreCOGR, AAMC, and ARIO Submit Joint Letter to NIH on Communicating Research Misconduct to NIH, NOT-OD-19-020
Read MoreJoint Response to NIH Registration and Results Reporting Standards for Prospective Basic Science Studies Involving Human Subjects (NOT-OD-18-217)
Read MoreOctober 2018 COGR Update
Read MoreFinal Joint Association Comments on Proposed Changes to the NIH Guidelines on Recombinant or Synthetic Nucleic Acid Research
Read MoreCOGR Submits Letter to DEA Regarding Production Quotas for Schedule I & II Controlled Substances
Read MoreCOGR's September 2018 Update
Read MoreRegister for the COGR October Meeting Today!
Read MoreStatement of Support for Kelvin Droegemeier As OSTP Director
Read MoreHigher Education Associations RFI Response: Federal Technology Transfer Authorities and Processes
Read MoreJoint 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.
Read MoreJune 2018 COGR Meeting Report
Read MoreCOGR's Response to NIH OLAW's Request for Comments
Read MoreCOGR June 2018 Update
Read MoreCOGR Final Meeting June Meeting Agenda
Read MoreCOGR Submits Letter to DOD on Security Requirements
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.
Read MoreJoint Association Letter to NSF on Reporting of Sexual Harassment (No. 144)
Read MoreCOGR May 2018 Update Now Available
Read MoreLetter to FBI Director Requesting Meeting Regarding National Security Higher Education Advisory Board (NSHEAB)
Read MoreRegister Today for June 7-8, 2018 COGR Meeting!!
Read MoreJoint Statement on Foreign Plots Targeting America's Research and Development
Read MoreCOGR's February 2018 Meeting Report Now Available
Read MoreCOGR February 2018 Update Now Available
Read MoreCOGR February 22-23 Meeting Agenda
Read MoreCOGR Releases Matrix of Recent Legislative Actions Taken to Reduce Research Regulatory Burden
Read MoreCOGR Sends Follow Up Letter to Open Science Committee Members on Public Access
Read MoreCOGR December 2017 Update Now Available
Read MoreRegister Today for the February 22-23, 2018 Meeting!
Read MoreCOGR October 2017 Meeting Report Now Available
Read MoreCOGR Submits Joint Association Letter to EPA Regarding Advisory Boards & Committees
Read MoreCOGR 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.
Read MoreCOGR Submits Joint Letter with AAU & APLU on Access to Genomic Data
Read MoreCOGR October 2017 Meeting Agenda (Updated)
The October Meeting Agenda has been slightly updated for Thursday afternoon.
Read MoreCOGR October Update Now Available
Read MoreJoint 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.
*Sent to COGR Listserv 9/19/17
Read MoreJoint Association Letter Submitted to FDA on Hatch-Waxman Amendments to the Cosmetic Act
Read MoreCOGR September 2017 Update Now Available
Read MoreRegister Today for COGR's October 26-27, 2017 Meeting
Read MoreWhat Do Revised U.S. Rules Mean for Human Research? (Science, Aug. 2017)
Read MoreCOGR Submits Joint Letter with AAU to DOD on DFARS Streamlining Measures
Read MoreAssociations 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."
Read MoreCOGR Submits Joint Association Letter on DOE Regulatory Reform
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.”
Read MoreCOGR June Meeting Report Now Available
Read MoreCOGR Submits Joint Association Letter to Request Delay in Common Rule Compliance Date
Read MoreCOGR Letter to Mulvaney and Price Objecting to NIH and F&A Budget Cuts
Read MoreCOGR May 2017 Update Now Available
Read MoreF & A and the Cost of Research
Read MoreCOGR June 8-9, 2017 Meeting Agenda Now Available
Read MoreResearch 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."
Read More
Register Today for COGR June 8-9 Meeting!
Read MoreAt OMB Request: Letter to Identify OMB Actions to Reduce Administrative Burden
Read MoreCurrent Developments - April 2017
Read MoreCOGR Submits Letter to DOD Regarding Pre/Post Award Administrative Matters on Financial Assistance Awards
Read MoreCOGR 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.
Read MoreCOGR 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.
Read More
COGR February 2017 Meeting Report Now Available
Read MoreCall for COGR Board Nominations 2017!
Read MoreUpdated: COGR February 23-24, 2017 Meeting Agenda Now Available
Read MoreCOGR February 2017 Update Now Available
Read MoreCOGR’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.
Read MoreOverview 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
Read MoreCOGR's Response to DOE on Revised DOE Order 142.3A
February 1, 2017: COGR's Response to DOE on Revised DOE Order 142.3A
October 27, 2017: COGR Submits Joint Letter with AAU to Request a Limited Exemption on DOE Order 142.3A
DOE Order 142.3A Unclassified Foreign Visits and Assignments Program
Read MoreCOGR, AAU, APLU Submit Joint Comments to NIH RFI on Data Sharing NOT-OD-17-015
Read MoreCOGR Meets with OIRA Staff to Discuss Final Common Rule Under Review
Click here to review document.
Read MoreDecember 2016 Update Now Available
Read MoreTransition Letter to Trump Administration
Read MoreJoint Comment Letter with AAU, AAMC, APLU & AUTM to NIST Regarding Bayh-Dole NPRM
Read MoreCOGR October 2016 Meeting Report Now Available
Read MoreCOGR Submits Joint Letter with AAU, APLU, and AAMC Requesting Extension to NIH sIRB Policy Implementation
Read MoreCOGR October 2016 Update Now Available
Read MoreCOGR's FLSA Postdoctoral Research Survey Executive Summary Now Available
Read MoreCOGR 2016 Meeting Agenda Now Available!
Read MoreCOGR's September 2016 Update
Read MoreCOGR Response to Part 2 of the National Academies Report
Read MoreCOGR Submits Proposed FAQs on Uniform Guidance to OMB
Read MoreCOGR/AAU/APLU Submit Joint Letter Thanking NIH for Rescinding NOT-OD- 16-088
Read MoreCOGR Comments on Proposed Changes to HHS Adoption of UG
Read MoreJune 2016 Meeting Report and Summary Now Available
Read MoreCOGR Releases Joint Statement with AAU and APLU on National Academies Report to Optimize Federal Investments in Academic Research
Read MoreCOGR Submits Comments to NIH on Postdocs Supported by NRSA and RGA Awards
Read MoreCOGR & AIRI Submit Joint Letter on Procurement as Requested by OMB
Read MoreMay 2016 Update Now Available
Read MoreJune 9-10 COGR Meeting Agenda Now Available!
Read MoreCOGR Submits Recommendations to ORI Director Dr. Kathryn Partin
Read MoreCOGR Releases Findings From a Review of the Common Rule NPRM Comments
Read MoreCOGR and AAU Submit Joint Comments on OMB's Draft Open Source Policy
Read MoreNSF 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.
Read MoreCOGR February 2016 Meeting Report Now Available
Read MoreCOGR and AAU Submit Joint Letter to DOD on DFARS Case 2013-D-018
Read MoreCOGR's February 2016 Update
Read MoreCOGR Seeks Clarification from the U.S. Fish & Wildlife Service on COI Language
Read MoreCOGR February 25-26, 2016 Meeting Agenda Now Available
Read MoreCOGR Submits Letter to OMB Requesting “Implementation of Sensible Procurement Standards”
Read MoreJoint COGR/AAU/APLU/AUTM Letter Submitted to DOEd on Open License Requirement
Read MoreCOGR Submits Comment Letter to NSF on Research Terms and Conditions
Read MoreCOGR 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
Read MoreCOGR Submits Comments on NIH Guidelines on Recombinant or Synthetic Nucleic Acid Molecules
Read MoreNIH Releases 2015 Revised Grants Policy Statement
Read MoreRevised Grants.gov Application Guide Now Posted
Read MoreNovember 13, 2015: COGR Submits Letter to OMB on Utility Cost Adjustment Methodology
Read MoreOctober 2015 COGR Meeting Report Published
Read MoreOctober 30, 2015- COGR/AAU Joint Letter on DFARS Case 2013-D018
Read MoreOctober 28, 2015- COGR Responds to Part 1 of the National Academies Report
Read MoreNSF Releases 2016 PAPPG
Read More2015-2016 COGR Meeting Dates Published
Read MoreOctober 2015 COGR Update
Read MoreSeptember 24, 2015 COGR Letter to OMB on UG Deviations
Read MoreSeptember 4, 2015 - COGR Comment Letter to the Department of Labor Wage and Hour Division Regarding RIN 1235-AA11
Read MoreAugust 17, 2015 - August 2015 COGR Update COGR has published its August 2015 Update.
Read MoreAugust 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.
Read MoreJuly 27, 2015: COGR Submits Comments to GSA on FAR Case 2014-025 Fair Pay and Safe Workplace
Read MoreJune 30, 2015 - Revisions to Procurement Standards and Grace Period Extension
Read MoreMay 26, 2015 - May 2015 Update
Read MoreMay 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.
Read MoreMay 8, 2015 - June 2015 COGR Meeting Agenda
Read MoreApril 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).
Read MoreApril 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.
Read MoreMarch 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.
Read MoreFebruary 20, 2015 - COGR Letter to EPA on Interim Conflict of Interest Policy
Read MoreFebruary 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)
Read MoreJanuary 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.
Read MoreJanuary 16, 2015 - Joint AAU and COGR Letter to NIST on Controlled Unclassified Information
Read MoreJanuary 16, 2015 - COGR Summary of Background and Technical Corrections to Final Uniform Guidance
Read More