COGR. APLU, and AAU Submit Joint Comments on DFARS Case 2020-D028 [Docket DARS-2024-0027]

The Association of Public and Land-grant Universities (APLU), the Association of American Universities (AAU), and the Council on Governmental Relations (COGR) submitted comments to the Department of Defense regarding proposed amendments to the Defense Federal Acquisition Regulation Supplement (DFARS) on public access to DOD-funded fundamental research. The organizations express strong support for the DOD’s efforts to enhance public access to federally funded research, particularly praising the alignment of definitions and data management plan requirements with those of other federal agencies, as well as the use of shared repository infrastructures to streamline compliance for researchers. To further harmonize DOD policy with other federal agencies, the letter recommends several clarifications and revisions: specifying an effective date of October 1, 2025 for new grants and contracts, clearly defining the “official date of publication” for manuscript submission, strengthening language to protect sensitive data in compliance with national security and confidentiality laws, and explicitly allowing the direct charging of publication and data sharing costs to grants or contracts. The organizations emphasize that these changes will help ensure clarity, facilitate adoption within the research community, and protect sensitive information. They commend the DOD’s commitment to scientific advancement and look forward to continued collaboration on implementing these policies.