Comment Letter

COGR Letter to OEI HHS-OIG

The letter from Matt Owens, President of the Council on Governmental Relations (COGR), addresses the Office of Inspector General (OIG) at the U.S. Department of Health and Human Services (HHS) following a meeting on January 30, 2024, regarding the NIH Recipient Institutions’ Reporting of Monetary Donations that Support Research Survey. COGR thanks the OIG representatives for their engagement and discusses two primary concerns that arose during the meeting: extending the survey response deadline and enhancing response options within the survey. Specifically, COGR urges HHS OIG to extend the survey deadline by 30 days, citing that many institutions have only recently identified survey recipients and require more time to coordinate comprehensive, multi-departmental responses. Additionally, COGR advocates for the inclusion of a free-text response box and an "other" answer option for each survey question, emphasizing that the current design may force institutions to select "don't know" for scenarios where they actually have nuanced answers—potentially leading to misinterpretation of institutional competence and data accuracy in the final report.

The letter articulates concerns that the absence of detailed free-text and "other" response options may compromise both the accuracy of responses and the quality of data analysis, as well as lead to erroneous public interpretations of institutional capabilities. COGR believes that implementing these suggestions will facilitate more accurate, complete, and analyzable data, thereby benefiting the survey's overall integrity and utility. The letter concludes with an expression of appreciation for the OIG’s collaboration and openness to feedback while offering ongoing dialogue to address any further questions.

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