The Council on Governmental Relations (COGR), representing 188 member institutions, submitted feedback to the Office of Management and Budget (OMB) regarding the 2019 Compliance Supplement under 2 CFR Part 200. COGR expressed appreciation for OMB's movement toward a risk-based, performance-oriented audit framework, emphasizing its potential to reduce administrative burden while upholding accountability. The letter provided specific recommendations aimed at enhancing clarity and consistency in the Supplement. In particular, COGR advocated for a well-defined interpretation of the term “paid” within cash management to align with federal regulations and streamline audits. Additionally, COGR requested unambiguous language confirming the allowability of micro-purchase and simplified acquisition thresholds for research institutions, referencing OMB Memo M-18-18 to clarify eligibility and reduce confusion. Concerning the Research and Development Cluster, the organization sought an explanation for the increase from six to eight compliance requirements and questioned the rationale behind certain classifications in the final document, urging a more balanced approach in line with risk-based principles.
Overall, COGR’s communication highlights the sector’s desire for transparent, straightforward compliance guidance that supports both institutional efficiency and federal oversight. The letter closes with an invitation for continued dialogue, underscoring COGR’s commitment to constructive collaboration with OMB in refining compliance expectations and practices.
