The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted detailed comments to the National Science Foundation regarding proposed common disclosure forms for Biographical Sketch and Current and Pending (Other) Support. COGR generally supports harmonizing federal disclosure requirements but highlights several challenges with the proposed forms, emphasizing the need for clearer definitions, examples, and guidance to reduce ambiguity and minimize administrative burden. The association questions the practical utility of certain data elements—such as some in-kind support disclosures and requirements to report startup companies unrelated to intellectual property—as well as the adequacy of the estimated completion time, which COGR believes is significantly underestimated.
COGR calls for critical assessment and elimination of unnecessary data fields, clearer differentiation among types of appointments and disclosures, and consistent reporting requirements and formats across agencies. It expresses concern over agency-specific variations that could undermine harmonization efforts and increase researcher burden, recommending a truly uniform, coordinated approach with input from stakeholders before implementation. For efficiency, COGR advocates for comprehensive integration of information technology, centralized resources and guidance, and timely, simultaneous adoption of final forms across all agencies. COGR appreciates the partnership with federal agencies in balancing research security with reduced administrative burden, and it offers ongoing cooperation to refine and implement these important policy tools.
